Compliance

ULVAC values compliance, and in addition to conducting awareness activities so that each person in the ULVAC Group acts with a spirit of compliance, we are establishing and operating a range of institutions and regulations to ensure more thorough compliance.

Establishment of a Corporate Code of Conduct

ULVAC has established a Corporate Code of Conduct comprising 18 items, conducted education, and distributed booklets to create a spirit of compliance, in order to ensure that the execution of the duties of officers and staff is compliant with the law and internal regulations, and fulfills our social responsibility as a corporation.

Corporate code of conduct

Compliance Education

ULVAC is working to create a spirit of compliance through awareness activities. As an element of this, we are conducting activities such as providing opportunities for regular and ad-hoc education and training.

Compliance Education

Whistleblowing System

ULVAC has adopted a whistleblowing system. The system operates through the Internal Auditing Office, which is under the direct authority of the president and has guaranteed independence. The Internal Auditing Office also serves as the office for the Compliance Committee, and it is structured to give full consideration to confidentiality throughout the process of investigating the content of reports. This system does not prevent the person making the report from selecting other institutions or organizations within the Company as the destination for the report, and in those instances, the report will be handled as appropriate to the circumstances. Anonymous reports are also accepted, and the people making the reports are not treated unfavorably in any way.

After a whistleblower report has been received, the initial response is for the Compliance Committee to investigate the facts. This investigation is particularly mindful of fairness, and is conducted judiciously and thoroughly. If necessary, assistance may be sought from external experts, such as lawyers, and thorough interviews that are as wide-ranging as possible may be conducted and analyzed. Also, the president of the Company shall chair the Compliance Committee, and members of the Committee shall observe a strict duty of confidentiality when carrying out their duties.

Dealing with Acts of Violation

If it is deemed that a violation of laws or regulations has been committed based on the results of an investigation by the Compliance Committee, then the opinion of an external expert, such as a lawyer, may be sought as necessary, immediate shutdown or improvement measures will be implemented, and those who were involved with the violation will be dealt with after deliberation by the appropriate institution. In addition, the fundamental causes that brought about the violation are also studied to formulate effective measures for preventing recurrence.