Measures Against Corruption

The Denka Group prohibits all forms of corruption, including acts that violate laws and regulations such as bribery and excessive entertainment and gifts that exceed social norms. Furthermore, the Business Conduct Guidelines stipulate that Denka Group officers and employees must comply with the anti-corruption laws of each country and region in which the Denka Group conducts business, including the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act 2010, and the Japanese Unfair Competition Prevention Act. The Denka Group also prohibits involvement in all forms of bribery, including bribery through third parties. Moreover, the Business Conduct Guidelines require Denka Group officers and employees (all executives and employees) to limit entertainment and gifts to legal and socially acceptable ranges, and to select business partners based on the best possible choices for the company in accordance with the Denka Group Sustainable Procurement Policy and Guidelines, rather than for personal gain.
Denka also raises awareness regarding the prevention of bribery when conducting transactions overseas and when expanding businesses into overseas markets, conducts due diligence to ensure that there are no corruption risks with target companies prior to M&As, and provides education to overseas subsidiaries.
In addition, a group company in Singapore has established internal regulations regarding entertainment and gifts that are more stringent than those required by local laws.

Companies must not engage in any transactions with anti-social forces or individuals involved in money laundering.

The Denka Group Ethical Regulations strictly prohibit the provision of benefits to anti-social forces. Furthermore, the Business Conduct Guidelines stipulate that Denka Group officers and employees must not have any relationship with anti-social forces and must respond firmly to unjust demands, including legal action. The Guidelines also state that Denka Group officers and employees must not be involved in or cooperate with criminal acts such as drug dealing, terrorism, arms smuggling, fraud, or money laundering.
Through the Denka Global Compliance Program, Denka conducts training for Denka Group officers and employees in Japan and overseas on preventing bribery and money laundering and cutting off relationships with anti-social forces and criminal organizations.
In addition to the above, the Legal Department is working to include anti-social force exclusion clauses and anti-corruption clauses in various contracts. In Japan, the General Affairs Department is taking the lead in these efforts, and, when necessary, is working with outside lawyers, police authorities, and specialized institutions to ensure that the Denka Group has no relationships with anti-social forces.