THE NEW VALUE FRONTIER

Compliance

The Kyocera Group operates within a corporate culture guided by our Kyocera Philosophy and its general criterion for decision-making: "Do the right thing as a human being." This criterion emphasizes the concept of coexisting harmoniously with society amid the traditions and cultures of our host communities. Recent years have seen an increase in international laws and regulations that reflect the spirit of our philosophy, and other corporations are adopting their own similar approaches. The Kyocera Group understands the importance of legal compliance and conducts business in accordance with all applicable laws and regulations.

Compliance Initiatives

The Kyocera Group has established a "Kyocera Compliance Statement" to clarify its stance towards compliance activities on a global level, which was announced both within the Company, and to external stakeholders. This Kyocera Compliance Statement has been issued across the Group, and is used to ingrain a deeper awareness of compliance issues. Starting with the General Data Protection Regulation (GDPR) in Europe, the introduction of laws stipulating strict handling of personal data, including regulations on transferring personal data outside of one's own country or region, has been accelerating worldwide in recent years. To appropriately respond to incidents of personal data breaches due to successive cyberattacks and global digital marketing initiatives, our company will work in collaboration with relevant departments and overseas group companies and will continue to investigate and implement measures related to the handling of personal information. In addition, as the Company's business activities expand outside of Japan, we must comply with personal information protection restrictions imposed by each country. After the General Data Protection Regulation (GDPR) took effect in Europe, we have seen a push to introduce strict laws concerning the handling of personal data in countries around the world, including new restrictions on the transfer of personal data and other information outside a country or region. We will continue to cooperate with all divisions and Group companies to study and implement measures for the handling of personal information to address concerns regarding to global digital marketing. Further, in a step toward addressing the recent tightening of anti-corruption laws and regulations, of which many international companies have run astray, we have published the Kyocera Group Basic Policy on Anti-Corruption as our guide for global business activities. This compliance system is defined in the anti-corruption regulations of Kyocera Corporation. Additionally, Group companies are implementing internal regulations and training employees on anti-corruption rules and procedures.

Kyocera Compliance Statement

The Kyocera Group applies the spirit of its Corporate Motto "Respect the Divine and Love People - Preserve the spirit to work fairly and honorably, respecting people, our work, our company and our global community" as its basic code on global compliance with laws and regulations.

Since its founding, the Kyocera Group has maintained a fair and honest corporate culture as established in the Kyocera Philosophy whose central principle is "Do what is right as a human being". In alignment with the Kyocera Philosophy, we have never accepted anticompetitive practices such as cartels or acted to endorse criminal organizations, and we have consistently maintained appropriate accounting practices according to the Kyocera Accounting Principles.

"Living Together" has been the foundation of our corporate activities, and as such, we honor coexistence within society and diversity, the traditions and cultures of the related countries, and the humanity of employees, and pursue both material and spiritual happiness for our employees with concern to their physical and emotional health.

Today, laws and regulations that align with Kyocera Group's basic principles are being enacted across the globe. The Kyocera Group fully supports this movement and complies with competition laws, anti-bribery regulations, personal information protection laws, tax laws (including laws preventing facilitation of tax evasion) and any other related laws and regulations of the related countries. The Kyocera Group also respects the efforts of international organizations and countries to protect human rights.

Corporate compliance with laws and regulations is a subject of increasing attention in society, and compliance demanded by society is increasing. The Kyocera Group understands that compliance with laws and regulations is an important endeavor essentially required by the Corporate Motto and Kyocera Philosophy that have regulated our company since founding, and that compliance with related laws and regulations in all countries of the world where the Kyocera Group conducts business is crucial for maintaining the trust of customers, business partners, suppliers, investors, employees and any other stakeholders, therefore the Kyocera Group actively establishes specific departments and prepares regulations for the cause to ensure Group-wide and global compliance with laws and regulations.

