The ULVAC Group views compliance as a vitally important issue. In addition to conducting awareness raising 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 thorough compliance.
ULVAC has established a Corporate Code of Conduct comprising 18 items, conducted education, and distributed booklets to inculcate a culture of compliance, in order to ensure that the execution of the duties of officers and employees is compliant with laws and regulations and internal rules, and that we fulfill our corporate social responsibility.
ULVAC, Inc. is working to create a culture of compliance through awareness raising activities. As part of this effort, we conduct periodic and ad hoc online training and face to face training on corporate ethics, export compliance, prevention of insider training, prevention of harassment, and other topics, and test the degree of comprehension.
ULVAC, Inc. has adopted a whistleblowing system operated through the Internal Auditing Office, which is an independent body. The Internal Auditing Office also serves as the secretariat 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 such case, the report shall also be handled appropriately.
Individuals making reports are not treated unfavorably in any way. Reports can also be submitted anonymously.
After a whistleblower report has been received, the initial response is for the Compliance Committee of ULVAC, Inc. to conduct an investigation in order to establish the facts. This investigation is particularly mindful of fairness, and is conducted judiciously and thoroughly. If necessary, assistance maybe sought from external experts, such as lawyers, and thorough interviews that are as wide ranging as necessary may be conducted and analyzed.
The president chairs the Compliance Committee and the members of the Committee observe a strict duty of confidentiality in carrying out their duties.
In the event that, based on the results of an investigation by the Compliance Committee, it is deemed that a violation of laws or regulations has been committed, then the opinion of an external expert, such as a lawyer, maybe sought as necessary, steps will be taken to ensure that the violation ceases with immediate effect and improvement measures will be implemented, and those involved in the violation will be dealt with after deliberation by the appropriate bodies. In addition, the root causes of the violation are also investigated in order to formulate effective measures for preventing recurrence.