Fair Operating Practices

It is our belief that in carrying out business activities, we need to do more than just ensuring DNP’s and its employees’ compliance with laws and regulations but always remain fair and equitable, acting under high ethical standards that exceed the expectations of society. To help maintain and develop orderly, free and competitive markets and consistently undertake business activities that measure up to society’s expectations, we aim to instill and establish corporate ethics more firmly throughout the DNP Group.

Medium-to long-term vision

We help to maintain and develop orderly, free and competitive markets based on laws and social ethics and by always remaining fair and equitable.

SDGs Covered by the Vision

  • Goal 10: Reduced Inequalities
  • Goal 12: Responsible Consumption and Production
  • Goal 16: Peace, Justice and Strong Institutions

Performance Indicators to Monitor the Progress in Achieving the Vision and Activity Results

Performance indicators Targets Results
  • (1)Number of meetings of the Corporate Ethics Committee*1
  • (2)Bases holding Autonomous Corporate Ethics Training*2
  • (1)Hold the meeting once a month (12 times a year) or more.
  • (2)Achieve 100% (covering all applicable bases).
For most-recent fiscal year results
  • *1An organization overseeing internal controls, responsible for promoting a compliance framework to ensure that all business activities of the DNP Group are carried out in an appropriate manner. Consisting of directors and corporate officers in charge of organizational units within the head office, the committee holds regular monthly meetings to formulate and determine policies and various activity implementation plans concerning the compliance framework of the entire Group. The committee is also responsible for comprehensively inspecting, reviewing and providing guidance for the framework established and operated in accordance with the implementation plans.
  • *2Training provided on a continuous basis since 2003. The heads of each business division provide lectures on corporate ethics as a foundation of business and explain to their staff the issues and countermeasures relevant to the operations of their respective divisions.

Structure to Promote Management

Structure to Promote Management and Training

As an organization for overseeing compliance, DNP has established the Corporate Ethics Committee (Chairman: senior managing director), which is composed of directors and corporate officers in charge of each division and department at the head office. Additionally, we have established a Corporate Ethics Committee in respective business units and Group companies that execute operations and undertake multifaceted corporate ethics activities in accordance with management based on the Committee of Sponsoring Organizations of the Treadway Commission (COSO) framework.

DNP considers continuity,autonomy,positivity and efficiency to be crucial in promoting compliance-related management. DNP implements various training programs for the entire Group throughout the year with the aim of fostering such an organizational culture and strengthening its management foundation.

This is a schematic image of the DNP Group Structure for Ensuring Thorough Corporate Ethics. Under this scheme, the Head Office performs inspections and provides guidance and education while the Operating Units carry out reporting.

1Personnel evaluation system

We use corporate ethics as a basis of performance evaluation and promotion decisions made under the personnel evaluation system and strive to develop human resources who live up to society’s expectations with sincerity.

2Self-examination of compliance with law and rules

DNP’s business units and Group companies use evaluation items developed by the responsible head office division to perform self-examination and self-evaluation for constant improvements. This activity has been carried out since 1997 under the motto “Protect our company by ourselves.”

3Compliance evaluation system

Implemented in 2005 by the responsible head office division as a system to evaluate DNP’s business units and Group companies using common performance indicators. This evaluation is conducted twice a year on a regular basis.

4Corporate ethics training

We provide various education and training opportunities, as we believe that a high level of awareness and a correct understanding among employees will make our efforts related to corporate ethics more effective.

5Open Door Room*3

Established in 2002 as a whistle-blower system to receive inquiries and reports on matters concerning corporate ethics. We also set up an external helpline in 2015, in which lawyers receive relevant inquiries and reports. These are safe inquiry and reporting systems operated in accordance with the DNP Group Open Door Room Operating Standards, which are based on Japan’s Whistle-Blower Protection Act.

6Global Internal Whistle-blowing System*3

In 2020, we reviewed our internal whistle-blowing system and framework at our overseas bases and established the global internal whistle-blowing system as a new whistle-blowing contact point capable of multilingual responses. In this manner, we are proceeding to strengthen compliance at overseas bases by making quick and appropriate responses.

7Supplier Hotline*3

This hotline, established in 2009, receives information from suppliers on any misconduct (or possible misconduct) of DNP employees or other parties, which they have come to recognize during their transaction with the DNP Group.

  • *3The information we receive at each of these consultations and whistle-blowing contact points also encompasses problems related to human rights, labor, and graft and corruption, including bribery.

DNP’s Main Initiatives

Initiatives to Ensure Compliance with the Law and Social Ethics

At a meeting of the Board of Directors in 2007, DNP formulated the DNP Group Code of Conduct, which specifies 10 conduct rules such as “Compliance with the laws and social ethics” to be observed by all employees in carrying out corporate activities. Subsequently as well, we have regularly reviewed the Code of Conduct in accordance with changes in the social environment while we strive to permeate the Code each time through opportunities such as level-specific training. In addition, we set up the Open Door Room in 2002 and the multilingual global internal whistle-blowing contact in 2020. These serve as points of contact for consultations and reporting in the event of a misconduct problem that cannot be solved through consultations with superiors or surrounding employees or by one’s own department alone. In this way, we are working to ensure that the self-cleansing ability of our organization functions properly across the entire DNP Group. Regarding the issues that become evident through consultations and reporting, DNP addresses them appropriately and takes corrective measures as necessary. As a result of these efforts, no serious violations were found in FY2020.

Anti-Bribery Initiatives

As recent corporate activities expand beyond regional and national boundaries, regulations concerning bribery are being tightened in each country in order to ensure a fair and open competitive market. DNP has always prohibited employees from seeking profit through bribery and other dishonest means and stipulated so in the Code of Conduct. To further reinforce our efforts in this area, in 2018 we established various policies and regulations that include the DNP Group Anti-Bribery Policy, the DNP Group Anti-Bribery Regulations and the DNP Group Anti-Bribery Guidelines. In conjunction, we have externally disclosed our anti-bribery policy to express DNP’s approach and position while internally we hold briefing sessions for each organization and provide e-learning education for all DNP Group employees to ensure an awareness and thorough understanding of this policy. Concurrently, based on the anti-bribery selfcheck sheet, we check each item that includes the existence of any contingencies at subject business sites, application procedure results, and educational and enlightenment activity results.

Dealing with Political Donations and Anti-social Forces

DNP’s basic policy is to maintain political neutrality by not making political donation, either directly or indirectly. Therefore, there were no instances of any political contributions in the past three-year period up to 2021.To anti-social forces that negatively affect public order and sound activities of society, we also prohibit the provision of inappropriate payoffs.

Appropriate Tax Payments

The DNP Group will contribute to the socio-economic development of the countries and regions in which we do business, by complying with relevant tax laws and regulations and social ethics, and making appropriate tax payments.