January 1, 2020
Kyocera Corporation
Goro Yamaguchi, Chairman
Hideo Tanimoto, President

Global Five-Regional Legal and IP System

Our proactive M&A strategy has seen the number of Kyocera Group companies grow to around 300, a figure expected to increase in future. For efficiency, the Corporate Legal and Intellectual Property Group divides the globe into five regions. Each local headquarters works with the Kyocera Group companies in its region to build a system for reducing legal risk and ensuring to compliance activities. Building a network to facilitate cooperation between Group companies is vital for the efficient implementation of compliance activities globally. To this end, we established the "Kyocera Group Global Legal Compliance Meeting", for the headquarters and operating companies in each region to our policies alongside local challenges. These conferences are actively held in each of the five regions, including Americas, Europe / Middle East / Africa, Japan / Korea, China, and Asia-Pacific, prompting lively discussion based on local circumstances.

Images:Kyocera Global Legal Compliance IP Meeting
Kyocera Global Legal Compliance IP Meeting

Compliance Promotion Month

We designate December of each year as Kyocera's "Compliance Promotion Month" and conduct awareness and education programs for all employees. Additionally, to provide an opportunity for each individual to re-recognize the importance of compliance activities, we issue a message from the president, share important points during morning meetings ("quick notes"), and conduct e-learning sessions for all employees. Furthermore, we are implementing new initiatives in line with the times, such as establishing a consultation desk where employees can easily ask questions about compliance via chat. By sharing these initiatives with each group company, we aim to promote compliance activities and build a robust group structure.

Compliance Meetings

At Kyocera, to promote compliance activities in the business field, we appoint a responsible person in each business division and hold meetings twice a year where these responsible persons gather. In these meetings, indirect departments and domestic group companies also participate, and we plan annual activities, check progress, share information, and exchange opinions.

Compliance Information Dissemination Site

To ensure that employees can smoothly access compliance-related information and to enhance internal information distribution, we are utilizing digital tools to build an internal site that is easy to view and understand. Moving forward, we will continue actively sharing information in line with legal revisions and changes in societal expectations to maintain and improve employees' compliance awareness.

Fair and Free Competition

The Kyocera Group bases its decisions on "what is right as a human being," and believes it is important to maintain and promote fair and free competition. As part of these activities, the Kyocera Group publishes the Kyocera Group Global Antimonopoly Law Compliance Manual and disseminates the Antimonopoly Law and the Antimonopoly Law Compliance Regulations to employees in Japan and overseas, which specifically stipulate matters to be observed as employees. The Kyocera Group conducts training on global antitrust law and complementary training for all Kyocera Group employees every two years, alternating between the two. In addition, interview-style education for management-level employees is conducted. We will continue to improve understanding of the Antimonopoly Law and ensure compliance with the Antimonopoly Law and other related laws and regulations through ongoing education. In recent years, considering the time that has passed since the introduction of the Antitrust Law Compliance Regulations, we have been confirming the operational status of these regulations within each group company and monitoring to ensure they are being appropriately implemented. By continuing education and monitoring, we aim to improve our company's understanding of the Antitrust Law and ensure strict compliance with related laws, including the Antitrust Law.

Image:Kyocera Group Global Antitrust Compliance Manual
Kyocera Group Global
Antitrust Compliance Manual

Ensuring Fairness in Outsourced and Subsidized Projects

The Kyocera Group (in Japan) has established "Management Regulations for Commissioned and Supported Projects" to clarify the management system for commissioned or supported projects funded by public research organizations or administrative agencies and to prevent misconduct, and is committed to appropriate research activities.

Measures for Anti-Corruption

The Kyocera Group has established a basic policy on anti-corruption and publicizes the basic policy in order to let its basic stance of actively working to eradicate corruption known both internally and externally. The Kyocera Group makes thorough efforts based on the Kyocera Philosophy to prevent bribery by rolling out anti-corruption regulations established at each group company. These anti-corruption regulations prohibit not only bribery such as the offering and receipt of excessive gifts or entertainment, but also activities that deviate from ordinary business practices. The Kyocera Group also provides anti-corruption training internally so that the employees are well aware of basic policies and anti-corruption regulations.

