〔Corporate Governance〕CSR Management
The KOSÉ Group, in line with its Behavioral Charter that serves as the core of its Action Guidelines, is committed to the belief of its founders in having a “mind to follow the right path.” The KOSÉ Group strives to become a company that is trusted and supported by customers and the public at large through implementing self-governance, acting based on judgment in good faith and use of common sense, and respecting the rights of all persons concerned.
Establishment of the Corporate Governance System
KOSÉ Group Action Guidelines and code of conduct
The KOSÉ Group defines its Behavioral Charter and Code of Conduct (shown below), in the KOSÉ Group Action Guidelines. The Guidelines stipulate that employees are required to comply with laws and regulations, observe social norms, and make decisions and take actions in good faith and through the use of common sense at all times. They also encourage employees to make efforts to ensure they will continue to be trusted by the public.The Guidelines are made available to officers and employees via a groupware, and they are used as a training material for new employees in Japan. They are also available as a booklet in four languages (English, Chinese (simplified and traditional), Korean and Thai) for distribution to local employees in overseas offices.
KOSÉ Group Code of Conduct
1. We will comply with laws and regulations and pledge to observe the following standards in our relationship with customers and clients:
- We will provide excellent and safe products.
- We will provide appropriate information and services.
- We will not take advantage nor impose the KOSÉ Group’s position in our relationship with our clients for personal interests.
2. We will comply with laws and regulations and pledge to observe the following standards in our relationship with the community and society:
- We will work to improve the transparency of our corporate management and business operations as well as accurately and promptly disclose corporate information to ensure our corporate accountability to our customers, shareholders, investors and communities as well as society in general.
- We will ensure the appropriate management and protection of any information about our company and customers.
- We will make efforts toward environmental conservation through all of our processes including development, manufacturing, distribution and disposal by developing ecological products and by using energy and resources efficiently.
- We will use our intellectual properties appropriately and take steps to protect our intellectual property rights.
- We will maintain a healthy and honest relationship with the government and its administration.
- We will not conduct any antisocial act. We will take a firm stance in dealing with antisocial forces.
- We will respect customs and cultures in all countries and regions and comply with their laws and regulations.
3. We will comply with laws and regulations and pledge to observe the following standards in our relationship within our company and our employees:
- We will comply with our company’s rules and regulations.
- We will take steps to maintain a healthy office environment at all times, respect the human rights of each individual, and we will not engage in any action that constitutes discrimination.
4. We will take leadership in ensuring awareness and compliance with laws and regulations.
- Our management recognizes that the implementation of this Code of Conduct is its role.
- Our management will lead by example and ensure awareness and compliance.We will establish a compliance committee, stay open to internal and external feedback and foster mutual communication to establish effective internal systems.
Establishment of Compliance Help Desk
The Compliance Help Desk, available by phone and email, was established with the goal of finding illegal acts and violations of internal rules that are possibly being committed in the KOSÉ Group. All employees are made aware of this Help Desk through the KOSÉ Group Action Guidelines distributed to everyone upon joining the company, compliance training posters that are regularly posted, and a training material for Beauty Staff called the EMB Textbook, among others. It is also made available all the time via a groupware.
All information given through the Help Desk are handled in a way that ensures that the informant is not put at risk. With advice from external lawyers, the Compliance Committee acts on this information fairly and sincerely, works to get the facts early and resolve issues promptly.
A Compliance Help Desk for group companies overseas is also available where employees of each office can directly report to the head office via email. This information is also disseminated to employees.
Risk management and compliance education
The KOSÉ Group established Risk Management Compliance Committee and regularly holds compliance trainings for the continuous development of its employees.We also have a social media policy and implement activities that consider the risks in using social media.
Risk Management Orientation
An orientation for officers, managers, and executives is held every year to provide a venue to share information on the changes in laws, regulations and environment. With a goal of establishing company-wide risk management compliance maintenance activities, activities to drive awareness are held continually with the use of recent cases.
Training for All Employees (including temporary and part-time employees)
Every year since 2008, trainings that focus on the important issue of compliance is given to KOSÉ Group employees through the use of e-learning and handouts. Participation is managed strictly and all employees are encouraged to take part in them.
