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Compliance Promotion

Our Basic Policy

The Asahi Group established the Asahi Group Code of Conduct in January 2019 as a means of achieving the Asahi Group Philosophy (AGP), which applies across the Group.

We understand compliance to mean acting in a way that society expects a corporation to act. This includes observing laws and public regulations, company regulations, and other rules in addition to social norms and the like, or in other words, never betraying the relationship of trust with stakeholders. As such, the Asahi Group Code of Conduct defines the specific actions that all officers and employees should take, and by making all personnel fully aware of the Code of Conduct we are working to ensure that they act with compliance as their top priority. In addition, the Code of Conduct has been translated at our overseas Group companies as needed (into a total of 16 languages), and all personnel are familiarized with it.

The Board of Directors is responsible for monitoring compliance with the Code of Conduct. The establishment and/or revision (excluding minor changes) of the Code of Conduct shall be resolved and determined by the Board of Directors.

 

Compliance Promotion Systems

The Asahi Group established the Asahi Group Ethics/Compliance Policies to promote compliance management. Based on the Policies, we clarify our internal system and operation and promote fair and highly transparent business activities founded on compliance in the broad sense of the term, going beyond the observance of laws and regulations.

The Asahi Group established its Compliance Committee as the highest-order organ to deliberate on compliance. The Committee consists of directors, the head of Legal Section, and other persons of Asahi Group Holdings appointed separately by the Committee. It monitors and works to improve awareness of the Asahi Group Code of Conduct and operation of the Clean Line System (whistle-blowing system) to raise the efficacy of compliance promotion activities.

Furthermore, the chief executives of all of Asahi Group's operating companies are responsible for observing and promoting compliance with the Asahi Group Code of Conduct, while the legal departments of the Group’s operating companies in both Japan and overseas cooperate with one another to structure the Group’s compliance promotion system.

Efforts to Prevent Corruption

In response to tightening restrictions on bribery※ in countries around the world, the Asahi Group established the Asahi Group Anti-Bribery Principles, which applies to all of the Group’s officers and employees, and is making Group-wide efforts to build a system to prevent corruption.

The Asahi Group Anti-Bribery Principles prohibits such acts, including the direct and indirect provision or receipt of bribery and the provision of facility payments. We require all of Asahi Group companies’ business partners and intermediaries including legal agents to adhere to the Principles, prohibit acts of corruption and ensure their full awareness. In cases of acquisitions, mergers, joint ventures, and other similar arrangements, we will conduct an assessment of the counterparty in advance in accordance with the risk levels of corruption.

In addition to conducting regular self-inspections on the prevention of corruption, we also review the Principles and corresponding procedures on a regular basis and make revisions and improvements as required.

For businesses with high risk of corruption, we have also established guidelines in order to prevent acts of corruption, and we are making our personnel fully aware of the guidelines.

To educate our employees on this issue, we conduct training on the prevention of corruption.

The Board of Directors is responsible for monitoring compliance with the Asahi Group Anti-Bribery Principles, while the Compliance Committee oversees compliance with the Asahi Group Code of Conduct, which includes stipulations on the prevention of such corrupt acts as bribing public officials, providing entertainment or gifts, making inappropriate donations, associating with organized crime elements, or being involved in money laundering. The Compliance Committee reports its findings to the Board of Directors.

The terms, “Bribe-giving”, “Bribe-taking” and “Bribery” used in the Asahi Group Anti-Bribery Principles are defined as follows:

    
  • "Bribe-giving" means providing, proposing, or promising monetary or other benefits aiming to cause an act or omission by any party in his official capacity such that another would receive an improper interest in connection with business.
  • "bribe-taking" means receiving, requesting or being promised to receive monetary or other benefits of personal interest or interest of a third party with the aim to cause an act or omission by any party in his official capacity such that another would receive an improper advantage in connection with business.
  • "Bribery" means Bribe-giving and Bribe-taking.

Violations of the Asahi Group Anti-Bribery Principles within the Asahi Group in 2020

Employees subjected to disciplinary action including discharge None
Corruption-related fines, monetary penalties, or settlements None

Implementation of Compliance Training

The Asahi Group companies independently plan and implement ethics and compliance training with the optimal content and method suited to their circumstances with the aim of enhancing their compliance levels.

Compliance training conducted in 2020

In November 2020, an e-learning course on the Asahi Group Code of Conduct was held for approximately 14000 employees of the Asahi Group's major operating companies in Japan. Each company also made such efforts as providing an explanation of the Asahi Group Code of Conduct during new employee induction training.

Monitoring System

Internal Audit

Asahi Group Holdings checks compliance with legal and company rules in internal audits conducted by our Internal Audit Section every year.

Compliance Survey

The Asahi Group conducts a global compliance survey of major Group companies once a year. The aim is to verify the level of awareness of the Asahi Group Code of Conduct and identify the legal risks present, then apply the findings to making improvements.

Whistle-Blower Scheme

A confidential whistle-blower scheme called the Clean Line System has been set up to encourage early detection of risks associated with the corporate activities of the Asahi Group and prevent risks from developing into serious problems. Where the matter involves a breach or potential breach of the relevant laws and regulations or stipulations of the Asahi Group Code of Conduct including the prohibition of corruption, and where the matter cannot be resolved satisfactorily by the conventional organizational structure, the whistle-blower is encouraged to approach contacts either inside or outside the company. Members of the Audit & Supervisory Board, as well as the Head of General & Legal Affairs Department of Japan Headquarters of Asahi Group Holdings are the internal points of contact, while an outside attorney serves as the external liaison. Anonymity is assured for all whistle-blower reports. A report can be made via letter, in-person and email, and can be sent at any time of the day or night.

All notifications are thoroughly investigated by the Head of General & Legal Affairs Department of Japan Headquarters or equivalent with the cooperation of relevant parties. If problems are identified they are dealt with as appropriate, then the whistle-blower is informed of the results. The Asahi Group Internal Reporting System Policies guarantee confidentiality and stipulate that no person shall suffer detrimental treatment as a result of making a notification.

The Asahi Group is committed to ensuring that employees are fully aware of the Clean Line System. A link is displayed prominently on the top page of the company intranet, and details are also provided on the Compliance Card carried by all employees.

Our Regional Headquarters have established contact points for internal reporting, and are dealing with matters reported as appropriate in the local languages used by local employees.

Number of Clean Line reports

  2016 2017 2018 2019 2020
Types of Reports Harassment/bad behavior 13 19 25 33 22
Mismanagement of employees 1 13 14 7 17
Violation of laws, regulations or company rules 0 7 2 9 6
Using company resources for personal gain 0 1 0 6 0
Other 1 1 0 6 2
Total 15 41 41 61 47

Figures for domestic cases only.