Kyocera Group Basic Policy on Anti-Corruption

The Kyocera Group has been conducting business based on the Kyocera Philosophy. The basis of the Kyocera Philosophy is "Do the Right Thing as a Human Being". The Kyocera Philosophy emphasizes the importance of conducting business activities in a fair manner, as exemplified by principles such as, "Pursue Profits Fairly" and "Insist on Playing Fair". Therefore, in light of the Kyocera Philosophy, it is impermissible for Kyocera Group employees to take unfair measures to gain profits.

Anti-corruption regulations have been strengthened around the world, and efforts to curb corruption are recognized as a social responsibility of the company. The Kyocera Group is a participant of the "United Nations Global Compact", which requires its participants to follow its principle, "Businesses should work against corruption in all its forms, including extortion and bribery". In response to the efforts to eradicate corruption, the Kyocera Group has formulated the Kyocera Group Basic Policy on Anti-Corruption ("Basic Policy on Anti-Corruption") in accordance with the Kyocera Philosophy and the Kyocera Compliance Statement, in order to become "The Company" which is respected by all.

Prohibition of Bribery

  • The Kyocera Group will not provide, offer or promise to provide bribes to any person directly or indirectly, but will compete based on quality and price and pursue profits fairly.
  • Officers and employees of the Kyocera Group will not engage in acts of bribery, including making facilitation payments to public officials, or those equivalent to public officials, or persons with business influence, even if we are asked to do so. Officers and employees of the Kyocera Group will follow the straight and true road.
  • Officers and employees of the Kyocera Group will separate personal matters from business and will never receive bribes.

Establishment of the Anti-Corruption Compliance System

The Kyocera Group will establish an Anti-Corruption Compliance System to prevent people from committing fraud. For example, the Kyocera Group will take the following measures.

  • Establishing anti-corruption regulations for each Kyocera Group company and guidelines for officers and employees to refer to in specific situations, according to each country and region.
  • Implementing anti-corruption training to ensure that officers and employees are fully familiarized with the contents of the anti-corruption regulations and guidelines.
  • Ensuring that business partners are familiar with the contents of this Basic Policy on Anti-Corruption and reconsidering transactions with business partners that violate anti-corruption laws and regulations, including the suspension of transactions with such business partners.
  • Establishing a hotline for Kyocera Group employees to consult or report any instances of corruption.

Bribery Risk Assessment and Control Procedures

  • The Kyocera Group conducts risk assessments based on anti-corruption laws and regulations in countries all over the world. The Kyocera Group will conduct periodic reviews of the Anti-Corruption Compliance System, and make improvements as necessary.
  • In order to prevent bribery through third parties such as distributors, agents etc., and to reduce the bribery risk relating to business mergers and acquisitions, the Kyocera Group will conduct preliminary evaluation of such third parties and candidates for acquisitions, mergers, joint ventures, etc. in accordance with bribery risks prior to the commencement of transactions.
  • When engaging a third party, such as a distributor, an agent, etc. the Kyocera Group will require such third party to comply with this Basic Policy on Anti-Corruption and the anti-corruption regulations in order to build a healthy business relationship.

Appropriate Accounting and Monitoring

  • To ensure transparent management, the Kyocera Group will perform accurate accounting based on the Kyocera Management and Accounting Principles, and will keep proper accounting books and records pursuant to the rules of each Kyocera Group company.
  • The Kyocera Group will monitor the implementation of this Basic Policy on Anti-Corruption through self-reviews, internal audits, etc. and will take corrective measures promptly should there be any problems found.

Disciplinary Measures

Each Kyocera Group company will fairly and strictly discipline its officers and employees who violate this Basic Policy on Anti-Corruption and any applicable anti-corruption laws and regulations, according to the internal rules of each Kyocera Group company.

April 1, 2020
Kyocera Corporation
Goro Yamaguchi, Chairman
Hideo Tanimoto, President

Example Approach

Security Trade Control System

The Kyocera Group complies with various national laws, such as the "Foreign Exchange and Foreign Trade Act" (FEFTA) related to international security trade management, and has established a security trade management system to prevent the outflow of parts for weapons of mass destruction, conventional weapons, and products and technologies that could be used for their manufacturing and development.

