Compliance

Ushio has established “10 Action Guidelines” to define standards for behavior that require everyone at the Group to comply with laws, regulations, the Articles of Incorporation, and Management Philosophy. The Compliance Committee is responsible for ensuring that employees observe these guidelines. The Business Auditing Department and Compliance Committee jointly perform audits to monitor the status of compliance and submit audit reports as necessary to the Board of Directors and Audit & Supervisory Committee. Furthermore, information involving the performance of directors’ duties is recorded, stored, and managed, in documentary and electronic formats.
 
This enables the directors and Audit & Supervisory Committee members to view the information at any time and take timely and appropriate action as required. To reinforce awareness of the importance of compliance, all Group companies use Ushio’s standards for behavior and other guidelines and the Business Auditing Department performs audits of the Group companies.

Compliance with Laws and Regulations Related to the Security of Exports

Ushio Group has adopted a basic policy of not engaging in any export or export-related transactions that impair the maintenance of peace and security worldwide, and is implementing various measures for security export control.
We have established an internal rules and guidance (CP: Compliance Program) for compliance with export-related laws and regulations in order to secure our system for promoting security trade control. Based on the CP, our export controls are conducted to determine cargos and/or technologies are whether appearing on the List controlled items or not. At the same time, the entire content of transactions is reviewed by confirming end users and application, and decisions on whether or not to export a cargo or technology are to be made.
 
In addition, we are building a self-management system through measures such as responding to legal revisions, employee education, and internal audits.
As a result of establishment of these export control systems, we have obtained a Bulk Export License from METI that can be granted only to exporters with strict control.

Ushio Helpline

The Ushio Helpline has been in operation in the Ushio Group since October 2006. When any Group employee in Japan is subject to or knows about improper behavior, such as workplace violations of laws and regulations, internal rules, ethics or other standards for behavior, he or she can use this helpline for direct communication with individuals outside the Group to consult or report on this improper behavior. The helpline allows for quick discovery and correction of improper behavior together with measures to prevent recurrence. It provides access to consultations while protecting individuals who use the helpline from any negative consequences.

All whistle-blowing statements received via an external channel are immediately reported to the chair of the Compliance Committee, who is a managing director appointed by the president. Under the direction of the chair of the Compliance Committee, Ushio aims to quickly resolve issues by conducting audits, responding to incidents, and putting in place measures to prevent a reoccurrence. To prevent this system from losing effectiveness, Ushio takes action to raise awareness of compliance through internal newsletters, training sessions and a compliance awareness month.

Information Security

Ushio handles private information of frequent customers and is entrusted with their important Company information and other information assets in the course of its business activities. We consider it a top priority to safeguard such information from threats such as leaks and modification. Moreover, because we recognize that information is an asset that generates value and is a source for increasing corporate value, we are taking measures such as raising awareness of information security among our employees and improving our risk management systems.

This kind of management requires three interlocking initiatives: rules must be determined, a framework must be created for observing those rules, and awareness must be raised. We implement these based on our information security management rules and make sure they are applied uniformly and consistently for the Ushio Group throughout the world. In particular, Ushio believes that it is important to appropriately review the security rules in order to adapt them to changes in the business environment, and we will also promote the development of security policies for Group companies in the future. In particular, we believe it is important to review security rules as appropriate to adapt to changes in business environment.
As some of our specific initiative, we are advancing activities to establish an Ushio group policy in order to strengthen information security management and risk management. In 2022, we are planning to establish a group policy for entire Ushio group.
 
On the other hand, domestic subsidiaries and headquarters use AI to analyze PC operation logs to ensure early detection and deterrence of internal information leaks.
In addition, we have introduced SOC (Security Operation Center) as a measure against targeted e-mail attacks to monitor and analyze external threats. We protect information assets from leaks and loss by detecting and defending external attacks at an early stage.
 
However, system-based countermeasures are insufficient, and continuously raising employee awareness of information security is an important issue. Accordingly, we conduct in-house education through e-learning every year. We are also working to enhance information literacy by conducting training for targeted e-mail attacks.
These are positioned as activities to protect the profits of customers and stakeholders, and we will promote these activities globally so that each and every employee has a high level of information security awareness.

Risk Management

Through its relevant departments, the Company has identified, evaluated, and specified respective risk categories related to business execution and management, including compliance, the environment, product quality, finances, legal matters, natural and other disasters, information management, and export controls.

