AGC General Counsels (From left: Group and Japan/Asia, Europe and North America)
In 2006, the AGC Group established a system to report disputes and litigations on a monthly and as-required basis. This system is designed for the prompt identification and management of disputes and lawsuits throughout the Group. Through this global legal management system, dispute- and litigation-related information is collected at the Group General Counsel level; the Counsel then reports the information to the Group CEO and the rest of top management. Utilizing this system, and in cooperation with the Regional General Counsels and related departments, the Group is working to reduce the Group's legal risks.
In addition, the AGC Group is implementing both organizational and personnel measures in response to the Group's global legal needs, including the assignment of an employee dedicated to legal issues in China, and holding legal meetings attended by members from the United States and Europe where relevant policies are shared and confirmed. Progress of disputes and litigations are reported regularly to the Board of Directors.
In addition to the Group Code of Conduct, the AGC Group has formulated and implemented global guidelines for compliance with antitrust laws. Under the guidelines, when meeting with a competitor company, 1) the purpose of the meeting must be carefully reviewed by a supervisor in accordance with the guidelines and participation shall be allowed only on an extremely limited basis, 2) advance permission to attend must be obtained from a supervisor and 3) following attendance, meeting minutes must be recorded and reported to a superior. In addition, the Group is promoting antitrust law compliance training for each region and organization. “Systems and mechanisms for complying with antitrust law” is given as a common global priority item in internal audits, and audits of the state of compliance within the guidelines are implemented.
Antitrust law education in Singapore
The AGC Group provides continuous training on antitrust law globally.
In 2015, online training (e-learning) on the AGC Group Code of Conduct, which includes content on antitrust law, was implemented for Japanese employees (AGC Asahi Glass and Group companies in Japan). In addition, online training on antitrust law was implemented in North America.
Training further tailored to specific duties was implemented at Group companies in each country and region, based on local antitrust law enforcement conditions. In Japan, classroom training and stratified training tailored to the major risks of each business division was implemented. In Asia, classroom training was implemented for approximately 500 management, legal supervisors and marketing-related personnel in Singapore, Indonesia and China. In China, legal supervisors traveled to all sites to implement classroom training. In North America, Europe and Brazil, classroom training was continuously implemented for management and for marketing and procurement personnel.
The AGC Group Code of Conduct stipulates that the AGC Group maintains sound relationships with government agencies and other responsible organizations, and the Group works to comply with each country and region’s laws and regulations regarding anti-corruption.
In addition, as the prevention of bribery and other corrupt practices is being reinforced worldwide, the AGC Group is proactively promoting employee education.
In 2015, a lecture panel by external experts on the subject of anti-corruption was hosted for AGC Group management. In addition, a short-term diagnosis of the global compliance system was performed by external experts and policies were implemented based on the results. In 2016, the Group plans to establish the AGC Group Anti-Bribery Rules, which explicitly express our approach to prevent bribery involving public officials, and the Anti-Bribery Guidelines—China Version, which define the detailed procedures and grounds for judgment. Both sets of rules and guidelines will be put into place.
Contract workers and temporary workers dispatched from employment agencies play an important role in the many businesses of the AGC Group. At AGC Asahi Glass, in accordance with revisions to the Worker Dispatch Act, the company will continue to strive for the appropriate use of contracting and dispatching.
In addition, the Group annually conducts a survey on compliance with contracting requirements at AGC Asahi Glass production plants and major Group companies in Japan. The 2015 results also showed that compliance was properly observed. In the future, the Group will take further steps to enforce the legal employment of contract and temporary workers while complying with the revised Worker Dispatching Act with an eye to achieving total compliance.
As initiatives to ensure thorough compliance with the Act against Delay in Payment of Subcontract Proceeds, etc., to Subcontractors (hereafter “the Act”), the AGC Group confirms transaction details and conducts ongoing training of supervisors and managers.
Since 2009, the Group has carried out online training targeting employees who work with subcontractors, including those located in Group companies in Japan.
In 2015, the Group implemented online training with regard to the Act targeting approximately 5,900 employees. Additionally, in November, a liaison conference was held by approximately 20 subcontracting and purchasing management supervisors from each business division. At the conference, participants shared information regarding the status of administrative authorities’ Act enforcement and the results of each division’s self-checks, and are working to improve at the management level.
In order to protect its shareholders and investors, and ensure the fairness and reliability of securities markets, the AGC Group is making every effort to spread awareness of insider trading.
In addition to clearly stating in the AGC Group Code of Conduct that insider trading is forbidden, systems intended to prevent it are stipulated in the Information Management Joint Council Establishment Guidelines and the Insider Trading Management Regulations, which are actively employed.
Regular opportunities to learn about the AGC Group Code of Conduct are implemented, and information regarding the prevention of insider trading is thoroughly disseminated. These are reaffirmed when oaths are taken. Special training is implemented for directors, executive managers and personnel in specific posts (corporate planning, accounting, finance, Corporate Communications, IR, etc.)
Furthermore, if an AGC Group manager or employee has concerns that insider trading could occur when purchasing stocks or undertaking other financial transactions, the chairperson of the Information Control Council will set up a prior examination of the legality of the transaction in an effort to ensure that insider trading does not occur.