Compliance

Business Foundation

Our Basic Policy

ROHM Group has conducted our business observing the laws, business ethics and in-house rules in order to continue to gain the trust of various stakeholders as a company in compliance with the laws.

ROHM Group has the awareness and responsibility that "the company is a public institution of society" and establishes a system for compliance in accordance with "ROHM Group Basic Ethics Policy" and "ROHM Group Business Conduct Guidelines" to prevent the risk of legal and corporate ethics violations. We are committed to thorough management.

ROHM Group Basic Ethics Policy

"Respect for International Standards, and Compliance with Laws, Business Ethics, and in-house rules"

ROHM Group will conduct its business observing the laws, business ethics, and in-house rules in order to continue to gain the trust of various stakeholders as a company in compliance with the laws. The Group will also, in line with the globalization of business activities, respect international standards of conduct.

1. Conduct guidelines
ROHM Group shall act as specified below in accordance with the basic policy.
1.1 Fair action:
ROHM Group recognizes that a corporation is a public entity of society and responsible for acting honestly and fairly at all times based on social common sense and the awareness that each individual employee represents the Company.
1.2 Compliance with laws and regulations, and business ethics:
ROHM Group shall always conduct business activities in good faith and with a law-abiding spirit and solid understanding of ethics. The Group shall strive to constantly collect the related laws and regulations of each country and other information needed for business activities, and to gain a better understanding thereof. In addition, the Group shall establish in-house rules corresponding to the related laws and regulations, and strive to ensure the full awareness of and compliance with those in-house rules.
1.3 Compliance hotline and whistle-blower protection:
ROHM Group shall, by following the provisions of in-house rules, establish a contact point (e.g. compliance hotline) to which Group employees may report business activities that they suspect may be in violation of related laws and regulations or business ethics. Furthermore, in the event of any violation or suspected of any conflict-of-interest transactions, ROHM Group shall immediately implement corrective action to prevent the occurrence or recurrence of the foregoing act, and shall strictly deal with the violation. In addition, the Group shall not subject persons or groups who deny any violations and who report violations or suspected violations to disadvantageous treatment, on the grounds of such reporting.
1.4 Prevention of bribery and corruption:
ROHM Group shall, by following the provisions of in-house rules and agreeing with the spirit of corruption prevention required by international standards of conduct, commit no act for the purpose of or that may be suspected of not bribing governmental agencies or officers or employees thereof, or politicians of any country, in order to continue transparent and honest business activities. Any corruption, extortion and embezzlement are also strictly prohibited.
1.5 Prohibition of excessive business entertainment:
ROHM Group shall observe the provisions of in-house rules by not giving any gifts or providing any food, drink, or other economic benefits that are socially unacceptable. Furthermore, the Group shall be most cautious with any offers of entertainment and/or gifts from suppliers, and shall not accept any personal benefits, based on the clearly established policies and monitoring procedures of each country and region.
1.6 Disclosure of information:
ROHM Group shall disclose to stakeholders not only information in accordance with related laws and regulations, but also information on social connections of the Group, including company missions and policies, business activities, and social contribution activities in a positive, fair, appropriate, and timely manner.
1.7 Intellectual property rights:
ROHM Group shall strive to enhance its corporate value by upgrading technologies unique to each individual division and appropriately acquiring and using the rights to the Group's own intellectual properties. In addition, the Group shall respect and shall not use the intellectual property rights of third parties without permission, nor abuse the Group's own rights.
1.8 Implementation of fair business activities:
In expanding business on a global scale, ROHM Group shall observe the provisions of in-house rules and respect free market competition as a part of conducting fair business activities. The Group shall comply with related laws and regulations, social ethics, and contract provisions, and shall not pursue an increase in sales or income by means contrary thereto. The Group shall not conduct any transactions that violate related laws and regulations, social ethics, and/or contract provisions, including agreements that restrict competition with other companies in the same trade (i.e., cartelling), bid rigging, fictitious transactions, and selling price restrictions. Furthermore, the Group shall comply with import/export-related laws and regulations for the peace and safety of the international community.
1.9 Fair and appropriate expression:
ROHM Group shall use fair and appropriate expressions in public relations and advertising activities in compliance with related laws and regulations and based on the facts at all times. In addition, the Group shall observe public order and morality, and shall not use any unjust expressions that constitute false information, slander, social discrimination, or infringement of human rights.
1.10 Non-use of conflict minerals:
In the interesting of protecting human rights, ROHM Group shall not use in products any conflict minerals that have helped to finance armed groups that have conducted inhumane acts in conflict regions.
1.11 Confidential and personal information management:
ROHM Group shall strive to thoroughly manage the Group's confidential information obtained in the course of business activities, any third parties' confidential information acquired through business partnerships, information related to the privacy of concerned persons, and personal information, in accordance with the provisions of in-house rules.
1.12 Fair accounting and disclosure:
ROHM Group shall appropriately record and report information based on fair accounting practices and facts, and shall properly make tax payments in accordance with related laws and regulations. The Group shall takeinto account the interests of all stakeholders and respect the positions thereof, in order to build and enhance relations of mutual trust through the disclosure of information.
2. Management System:
ROHM Group shall build a management system to observe this Ethics Policy and work on the continual improvement of this Policy. The management system shall be designed to ensure compliance with applicable international standards of conduct and related laws and regulations, and the identification and mitigation of operational risks related to this Policy.
2.1 Responsibility:
ROHM Group shall operate the management system in accordance with the Labor Policy approved by top management as provided for in-house rules.
2.2 Identification of representative:
ROHM Group shall identify an internal representative responsible for ensuring implementation of the management system and related items, and the top management shall carry out periodic reviews of the status of the management system.
2.3 Statutory and customer requirements:
ROHM Group shall define the procedures for identifying, monitoring, and understanding international standards of conduct, related laws and regulations, and customer requirements.
2.4 Risk assessment and management:
ROHM Group shall define the procedures for identifying risks involved in the Group's business activities, determining the relative significance of each risk, managing the identified risks, and complying with related laws and regulations.
2.5 Improvement objectives:
ROHM Group shall define improvement objectives and implementation plans, and periodically assess and review the achievement of those objectives, in order to fulfill its social responsibilities.
2.6 Training:
ROHM Group shall provide training to employees to implement the improvement objectives in accordance with the Ethics Policy, and to meet requirements of international standards of conduct and related laws and regulations, as well as customer requirements.
2.7 Communication:
ROHM Group shall define the procedures for communicating this Ethics Policy, improvement objectives, and the assessment of the achievement thereof to employees, suppliers, and customers in an accurate and understandable way.
2.8 Feedback and participation of employees:
ROHM Group shall define the procedures for assessing employee comprehension of matters provided for in this Ethics Policy, obtaining employees feedback effectively, and making sustained improvements to this Policy based on those assessment results.
2.9 Audit and assessment:
ROHM Group shall conduct periodic self-assessments to ensure conformity to international standards of conduct, related laws and regulations, and customer requirements.
2.10 Corrective and preventive actions:
ROHM Group shall define procedures for correcting and preventing within an appropriate period of time the recurrence of defects/inadequacies detected in the course of internal or external audits.
2.11 Documentation and records:
ROHM Group shall create and retain records related to the management system in accordance with the provisions of in-house rules and related regulations.
2.12 Supplier responsibility:
ROHM Group shall define procedures for communicating requirements provided for in this Ethics Policy to suppliers and monitoring the compliance of the suppliers with this Policy.

