We emphasize not only compliance with laws and regulations but also compliance with internal codes and ethical codes. As well as conducting awareness-raising activities so that each person in the ULVAC Group acts with a spirit of compliance, we have established and are operating a range of institutions and regulations to ensure thorough compliance.
In order to further promote fair and highly transparent corporate management, ULVAC has established the Corporate Code of Conduct, to which all officers and employees are required to adhere, and conducts education. In addition, booklets are distributed to Group companies to raise awareness about the importance of compliance. We use this Corporate Code of Conduct as guidelines for asking ourselves whether our business conduct is "in the best interest of our customers," "correct in light of laws and social ethics," and "does not infringe human rights."
We conduct company-wide education on compliance, prevention of insider trading, prevention of harassment, prevention of misconduct in research activities, etc., for all employees of ULVAC, Inc. every year and the attendance rate is 100%. The education is designed to raise awareness not only in terms of knowledge but also to enable our employees to act appropriately.
In addition to operating an independent whistleblower hotline based on the Whistleblower Protection Act, we have also established an external whistleblowing contact. The system is structured such that confidentiality is ensured throughout the process of investigating the content of reports. By putting in place a whistleblowing system that allows whistleblowers to feel secure in their reporting, we aim to detect any misconduct early and take appropriate corrective action.
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 may be sought from external specialists, and thorough interviews that are as wide-ranging as necessary are 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, may be 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.
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