Regarding security export control that prohibits the export of products and technologies that lead to the development and manufacture of weapons of mass destruction, Denka requires its officers and employees to comply with export control laws and regulations through the "Denka Group Ethics Policy" and the "Security Trade Control Regulations," which form part of our internal regulations. Based on these regulations, we have established an Export Control Committee chaired by the President, and maintain and manage a security trade control framework, overseen by the Legal Department, which determines the applicability of products and technologies and reviews customer transactions. In addition, we strive to comply with the Foreign Exchange and Foreign Trade Act and the Export Trade Control Order by conducting internal audits and attending seminars outside the company.
Furthermore, the "Standards of Business Conduct" requires that officers and employees of the Denka Group comply with the export control laws and regulations of each country applicable to each export transaction, as well as laws and regulations related to economic sanctions. The Legal Department, which serves as the secretariat to the Export Control Committee, requires officers and employees of the Denka Group in Japan and overseas to comply with export control laws and regulations and economic sanctions in each country through the “Denka Global Compliance Program”. In addition, in order to realize a prompt internal approval process, working with relevant departments, the Legal Department has been implementing a workflow, known by officers and employees as the "Export Boss" workflow, to determine applicability and screen customer transactions and chemical substances using ICT tools in an effort to comply with security trade control regulations. The Legal Department also conducts checks and monitoring to prevent transactions with countries, regions and parties that are at risk of sanctions under economic sanction-related laws and regulations in an effort to comply with economic sanctions.