To deal with natural disaster risk and infection risk, we conducted a Company-wide project to formulate business continuity plans (BCPs). In addressing environment risks, we conduct periodic environment risk inspections and impact assessments to manage them. In IT information management, we have established an organization for persons responsible for management to prevent leakages of secret or personal information. With regard to export control risk, a dedicated department manages the risk by formulating rules and conducting specialized training, among other steps. For financial market risk relating to financial instruments such as marketable securities, we manage the risk by establishing rules. In the global supply chain, including international models, we manage the risks relating to corruption, human rights abuses, and environmental pollution as one aspect of CSR procurement.

With regard to the above risks, the Company has established the Compliance Committee, chaired by a director, and a framework for reporting to the Corporate Strategy Meeting.

Protecting Intellectual Property Rights

Ushio takes the following measures to protect its own intellectual property rights and ensure that it respects the rights of other companies.

1. We will observe laws and regulations pertaining to industrial property rights, copyrights and other intellectual property rights.
2. We will make efforts to manage risk in order to prevent other companies from infringing upon our intellectual property rights and to ensure that we do not infringe upon the rights of other parties.
3. We will strive to submit applications and obtain rights in a timely manner in line with business development, and thus to contribute to vigorous corporate activities.
4. We will consider the overseas countries and regions in which we submit applications as well as the content of overseas applications in an effort to enhance our overseas competitive strengths
5. We will ensure that all employees understand management rules pertaining to employee inventions, and will observe these rules.

Initiatives to Prevent Corruption

Ushio's 10 Action Guidelines  as a Member of Society for business activities commit us to conducting fair and equitable business transactions, and we have always taken vigorous action to prevent corruption. In these Guidelines, Chapters 6 and 7 are designed to prevent corruption. They have the provisions shown below.

6. We shall comply with laws and regulations and carry out fair business activities in accordance with socially accepted practices.
"When offering any gift or entertainment, we will comply with laws and regulations and always limit it to the nature, frequency and value appropriate in light of social norms. When receiving an offer of any customary or courtesy gift, such as seasonal gifts, in relation to business, we will politely refuse it. Also, in response to an offer of any meal or entertainment, we will refuse it as a general rule .
We will deal with governmental offices in compliance with applicable laws and regulations and in fair and open manners. We as a business entity may request the revision or abolition of industrial and economic systems or policies from politicians and government. However, we will always do so in fair and open manners. When offering political donations, we will comply with applicable laws and regulations and expect no specific reward or favors to be provided."

7. We shall fulfill our duties to the best of our abilities in conformity with internal regulations and standards.
"We will always draw a clear line between corporate and private matters and gain no personal interest in association with business positions or duties."

In 2010, Ushio became a signatory of the United Nations Global Compact's Ten Principles, which include provisions for preventing corruption, and we support the prevention of corruption and bribery in business activities.

 

Specific Activities

In our operations, we are concerned about the risk of bribery to promote sales of laboratory instruments, light source products and medical equipment to universities and government agencies. In sales of medical equipment in particular, we stress the importance of maintaining proper relationships with our customers, namely medical practitioners. Ushio regularly trains its sales staff on transparency guidelines with the aim of preventing corruption.

Newly appointed procurement managers rigorously further greater understanding of the Company's procurement practices and work to prevent inappropriate relationships with suppliers. In operations related to the sale of our wide range of products and the procurement of materials, there are concerns that efforts to prevent corruption and bribery will become increasingly complex as the Company's scope of operations expands overseas, owing to the possibility that overseas laws and regulations pertaining to the prevention of corruption (especially FCPA in the US and UKBA in the UK) will apply to other regions.

We provide individualized anti-corruption trainings related to each employees’ duty operations. In addition, we provide managers with trainings specific to the above concerns in light of the global trend toward stricter enforcement of anti-corruption laws, and all employees are required to read through “the 10 Action Guidelines as a Member of Society” during our Compliance Month. Through these efforts, we are working to ensure that all employees throughout the company are fully aware of the importance of anti-corruption.

The Ushio Hotline is the direct line of communication for employees to file reports, including reports related to the abovementioned items of concern, which may be reported anonymously. There has been no reported case of bribery or other illegal activity, nor has there been an instance of disciplinary action or dismissal.

In the event of illegal actions being confirmed, an investigation conducted by the responsible executive officer acting as Chair of the Compliance Committee reporting directly to the president, or other appropriate action is carried out and reported to the Board of Directors as necessary.

Ushio does not have fines or penalties specifically for corrupt practices, but in the event of a serious situation being detected, it will implement appropriate disciplinary action in accordance with Ushio internal regulations.