Compliance Promotion Structure
Renesas Electronics’ Internal Control Promotion Committee, chaired by the CEO, deliberates and makes decisions on compliance matters, and reports key issues to the Executive Committee and the Board of Directors. The Legal Division oversees all matters relating to promoting compliance and designates the divisions/offices in charge of compliance which are responsible for each compliance risk category.
General managers of Renesas Electronics divisions and offices and presidents of Group companies are responsible for compliance in their respective organizations. They cooperate with the divisions/offices in charge of compliance in each field in deciding on and implementing the measures necessary to promote compliance.
If a compliance violation does occur, the division, office or Group company reports it promptly to the head of the division or office in charge of compliance for the field in question and to the chief of the Legal Division.
Compliance Promotion Activities
The division or office in charge of compliance in each field monitors trends in the establishment or revision of laws, etc., that underlie compliance promotion. Then it raises awareness by preparing regulations and manuals, providing training and practicing communication, and performs monitoring.
The Legal Division conducts training and awareness-raising initiatives on all compliance matters. All Group employees, moreover, fill out a questionnaire to verify that compliance has taken root. If necessary, the results are shared with the divisions or offices in charge of compliance, which find this information useful when they revise the measures necessary to promote compliance.
Division and office heads and Group company presidents lead activities that promote compliance within their own organizations.
Major Compliance Risks
- Fraudulent order/fictitious revenue
- Subcontract Law violations, camouflage contracting, illegal importing, interest-conflicting transactions
- Illegal export
- Computer viruses, illegal software copying, unauthorized access
- Deceptive advertising
- Infringement of other parties’ intellectual property rights
- Antimonopoly Law violations (cartels, etc.), transactions with antisocial forces, confidential/personal information leaks, insider trading, internal illegal activities
- Defective products, product data falsification
- Accounting fraud
- Inappropriate relationships with sales partners, illegal conduct against sales partners
- Human rights abuses (sexual harassment, etc.), occupational accidents, corporate entertainment/gift-giving scandals, illegal political donations
- Environmental damage, contamination involving specified hazardous substances
The Renesas Electronics Group executives and employees may encounter a situation in which they are not able to consult with or report to their supervisors or divisions and offices responsible due to certain reasons and circumstances, even when they have identified compliance-related problems. To deal effectively with such situations, the Company has established the Renesas Electronics Group Hotline (“Group Hotline”) as a whistleblower’s contact for consultation by executives and employees of Group companies and for reporting such problems.
In addition, by employing a third party who serves as an external contact point, we have established a system under which the anonymity of the person reporting is protected at his or her request. This external contact point can be accessed not only by the Group’s executives, employees or temporary staff, but also by members of the Group’s suppliers and authorized distributors. The Company’s internal rules clearly prohibit the adverse treatment of those who consult with or report to the Group Hotline. The Company has posted such rules on its websites both internal and external so that people can use the Group Hotline without anxiety. The hotline was used 12 times in fiscal 2018 for consultation or reporting.
Initiatives against Antisocial Forces
In June 2007, the Japanese government announced guidelines for enterprises to prevent damage by antisocial forces. The movement to eliminate antisocial forces steadily became prevalent in all parts of society. In the Renesas Electronics Group Code of Conduct and Basic Rules for Rejecting Transactions with Antisocial Forces, the Group likewise prohibits employees from doing business with antisocial forces and has set up a system to prevent such transactions. Specifically, there is a self-verifying system at each workplace and affiliated company that uses self-discipline to decide whether transactions can go forward and works to prevent business with antisocial forces. In addition, workplace managers and affiliated company presidents perform self-audits and check on the status of their businesses.
Security Export Control Initiatives
The Renesas Electronics Group’s products are used in industries around the world. To ensure that these products are not used to disrupt international peace and security, the Group must manage our exports appropriately day to day.
Therefore, the Group complies with laws and regulations regarding security export controls, and by setting out in a compliance program the independent actions it should take from the perspective of risk management, it attains a high level of management. Moreover, we periodically audit all sites in Japan and overseas to ensure they are constantly maintaining appropriate control, and we provide systematic position-specific and job-specific training to all employees.
Renesas Electronics has obtained a Special General Bulk License from the Ministry of Economy, Trade and Industry, and furthermore has been certified as an Authorized Economic Operator (AEO) exporter by Tokyo Customs of the Ministry of Finance of Japan.
Confidential Information Management/Personal Information Protection