Corporate Compliance

To promote corporate compliance activities, the Daicel Group established the Corporate Compliance Management Regulations and the Corporate Compliance Management System based on a check-act-plan-do (CAPD) cycle^* to drive continuous improvement and development of activities.

The Daicel Group believes that corporate compliance should not be limited to the activities of certain individuals or organizations but should be practiced by all Group employees.

Daicel has established a Corporate Compliance Program Office under the responsibility of Senior Managing Executive Officers to promote its corporate compliance activities across the entire Group.

The Corporate Compliance Program Office  complys and  submits a report on the status of corporate compliance and outstanding issues to the Corporate Compliance Program Division at the end of the fiscal year. The division compiles these reports and presents the status of compliance and issues of the Group as a whole at the Top Management Review on corporate compliance, which is attended by the top management, Standing Audit & Supervisory Board Members, and the Workers’ Union representative, to discuss related issues and objectives for the next fiscal year.

The result of the discussion is reported to the Board of Directors, and the Corporate Compliance Program Office rolls out the priority objectives to each organization. Each Organization formulates and implements activity plans in accordance with the priority objectives, reviews its activities and identifies issues every year, and reports them to the Corporate Compliance Program Office.

The head of each organization appoints a corporate compliance activity facilitator to spearhead corporate compliance activities.

The Corporate Compliance Office, with the aim of promoting corporate compliance activities, engages in direct and timely dialogue with the heads of department and corporate compliance activity facilitators of each organization, providing various information on compliance and exchanging opinions.

Relevant divisions provide support for each organization’s compliance activities by participating as necessary, based on the information gathered through discussions about their activities. In addition,  the Corporate Compliance Program Office also checks the status of compliance violations through timely dialogue with all divisions and Group companies.

In the event that the Corporate Compliance Program Division identifies any issues that may significantly impact corporate management, it will confirm the facts and promptly report to the corporate compliance officer and the Standing Audit & Supervisory Board members to discuss how to respond.

In addition, the Corporate Compliance Program Division reports every month to senior management and regularly (about four times a year) to the Board of Directors on a summary of the reports received and consultations undertaken through the Compliance Help Line, which was set up to identify and adjust for management risks at an early stage, and through the whistleblower system established at each Group company, as well as the status of responses and results.

Daicel has established the Legal Compliance System, through which supervisory divisions in charge of ensuring compliance with different laws manage information on the latest legal developments. The Legal Compliance Division is made up of different departments, centering around the corporate departments such as the Legal Group. They provide relevant departments with legal information on any amendment of laws and guidelines as well as educational materials to ensure thorough legal compliance. This information is also provided to domestic Group companies. When new laws and regulations are established, the Legal Group temporarily takes on the role of a legal compliance division to confirm their details and other important matters before designating the appropriate legal compliance division.

To address specific compliance issues, such as export management and the protection of personal information, Daicel has established individual committees in accordance with each set of relevant rules and regulations. These committees maintain and promote compliance.

In the Ethical Standards of Daicel Group, it states “We practice fair business and competition. We understand the laws, regulations and rules of each country. We do not participate in unfair or anti-competitive business practices, including collusion, cartels, and bid rigging.” In April 2024, we created the"Daicel Group Basic Policies on Anti-Corruption and Compliance with Competition Law." [PDF: 149KB]All Daicel Group employees are required to act in line with the word and spirit of this policy and live up to the code in their day-to-day operations. In FY2026/3, there were no reports of anti-competitive behavior, violations of laws or regulations governing corruption, bribery and conflicts of interest, other illegal activities, fines, or monetary penalties.

In its business activities, the Daicel Group has established the Daicel Group Basic Policies on Anti-Corruption and Compliance with Competition Law. To maintain free and fair competition, the Group also abides by the Antimonopoly Act (the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade), the Proper Transactions Act (the Act on Ensuring Proper Transactions Involving Specified Entrusted Business Operators) as well as laws, regulations, and guidelines on anticompetitive behavior stipulated by each country.

With the aim of maintaining fair and free competition, Daicel has formulated our own manuals such as the "Compliance Manual for the Antimonopoly Act," the "Guidelines for Information Exchange Among Competitors -Prohibited (“Don’t”) and Recommended (“Do”) Practices to Prevent Violations of Competition Laws-," the "DOs & DON'Ts Practical Guide on U.S. Antimonopoly Law," and the "Practical Guide on EU Antimonopoly Law." We concurrently work to raise employee awareness through rank-based group training and e-learning. For employees who are to be transferred outside of Japan, we educate them on local laws and regulations as well as other important issues.

In addition, starting in FY2025/3, we have been regularly holding study sessions for the Daicel Group, led by a consultant with experience as Secretary-General of the Japan Fair Trade Commission. Through these sessions, we continue to promote awareness of legal compliance within the Group. Also, we provide education that caters to the needs of each company by organizing e-learning for the prevention of anticompetitive behavior for officers and employees at domestic Group companies, as mentioned above, while also providing English language educational materials for overseas Group companies to accelerate initiatives across the entire Daicel Group.

