Compliance Management

Group Policy

Pursuing Open and Aboveboard Business Activities

Based on our Group philosophy, the "Sysmex Way," we define our view of compliance as "the conduct of open and aboveboard business activities on the basis of observance of laws and regulations and high ethical standards." In accordance with this definition, we have established a Global Compliance Code, in which particularly important conformance rules and behavioral guidelines for all Group executives and employees are detailed. In addition to Japanese, the Global Compliance Code has been translated into English and many other languages.

Global Compliance Code (Overview)

  1. Ensuring the Safety of Our Products and Services to Customers
    In all our corporate activities, we shall make it a matter of priority to provide our customers with safety and security in the operation and use of our products and services.
  2. Promoting Fair Dealing and Free Competition
    We shall comply with the laws and regulations of each country and region concerning the promotion of fair and free competition, deal fairly with all our customers and other business partners and conduct transactions under appropriate conditions. In addition, in relation to other companies in the same business, we shall not illegally, dishonestly or unreasonably restrict their business, nor shall we defame them.
  3. Fair and Proper Information Disclosure and Exercise of Complete Information Control
    Our corporate information, such as our Group’s financial condition and business activities, shall be disclosed in a fair, prompt, correct, and clear manner in accordance with applicable laws and regulations, and we shall exercise strict control over confidential information collected through our business activities so as not to infringe the rights of third parties.
  4. Implementation of Appropriate Research and Development Activities
    When carrying out research and development, we shall protect the dignity, privacy, and human rights of trial subjects, and shall comply with applicable laws and regulations to carry out our research activities in accordance with high ethical standards.
  5. To Respect Intellectual Property
    We respect both the rights of our Groupʼs intellectual property and the intellectual property of others. We shall not unlawfully acquire or use any confidential business information or the proprietary assets of others.
  6. To Maintain International Peace and Safety
    We shall comply with export-related laws and regulations, and shall not engage in any transaction which may impede the maintenance of international peace and safety.
  7. To Conduct Proper Accounting and Appropriate Tax Payments
    We shall always apply the appropriate accounting measures and recognize the tax obligations set forth in applicable tax laws and accounting regulations and standards.
  8. To Respect Human Rights and to Improve Occupational Health and Safety
    We shall support the Universal Declaration of Human Rights and Core Labour Standards, and respect fundamental human rights, and shall not commit acts such as discrimination or harassment. We shall also comply with applicable laws and regulations and endeavor to improve occupational health and safety. Further, we shall not commit any unfair labor practices against the personnel of the company.
  9. Prohibition of Conflicts of Interest
    We shall not attempt to gain any personal profit in the performance of our duties, and shall not make any unauthorized use of our Groupʼs assets, goods or information, nor shall we perform personal acts that may cause harm to the Groupʼs business activities or reputation.
  10. To Maintain Sound Relationships with Society
    We shall comply with applicable laws and regulations related to anti-bribery statutes and comply strictly with applicable laws regarding making political donations. The company shall not be intimidated by antisocial activities, behavior and groups, nor maintain any relationship with them.
  11. To Preserve the Global Environment
    We shall comply with environment-related laws and regulations, and respect the environment throughout our business activities, based on applicable laws and international standards, in an endeavor to preserve and improve the global environment.

Compliance Promotion Structure

Sysmex has put in place internal rules related to compliance. We are also working to enhance compliance awareness among employees.

The Group compliance officer chairs the Compliance Committee, which promotes compliance throughout the Group. Compliance officers in place at individual Group companies promote compliance at those companies.

Compliance Structure
Compliance Structure

Internal Reporting System

Sysmex has established and operates an internal reporting system for all Group companies.

In Japan, we have set up an internal reporting system known as the “Campanula Lines”. Through this system, we offer field consultations related to compliance-related issues such as bribery and human rights abuses, and work to resolve any issues quickly. The “Campanula Lines” allow our employees to seek consultations and file reports via e-mail, postal mail, or telephone through two lines (in-house and external). We have also established a line via the Audit and Supervisory Committee that enables employees to seek consultations and file reports related to the management team. Information received through these lines is handled anonymously and based on the Whistleblower Protection Act to shield from any disadvantage people consulting or providing information.

The “Campanula Lines” Internal Reporting System
The “Campanula Lines” Internal Reporting System

Overseas, consultation and reporting lines provide local-language responses.

In fiscal 2018, we fielded 14 enquiries from Japan and overseas. We conducted investigations regarding these enquiries and dealt with each of them appropriately.

Compliance Education

Providing Continuous Education on Compliance

To instill compliance, Sysmex positions employee education and awareness activities as the foundation of compliance promotion. Based on the Group compliance training program, we conduct various types of compliance education on an ongoing basis. During new employee and rank-based training, we take the opportunity to foster compliance with the Global Governance Code.

We are expanding our educational tools to provide more detailed explanations of the Global Compliance Code on such themes as promoting fair trading and prohibitions against bribery, insider trading, and discrimination or harassment. Through autonomous, planned educational and awareness efforts, we instill and promote compliance awareness within individual divisions and companies.

Main Compliance Education in Fiscal 2018

  • Conducted compliance training for new employees
  • Conducted compliance training for newly appointed managers
  • Conducted training on the control and protection of trade secrets for Group employees in Japan
  • Conducted human rights training related to harassment, including LGBT* employees, as well as on personnel administration and the Workers Dispatch Act, for new employees, mid-career recruits, and newly appointed managers
  • Conducted training on the Sysmex Promotion Code as well as other training to promote fair trade
  • Conducted training related to laws, regulations, and industry rules on ensuring transparency in relationships with medical institutions
  • Acronym referring to sexual orientation/gender identification (lesbian, gay, bisexual and transgender)
  • Conducted compliance training for new employees
  • Conducted compliance training for managers
  • Conducted training related to the European General Data Protection Regulation (GDPR)
  • Conducted training about rules to promote fair trading in the medical device industry