The AGC Group's CSR
For Customers and Business Partners

2. Ensuring Fair Trade

The AGC Group's Approach

Measures for Ensuring Fair and Proper Corporate Activities

The AGC Group fully recognizes that fair and proper corporate activities are essential to its business operations. Accordingly, the AGC Group Code of Conduct has been established to guide the actions of every employee, and measures are taken throughout the Group as a whole to ensure fair trade, including compliance with antitrust laws and prevention of corruption.

Compliance with Antitrust Laws

In addition to the Group Code of Conduct that summarizes matters all employees must comply with in their work, the AGC Group has formulated and implemented global guidelines for compliance with antitrust laws. The Guidelines state that, when meeting with a competitor company, (1) the legality of the purpose of the meeting shall be fully examined 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 prepared.
Moreover, the Group is promoting face-to-face and e-learning education regarding compliance with antitrust laws in each region and organization. One of the global common priority audit items for internal audit is “Organization and procedure for compliance with antitrust law.” Audits of the state of compliance with these global guidelines are also implemented.

Status of Implementing Measures for Complying with
Antitrust Laws (AGC Group)

FY Number of participants in e-learning Number of internal audits
2017 995 63 (Group companies and divisions)

Preventative Measures for Anti-Corruption

The AGC Group Code of Conduct stipulates that the AGC Group maintains sound relationships with government agencies and other responsible organizations and individuals, and the Group works to comply with each country and region’s laws and regulations regarding anti-corruption.
In addition to the AGC Group Anti-Bribery Rules for public officers, the Group established and put into operation Anti-Bribery Guidelines in relevant countries in Asia that detail procedures, concepts and the basis of judgments.

Compliance with Laws for Contract Employees and the Worker Dispatch Act

The AGC Group conducts business in collaboration with business partners involving contracting companies and temporary workers.
In addition, the Group annually conducts a survey on compliance with contracting requirements at AGC's production plants and major Group companies in Japan, and has confirmed that compliance-related rules were observed in 2017. The Group will continue to make efforts to disseminate and thoroughly comply with contract requirements and comply with the revised Worker Dispatching Act.

Compliance with the Act against Delay in Payment of Subcontract Proceeds, etc., to Subcontractors

The AGC Group continually educates staff and managers to ensure compliance with the Act against Delay in Payment of Subcontract Proceeds, etc., to Subcontractors (Subcontract Act). Since 2009, the Group has conducted e-learning initiatives for employees who work with transactions affected by “the Act,” including employees located in Group companies in Japan.
In 2017, the Group conducted e-learning about the Act for approximately 6,700 employees. Additionally, in November, a liaison conference was held by approximately 20 subcontracting and purchasing management supervisors from each business division.

Prevention of Insider Trading

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 the prevention 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 Control Council Establishment Guidelines and the Insider Trading Prevention and Control Rules.

Furthermore, regular opportunities to learn about the AGC Group Code of Conduct are provided and information regarding the prevention of insider trading is thoroughly disseminated. Understanding of this information is 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 director or employee has concerns as to whether buying or selling stock could fall under insider trading, the Information Control Council prepares a system for review and works to prevent any instance of insider trading.