ROHM Group Business Conduct Guidelines

ROHM Group translates its Business Conduct Guidelines, which clarify basic ethical rules that must be observed in daily business activities, into seven languages and promotes their use at all group companies. In addition, opportunities for employee education at the company, such as workshops and legal e-learning, along with awareness-raising activities are offered to increase and ensure compliance.

Promotion Structure

To promote compliance throughout all ROHM Group,we have established a Compliance Committee under the CSR Committee. The chairman of the committee is the directors, and the heads of related departments are members. The outside directors who are audit and supervisory committee members and the general manager of the internal audit department attend the committee as observers.
ROHM Group also appropriately (at least quarterly) confirms the status of new or revised laws and regulations. As a result, it becomes possible to appropriately respond to and develop new items that the Group complies with, which can help prevent the risk of legal violations.

In addition to complying with laws and regulations, ROHM Group has been committed to complying with corporate ethics in accordance with the RBA Code of Conduct (※). Each Group company operates a management system related to labor and ethics, and ROHM head office controls the entire Group. Under this system, we identify important issues related to corporate ethics, and promote and strengthen compliance through appropriate countermeasures, internal and external audits, and continuous improvement.

  • RBA(Responsible Business Alliance) Code of Conduct is a set of social, environmental and ethical industry standards. The standards set out in the Code of Conduct reference international norms and standards
    including the Universal Declaration of Human Rights, ILO International Labor Standards, OECD Guidelines for Multinational Enterprises, ISO and SA standards, and many more. While the Code of Conduct originated with the electronics industry in mind, it is applicable to and used by many industries beyond electronics.

Management and Audit of Public Research Funds

In ROHM, top management took the initiative in appropriately conducting and managing the Public Research funds under the system of responsibility.

