System to Promote Compliance

The Denka Group has established the Denka Group Corporate Ethics Policy as the highest-level compliance regulation.
This Policy aims to maintain and secure the trust of society and to achieve the sustainable development and continuation of the entire Group by ensuring that all officers and employees (hereinafter referred to as "personnel") of the Denka Group practice compliance. To achieve these aims, this Policy stipulates the standards of conduct, organizational systems, responsibilities of relevant personnel, and the establishment of whistle-blowing systems that all personnel must comply with.
Based on this Policy, the Company has established the Ethics Committee, which is chaired by the President, at the Board of Directors. This Committee oversees various initiatives regarding compliance as a whole, including checking the progress of compliance promotion activities, responses to issues, and deliberating activity plans for the next fiscal year.
At the same time, the Board of Directors appoints an Executive Officer (Chief Compliance Officer (CCO)) in charge of promoting compliance. The CCO assists the President, who is the chairperson of the Ethics Committee, and the Legal Department, Internal Control Department, Human Resources Strategy Department, and other management departments of the Company conduct compliance promotion activities.
Through these efforts, the Company is promoting the strengthening of compliance systems for the Denka Group both in Japan and overseas based on the Corporate Ethics Policy and the organizational and responsibility systems stipulated in this Policy.
The Corporate Ethics Policy is reviewed regularly by the Ethics Committee, and if necessary, it can be revised with the resolution of the Board of Directors.

Denka Group Standards of Business Conduct

The Denka Group has established the "Denka Group Ethics and Compliance Guidelines - Business Conduct Standards (Standards of Business Conduct)" to further specify the standards of conduct that all officers and employees must comply with as set forth in the Denka Group Corporate Ethics Policy.
These guidelines set forth global standards for conduct (guidelines) that are required of all officers and employees to practice the Denka Group's management philosophy and values, and serve as a basis for ethical and legal conduct.
The guidelines cover a wide range of topics, including basic rules for conducting business in a proper manner, environmental preservation and safety, fair trading, export control and economic sanctions, insider trading, personal information management, quality compliance, confidential information management and intellectual property rights, exclusion of antisocial forces, corruption prevention, and respect for human rights including compliance with labor laws. The guidelines are distributed in booklet form (in Japanese, English, and Chinese) to all officers and employees of Group companies so that each person can use them as a guide in their daily work. The guidelines are also posted on the intranet and made widely known.
These Business Conduct Standards are subject to periodic review and revision by the secretariat of the Ethics Committee as stipulated in the Corporate Ethics Policy.

Denka Group Ethics and Compliance Guidelines Standards of Business Conduct (PDF format/7.08MB)

Awareness-raising and training on compliance

The Denka Group has established October as "Compliance Awareness Month" to ensure that all Group employees prioritize compliance and to promote the establishment of a corporate culture in which compliance is prioritized. During this month, the Group disseminates messages from the President and conducts various activities through the Ethics Committee, including e-learning training, surveys, and obtaining pledges of compliance with laws and regulations for all officers and employees of Group companies.
In the e-learning conducted in FY2024, more than 6,000 people participated across the Group.
In addition, the Legal Department, which serves as the secretariat for the Ethics Committee, extracts key compliance risks from the survey results and holds training sessions in those areas, as well as disseminating information via the intranet as needed to improve compliance literacy among officers and employees.

Group training at Denka headquarters

• ※1Employees without a business e-mail address are not eligible for e-learning.
• ※2Percentage of participants (6,439) to total consolidated employees (6,542) as of March 31, 2025.

Establishment of group policies (common regulations for the entire group) and company-wide common regulations

The Denka Group is currently working on establishing group-wide common regulations (group policies) as part of our efforts to thoroughly manage compliance risks across the Group.
By fiscal 2024, we aim to complete the establishment and development of group policies regarding occupational health and safety, quality compliance, respect for human rights, harassment prevention, sustainable procurement, bribery and corruption prevention, personal information protection, and information security, in addition to a complete revision of the former Denka Group Ethics Regulations into the Denka Group Corporate Ethics Policy. We are also planning to hold in-house briefings and training sessions for the officers and employees of Group companies to ensure that these established group policies are widely known.

Addressing Compliance Issues

In August 2022, the Denka Group established the Compliance Violation Case Handling Basic Regulations to address compliance issues raised through internal whistleblowing and line management in a fair and appropriate manner. These regulations stipulate specific provisions regarding internal reporting of compliance issues, investigation systems, deliberation procedures in the event that issues are recognized, and internal awareness-raising measures for corrective action and prevention of recurrence. When compliance issues arise within the Company, the internal investigation team conducts investigations in accordance with these regulations and seeks to resolve and correct issues promptly, including the implementation of necessary disciplinary actions.
When a serious and urgent compliance issue, such as a violation of laws and regulations, is recognized, a temporary Ethics Committee is convened without delay in accordance with the Denka Group Corporate Ethics Policy. The committee members, including the President and audit committee members, determine the investigation policy and system and confirm and deliberate on the investigation status and results.
Furthermore, to respond to compliance issues promptly and effectively, the permanent members of the Ethics Committee below the CCO hold monthly Ethics Committee Liaison Meetings to confirm the progress of issue responses and discuss compliance activities.
In addition, to summarize responses to compliance issues and preventive activities and deliberate on the compliance activity plan for the next fiscal year, a regular Ethics Committee is held every May.
The Ethics Committee Secretariat regularly reviews the effectiveness of the Denka Group Corporate Ethics Policy and the Business Conduct Guidelines in light of the status of compliance and social trends.