- FY 2012 Vol. 5 Learn Through Past Examples! Social Media Policy
- FY 2013 Vol. 6 Learn Through Past Examples! Information Management
- FY 2014 Vol. 7 Main Point and Reaffirmation! Personal Information Protection and Leakage Prevention
- FY 2015 Vol 8. Harassment in the Workplace
- FY 2016 Vol 9. KOSÉ Group Action Guidelines
The KOSÉ Group Action Guidelines was featured in FY 2016 and opportunities to learn about them once again were created. All employees are encouraged to make decisions and take actions in good faith and through the use of common sense in every possible scenario that may occur in daily work (information leakage, presents from clients, patronage to foreign officials, and others). Through e-learning, a total of 3,208 participants (2,808 domestic participants and 400 overseas participants (Japanese, English, and Chinese)) took part in a training about this topic.
Training for Beauty Staff
Since FY 2014, a training page entitled “Let’s Aim to become Compliance Beauties!” is published in the EMB Textbook that is issued 6 times a year as a training handout for Beauty Staff. Relevant cases that a Beauty Staff who engages with customers in many occasions must know are disseminated in the form of a four-panel manga.
Trainings for participants based on their groups
Newly-hired employees, newly-appointed managers, and managers of group companies take part in a compliance training specifically designed for their group once every year. Topics including introduction to compliance, information security, and harassment are delivered to each participant based on the participants’ needs. One-on-one trainings are provided to employees who are newly-assigned overseas as a part of risk management in a global business environment to ensure that they understand and comply with the country’s or region’s laws and regulations.
Compliance Training Month (December to January, every year)
Three types of compliance posters are created and distributed/posted in domestic group companies, offices and branches (73 locations in Japan).
With the increased adoption of information technology, it has become increasingly important to protect personal information. Recognizing that the protection of personal information is an important risk management issue, we updated the Management Regulations for Personal Information Protection, which were developed in 2005, to take account of current conditions. More specifically, we have strengthened the management system by creating a new position of Personal Information Manager, prepared a personal data register, revised the management manual and the reporting route for reporting security breaches concerning personal information, and placed emphasis on ensuring the implementation of the revised regulations. We are making sure that all employees are fully informed of and will implement appropriate management of personal information.
Personal Information Protection and Management System
Appropriate Disclosure of Information to Investors
A Financial Results Briefing is held twice a year for institutional investors and analysts. We are also focusing our efforts in IR activities to gain the understanding and trust of shareholders and investors through proper information disclosure by holding activities such as IR seminars for females.
Activities for Corruption and Bribery Prevention
The KOSÉ Group works to prevent domestic and international corruption and bribery to maintain the trust of the public by being sincere, just and fair at all times. Basic rules that guide our relationships with customers, clients, and the government are stipulated in the KOSÉ Group Action Guidelines and Basic Policy on Procurement and we strive to disseminate them to our officers and employees.
Dealing with Clients
- When selecting consignees, the selection is made from multiple candidates in accordance with the law through a fair evaluation. The KOSÉ Group’s will not take advantage nor impose the KOSÉ Group’s position for personal interests.
- Exchange of presents with clients is prohibited with the exception of cases within bounds of socially accepted norms.
- Deals with corporations or individuals that are deemed to have a special relationship with The KOSÉ Group will not be honored except for sales agreements.
- For new transactions, agreements are entered following the Basic Policy on Procurement.
Dealing with Public Officials
The KOSÉ Group established the KOSÉ Group Code of Conduct and KOSÉ Group Global Bribery Prevention Guidelines, conducts its operations within their bounds, and does not allow bribery to public officials and people in equivalent positions. We prohibit unlawful donations and promises of money, presents, services and other profits (including facilitation and payment) to public officials to gain deals and unfair profits, and continue to work to prevent corruption and establish and maintain fair business practices. We also conduct detailed audits and investigations in selecting distributors and agents and require prior agreement to our standards.
Facilitation and payment refers to small amount payments made to public officials in order to facilitate the processing involved in government services where they do not have discretion.