The System of Responsibility for Public Research Funds in ROHM

Top Management Chief Management A Person in Charge of Compliance
A person in charge President Manager of the legal & intellectual property division Reader of research and development division using Public Research funds
Role Person who take the final responsibility for conducting and managing of Public Research funds Person who support a person is in charge of top management and have the responsibility and authority. for managing all of research institutes In research division, person who has a practical responsibility and authority for conducting and managing the Public Research funds

Point of Contact for Conducting and Managing the Public Research Funds from Inside and Outside the Company

【Contact by Mail】
21, Saiin Mizosaki-cho, Ukyo-ku, Kyoto 615-8585 Japan
To consultation desk for the Public research funds, Legal & intellectual property division , ROHM Co., Ltd.

Hotline for Misusing of Public Research Funds and Illegal Research Activity from Inside and Outside Company about

【Contact by Mail】
21, Saiin Mizosaki-cho, Ukyo-ku, Kyoto 615-8585 Japan
To consultation desk for the Public research funds, Legal & intellectual property division , ROHM Co., Ltd.

Education and Training

In order to comply with and thoroughly enforce business ethics, it is important to raise the level of compliance literacy of each employee. ROHM Group have conducted regular training sessions on themes related to compliance and internal education and enlightenment activities such as legal e-learning in order to spread and raise awareness of compliance.
Also we have been providing training for management (directors), department heads, leader classes, and new employees at each level according to their level of compliance. Our aim is for employees at each level to gain an understanding and knowledge of the rules to be followed.

●General Education and Training

Education or Training Theme and Objective Target Number of Participants Participation Rate (%)
E-learning on Compliance (Labor and Ethics) Acquisition of knowledge such as compliance (work ethics, trade secret management, competition law compliance, insider trading regulation, subcontracting law) ROHM Group 3243 99.1
Level-specific Education on Compliance Acquisition of compliance knowledge required at each level and understanding of rules to be observed ROHM's New Employee, Chief Grade, Section Chief, Manager 3,243 99.1
Role-based Education on Compliance Acquisition of compliance knowledge required for group leader positions ROHM's Chief Grade 82 -
E-learning on Trade Secrets Preventing risks such as leakage of secrets by deepening employees' understanding of trade secrets ROHM Group(Japan) 5,645 96.6
ROHM Group(oversea) 12,729 92.8

●Specific Education and Training
※Education required for specific departments

Education or Training Theme and Objective Target Number of Participants
Compliance Training Program Maintain and improve compliance awareness by continuously educate on compliance in general Each Department Manager, Each Sales Employee, Product and Market Strategy members 523
Compliance Training Program in 2018
Competition Law Compliance Training

In addition to the above education and training, ROHM creates and distributes to its employees the “LEGAL Guide Book,” which explains legal knowledge in an easy-to-understand manner in order to prevent unlawful violation of laws and regulations.
This guidebook focuses on laws related to business activities, such as insider trading, management of confidential information, and bribery, and you can always check the items related to your business. In addition, since it is also used when facing legal issues or when conducting compliance education within a department, it is an effective tool that can be connected to each individual's awareness of legal compliance and actions.

LEGAL GuideBook

Comprehensive Anti-Corruption
(Bribery Prevention) Measures

ROHM Group established Regulation on Prevention of Bribery and aims to eliminate corruption in all affiliated companies in Japan and overseas. In addition to conducting bribery prevention briefings in level-based training courses and e-learning for all employees at ROHM Headquarters.

Whistleblowing System

As a whistle-blowing system, ROHM has set up a compliance hotline with an external law office as the contact point, and accepts all employees, including non-regular employees, from whistle-blowing and consultation regarding compliance violations in domestic groups. In addition, overseas affiliates also have compliance hotlines.
In addition, in order to properly operate this system, ROHM Group strictly adheres to the confidentiality of the person who made the report and the information obtained in the investigation, and ensures that those who report/consult will not be disadvantaged due to the report. Has been set. In addition, by distributing “ROHM Compliance Card” and raising awareness of the reception desk through bulletin boards and in-house training, we are working to promptly grasp risk information such as violations and respond swiftly and appropriately.

  • In FY2019 (April 1, 2019-March 31, 2020), 17 reports were received.
ROHM Compliance Card

We distribute the following ROHM Compliance Card to ROHM employees, which describes the items of compliance that each ROHM employee must comply with. In addition, this card also contains information on the law firm, which is the contact point for reporting, so that all employees can consult and report on compliance at any time.

ROHM Compliance Card
  • We shall conduct fair business transactions.
  • We shall not trade with antisocial forces.
  • We shall keep corporate confidentiality and protect personal information.
  • We do not offer price cartels or bribes.
  • We shall respect intellectual property rights.
  • We shall not conduct insider trading.
  • We shall comply with other laws and regulations.

In addition to the internal hotline described above, we have also established a compliance hotline for our business partners.