The Daicel Group has signed the United Nations Global Compact and is determined to prevent all forms of corruption, including bribery. Regardless of where we operate, domestically or overseas, we strictly forbid engagement in any actions that may be perceived as bribery, and we maintain highly transparent relationships with politicians, governments (public servants), business partners, and all other stakeholders.

As stipulated in the Ethical Standards of Daicel Group and the Daicel Group Basic Policies on Anti-Corruption and Compliance with Competition Law, established in April 2024, we prohibit the giving and accepting of gifts and entertainment to or from business partners, except when it is deemed to be within the scope of sound business practices and social norms, and it must be approved by the relevant division head. In addition, in order to ensure the effectiveness of the policy, we established the “Regulations for the Management of Entertainment and Gifts” in April 2025. We have also emphasized the importance of each division taking responsibility for establishing appropriate management systems for entertainment and gifts, tailored to their specific circumstances.

Daicel educates its employees on preventing corruption through rank-based group training and e-learning. For employees who are to be transferred outside of Japan, we provide training on the Prevention of Bribery of Foreign Public Officials under the Unfair Competition Prevention Act and precautions regarding local laws and regulations, including the extraterritorial reach of the US Foreign Corrupt Practices Act.

Furthermore, the whistleblower system also covers corruption and violations of the competition laws, and suspicious cases are investigated and properly addressed under the system, including reports from outside the Company.

In addition, no serious risks concerning corruption or bribery were found at any organization in FY2026/3 to the extent that it can be grasped through internal audits by internal audit departments, audits by auditing firms, and whistleblowing.

In the Ethical Standards of Daicel Group, we made the following statement, “We commit to the safeguarding of our company’s and third parties’ confidential information, including personal data, by maintaining an effective information security system. Accordingly, we practice proper and appropriate information management.”

Our Group respects the intellectual property rights held by third parties based on the Ethical Standards of Daicel Group and “1-(viii) Protection of Intellectual Property." We recognize that the intellectual property rights (patents, utility models, trademarks, design rights, etc.) that belong to companies are important assets and work to maintain and preserve such assets.

Regardless of where we conduct business, the Daicel Group strives not only to comply with applicable laws and regulations, social norms, and internal regulations but also to act with social decency to earn the trust of society. When dealing with tax matters, we will thoroughly investigate tax risks associated with international business transactions, including transfer pricing, to ensure that our tax payments are made in a legally compliant and appropriate manner.

Daicel conducted corporate compliance activities across the entire Group, as well as promoting each organization's own initiatives proactively in accordance with our corporate compliance management system.
In particular, one of the key elements we value is the Priority Objectives for the Daicel Group’s Corporate Compliance Activities, which are established every fiscal year.

Since our Group is engaged in a wide range of businesses and operations, we have formulated the “Priority Objectives for the Daicel Group’s Corporate Compliance Activities” as universal principles that all departments can work toward together.

In addition to the “Bad News Fast & First” and “Let’s create a workplace where all members can Visualize, Voice, Listen and Respond” initiatives, which have been continued with the aim of realizing our corporate culture objectives since FY2024/3, we have established two new priority objectives. The reason is that considering the trends of compliance violations that have occurred within our Group, we believe that action is needed from the aspect of not only organizational culture but also knowledge and internal controls.

Through year-round activities, we believe that the compliance awareness and knowledge of our Group employees have been gradually improving. However, we also realize that compliance standards required by society are becoming stricter year by year. Therefore, we believe that continuous initiatives based on this priority objective are essential as a basic principle for addressing compliance issues. Accordingly, for FY2027/3, we have set the same priority objective as last year, with the aim of further embedding compliance awareness among all Group employees.

The Daicel Group considers the thorough understanding of corporate compliance by each and every employee to be a key management priority issue, and every summer we conduct a Group-wide campaign called "Compliance Awareness Month" to encourage reflection on corporate compliance.

At the start of Compliance Awareness Month each year, we begin by issuing the "Top Message from the Officer in Charge of the Corporate Compliance Program Office." The two key points of the top message for FY2026/3 were as follows:

In response, the heads of each division convey their views on compliance to their members through talks, written messages, and other channels.

The Daicel Group conducts  an e-learning program on compliance for all employees of our Group, including contract employees and temporary staff. In FY2026/3, 100% of our Group companies participated, with 12,713 participants (a participation rate of 99.4% among targeted 12,793 people). The sections on “respect for human rights” and “quality compliance” in the e-learning curriculum were prepared in collaboration with the relevant corporate divisions.

We created case studies based on actual compliance incidents that occurred within the Daicel Group and held small group discussions in each organization. During these sessions, participants examined each case in relation to the “Daicel Group Code of Conduct” and the “Ethical Standards of Daicel Group,” discussing the causes of the incidents, countermeasures, recurrence prevention measures, and whether they had similar experiences. Through these discussions, members recognized and shared a variety of perspectives and ideas, and also deepened their understanding of the importance of “Voicing” and “Listening and Responding.”