Measures to Ensure Security in International Distribution

Kyocera has received approval as a "Specified Exporter" and "Special Importer" from Japanese customs under the "AEO system," an international standard for ensuring and facilitating international logistics security, where mutual recognition mechanisms are established in various countries. This approval recognizes Kyocera as a business entity with a system for managing cargo security and legal compliance (compliance). This ensures the security of products delivered to overseas customers and facilitates smooth transactions.

Image:Authorized exporter certificate
Authorized exporter certificate
Images:Authorized importer certificate
Authorized importer certificate

Appropriate Information Disclosure

The Kyocera Group complies with regulations relating to the disclosure of information. The Kyocera Group endeavors to provide appropriate information without falsehoods or expressions that invite misunderstanding, in accordance with social and moral principles. Additionally, The Kyocera Group established a mechanism by which the Quality, Legal & Intellectual Property and Corporate Communications Divisions monitor product labels, manuals, catalogues, sales promotion documents, and advertising to ensure compliance with the Antimonopoly Act, Copyright Act, Act on the Protection of Personal Information, etc. in accordance with our Public Document Verification Guidelines.

Ensuring Transparency in Political Donations

The Kyocera Group may provide political donations as required from perspectives such as the realization of policy-oriented politics and contributing to the sound growth of parliamentary democracy. When we make political donations, we will comply with relevant laws and regulations including the Political Funds Control Act.

Measures for Prevention of Insider Trading

The Kyocera Group has established a management system to prevent insider trading and is working to ensure thorough awareness among its employees. We have set up an internal information management system based on the "Insider Trading Prevention Regulations," and have established a stock trading prohibition period that restricts trading during certain periods before financial results announcements. Furthermore, in an effort to ensure thorough awareness of insider trading issues among employees, we continuously engage in activities such as distributing the "Insider Trading Prevention Guide" and regularly conducting education on insider trading prevention for all employees.

Images:Insider Trading Prevention Handbook
Insider Trading Prevention Handbook

Measures for Exclusion of Antisocial Groups

The Company's "Basic Policy for Internal Control" states our basic stance that "A resolute stance shall be maintained against anti-social forces and all unreasonable demands shall be refused."
In addition, the "Kyocera Activity Policy", which is a result of application of the Kyocera Philosophy to various aspects of the corporate activities, and on which the employees of Kyocera Group relay for day-to-day operation, thoroughly requires the employees to "be sure to solve the problem in a resolute attitude based on laws and regulations" against anti-social force.

Installation of a Whistleblower Reporting System

Installation of Employee Consultation Hot-Line Center (Internal Reporting System)

Kyocera Group employees can consult the Employee Consultation Hot-Line Center on a diverse range of issues. Employees can seek advice and consultation, as well as report actions that are or may be in violation of laws and internal regulations relating to human rights, labor, safety and health, environment, fair business practices, etc. Measures for protection of individual privacy are clarified, and employees can consult the Hot-Line Center directly by telephone, e-mail or other means. Details of the consultation are investigated and ascertained in cooperation with the relevant divisions. This is followed by corrective action and preventive measures against recurrence. At Kyocera, consultations were undertaken on 229 matters in FY2024, and steps toward resolution were taken in each case.

Installation of a Compliance Hotline

In April 2024, the Kyocera Group established a compliance hotline to improve corporate governance, and facilitate the early detection and prevention of any issues regarding laws, regulations and compliance. Through this compliance hotline, not only employees, but anyone, including customers and business partners, can report any action by an executive officer or employee of a Kyocera Group company that violates laws and regulations, the Kyocera Group CSR Guidelines, the Kyocera Group Human Rights Policy, or the Kyocera Corporation Labor-related Code of Conduct.

Installation of the Kyocera Audit & Supervisory Board Reporting System

Kyocera Corporation implemented the Kyocera Audit & Supervisory Board reporting system as an initiative for internal control to prevent corporate scandals. Unfair sales and business transactions, acts that violate accounting laws and regulations, and in-house rules, acts that violate the anti-bribery regulations and Antimonopoly Act as well as inappropriate acts regarding quality assurance in manufacturing are subject to reporting.