Sumisho Metalex Corporation

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Company Profile

Management with Compliance

In order to further increase our corporate value and achieve sustainable growth in the future, it is absolutely imperative for us to comply not only with laws and regulations, but also internal rules in all aspects of our management of the company.
Compliance is clearly defined in the Activity Guideline of Sumitomo Corporation as "to comply with laws and regulations while maintaining good ethics," on which we place the utmost importance in our management.
We have set up a compliance committee to reinforce our compliance system and are promoting educational activities so that the compliance-based mindset will be deeply rooted and extensively disseminated among all of our officers and employees in their daily work. In the event anyone should infringe a rule, it is assured that it will be immediately reported to his/her supervisor or relevant departments.In addition to the reporting system through the organizational ladders, we have introduced a "direct feedback" system by which any trouble can be reported directly to the compliance committee, thereby enabling the company to quickly take the best course of action.

As a member of the Sumitomo Corporation Group, we place compliance at the center of our corporate management in performing our daily business activities.

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Guiding Principles

As a member of the Sumitomo Corporation Group, we follow the compliance policy as set forth in the "Sumitomo Corporation Compliance Manual."

  1. Business Activities
    1.Observing Antimonopoly Laws
    Employees shall not engage in private monopolization, unreasonable restraint of trade or unfair trade practices.
    2.Security Control
    Employees shall not provide to any foreign country any weapons, arms or related technology that might disturb the maintenance of international peace and security.
    3.Customs/Controlled Items
    Employees shall carry out customs clearance procedures properly with respect to all items exported or imported. Employees shall not export or import any controlled items.
    4.Compliance with Applicable Laws
    Employees shall become familiar with the applicable laws relevant to their individual business responsibilities in order to have an appropriate understanding of such laws, and shall refrain from engaging in any conduct that violates such laws.
    5.Respecting and Protecting Intellectual Property Rights
    Employees shall not engage in actions that may infringe the intellectual property rights of others and shall protect the intellectual property rights of the Company, which are among its valuable corporate assets.
    6.Prohibition of Unfair Competition
    The Management Principles of the Company place prime importance on integrity. Employees shall not engage in any practices constituting unfair competition, which may damage the reputation of the Company.
    7.Information Management
    The Company's confidential information, including without limitation customer information, trade secrets and know-how, is a valuable corporate asset of the Company. Employees shall treat the Company's confidential information with great care and keep it in strict confidence. Confidential information received by the Company from a third party shall be treated with the same degree of care.
    8.Preservation of the Environment
    Employees shall give due consideration to the preservation of the global environment.
    9.Overseas Business Activities
    When conducting business overseas, employees shall familiarize themselves with the local laws and regulations governing their activities and act in compliance with these laws and regulations.
  2. Corporate Citizen As a Member of Society
    10.Prohibition on Giving Bribes
    Employees shall not engage in any conduct which would constitute, or has the appearance of, the offering of any bribe. Employees are also prohibited from giving gifts or offering entertainment to government officials.
    11.Prevention of Unlawful Payments to Foreign Governmental Officials
    Employees shall not provide or offer to provide any unlawful benefit, including without limitation cash, to any foreign governmental official for the purpose of procuring business.
    12.Political Contributions
    Employees shall not make any political contributions that are not in compliance with applicable law.
    13.Confrontation with Antisocial Forces
    Employees shall not yield to any antisocial forces and shall take a strong stand to oppose any such influence.
  3. Maintenance of a Good Working Environment
    14.Respect for Human Rights
    Employees shall respect human rights and shall not engage in any unfair discrimination.
    15.Prohibition of Sexual Harassment
    Employees shall not engage in sexual harassment, including any sexually offensive actions or remarks that have a negative impact on the working environment.
    15-1.Prohibition on Abuse of Authority
    Employees shall exercise their authority in the workplace within the appropriate scope and shall not use their authority to engage in harassment of any other employee, including comments, actions or gestures that may damage another employee's dignity or character, create a harmful working environment for another employee or cause another employee to fear losing his or her employment.
  4. Personal Interests
    16.Insider Trading
    Employees shall not engage in any conduct that violates, or may appear to violate, the laws and regulations regarding insider trading.
    17.Conflict of Interest
    Employees shall not engage in any conduct which conflicts with the interests of the Company.
    18.Proper Use of Information System
    Employees shall not use the information system of the Company for any unauthorized purpose.

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