The case studies were also translated into the languages used at our overseas Group companies, and discussions were held on the same content.

Throughout Compliance Awareness Month, we hold an annual "Corporate Compliance Training for Executive Officers" to provide our executives with an opportunity to reconsider corporate compliance. In previous years, we have invited leading experts in various compliance fields as lecturers. However, in FY2026/3, for the first time, the Corporate Compliance Program Office itself served as the instructor, using actual cases from within the Group to present issues and facilitate discussions. This practical approach gave our executives a direct opportunity to learn about the realities and challenges faced within the Group.

Daicel provides corporate compliance training tailored to each position and role for new graduate recruits, recently promoted employees, newly appointed executive officers of Group companies, employees assigned to overseas posts, and others. The Corporate Compliance Program Office also organizes seminars on compliance-related topics in response to requests from various departments.

As part of Group-wide compliance education, we distribute compliance-related study materials—such as news articles, group discussion topics, comics, and quizzes—on the Group’s intranet every month. We also independently create and regularly distribute a newsletter called “Compliance News,” which features familiar case studies from within the Group.

In accordance with the Whistleblower Protection Act, the Daicel Group has set up several help lines through which employees can report and receive consultations about issues that include violations of the Ethical Standards of Daicel Group. Intended to help prevent and detect wrongdoing and misconduct at an early stage, these help lines are available for anonymous consultations and can also be used in languages other than Japanese.

In anticipation of situations where appropriate problem resolution cannot be achieved through the usual chain of command via managers in each workplace, we have established the Compliance Help Line as a channel through which all officers and employees of the Daicel Group can report and consult with our division in charge of corporate compliance as a contact point. We have established not only an internal help line, but also an external help line managed and operated by external organizations within Daicel and Group companies in Japan.

Within our Group companies, in addition to a system where officers and employees can directly report to and consult with us, we have established an independent whistleblowing help line within each company and use both in tandem to gather opinions from a wider range of officers and employees. 

As such, our Group maintains a structure where officers and employees can readily report and seek advice.

We have established and publicly disclosed rules to protect those reporting or requesting consultation through the Compliance Help Line, including (1) protecting personal information and privacy, (2) prohibiting unfavorable treatment (prohibition of retaliation) for having made a report or sought a consultation, and (3) providing information on survey results.^​​

We have also established an online compliance help line system that can be used by external parties, including customers, business partners, contractors, former employees, and local residents. We regularly review and improve this environment to ensure that a wider range of stakeholders can use it, and we strive to incorporate diverse opinions into our company management.

The Corporate Compliance Program Office verifies the facts and investigates reports received through the Compliance Help Line. When problems are identified, the Office takes appropriate actions to resolve and rectify the issues and establishes measures to prevent their recurrence. If it is more appropriate for another department to handle the case, the Office refers the matter to the relevant department, following up to ensure proper handling. In principle, reports and consultation requests submitted to Group companies are handled by each Group company itself, but these reports and consultation requests submitted to Group companies are also shared with the Corporate Compliance Program Office, which provides support to the Group companies as necessary. All received reports and requests for consultation are also directly forwarded to the Officer in charge of the Corporate Compliance Program Office and Standing Audit & Supervisory Board Members.

Furthermore, the Corporate Compliance Program Division makes regular reports (about four times a year) at Board of Directors meetings that include the number of reports and requests for consultation received through all help lines, as well as an overview of each case and the status or results of their handling.

Along with regularly informing all organizations of these reporting and consultation services, the Group raises broad awareness of these services through rank-based training and e-learning courses offered during Daicel Group Compliance Awareness Month.

To ensure that employees and officers can use the help line without hesitation, we established and have been operating a “Help line Response Team” since April 1, 2024. This team consists of representatives from various corporate departments who collaborate to investigate and respond to reported cases. In addition, several female representatives participate in this "Help line Response Team" to provide a more multifaceted perspective and to reduce the reluctance of employees to report issues specific to women.

In FY2026/3, there were no reports or requests for consultation that materially impacted the Company’s management.

We conduct training for using help line to promote its use. This practical training, designed independently by our Group, is grounded in the idea that making actual use of the help line will do more than anything to eliminate resistance to it.

Although our Group was early to establish a whistleblower system and has made the structure and safety of our system known to employees, in-house survey results have revealed that many employees remain resistant to using it. We introduced the training to address this issue.

Participants in the training undergo a simulated experience identical to actual use of the help line through the following actions:

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The case documents are prepared on the basis of key compliance cases that actually occurred within our Group with the goal of making these incidents known and personally familiar to employees.

We began the training on a trial basis in FY2022/3 and introduced it full-scale in FY2024/3. During three  years from FY2024/3, 6,251 employees (99.6% of our target) underwent the training. Many employees tackled the training earnestly regardless of department or position, and we received many comments calling the training a “masterpiece" with a strong sense of reality. The number of help line reporting cases has recently increased significantly, growing about three-fold compared to FY2022/3. We believe that the expansion of our help line training into the Group supported this achievement.