In order to further ensure compliance-focused management across the entire Denka Group and to identify and correct compliance related issues as early as possible, in October 2018, based on the guidelines set forth by the Consumer Affairs Agency, the Denka Group formulated its Group Policy on whistleblowing (Compliance Hotline Regulations) for each of the major Denka Group companies in Japan and overseas, which are also covered by the Denka Group Ethics Policy. Based on this policy, the Ethics Committee has established and is currently managing the Denka Group Helpline, which serves as an improved version of the former compliance hotline s-ystem. The Legal Department and the Audit Committee Department serve as the Ethics Committee secretariat, accepting whistleblowing and providing advice in Japanese and other languages from officers and employees of Denka Group companies and their family members by telephone, e-mail, fax, letter, and other means. In addition, to ensure that officers and employees of the Denka Group in Japan and overseas feel comfortable using the helpline, we have established several external helpline, including outside attorneys, to accept whistleblowing and provide advice in both Japanese and other languages. Further, in compliance with the Law for the Prevention of Power Harassment (Revised Law for the Comprehensive Promotion of Labor Measures), we have also established a "help desk for workplace harassment" to receive whistleblowing and provide advice on harassment and to address acts of harassment.
Based on this policy, an investigation team consisting of the secretariat and related departments conducts fact-finding investigations while protecting the confidentiality of the identity of the caller. When a problem is identified, in accordance with internal regulations, the relevant department and related departments work together to address and correct the problem as soon as possible, including disciplinary action, and provide feedback on the results of the investigation and any corrective measures to whistleblower. The policy stipulates that (1) appropriate whistleblowing using the compliance hotline system is a legitimate work action that contributes to the early detection of risks and the enhancement of corporate value; (2) in the operation of the Helpline, Denka imposes confidentiality obligations on the secretariat, investigation team, people working in conjunction with the team, management, and other company personnel, to ensure the anonymity of whistleblowers; and (3) Denka Group officers and employees are strictly prohibited from disadvantageous treatment or retaliation against whistleblowers.
The Ethics Committee encourages Denka Group officers and employees to proactively utilize this helpline by sending out messages from the President, distributing a handbook featuring instructions about how to use the helpline, posting posters in Japanese and other languages at each office and plant of the Denka Group in Japan and overseas, and making the information available through the intranet. Use of the helpline is also encouraged by distributing information about the compliance hotline system and contact points to all officers of the Denka Group in all compliance training in accordance with the Denka Global Compliance Program.