JSR Group has formulated JSR Group Principles of Corporate Ethics to serve as a globally shared Code of Conduct, and we are now working to make these principles known to all. By preparing English, Simplified and Traditional Chinese, Korean, and Thai versions in addition to the Japanese version, we are ensuring that officers and employees at all Group companies can access and fully comprehend JSR Group Principles of Corporate Ethics in their native language or in a language in which they are proficient.

We provide an e-learning program on JSR Group Principles of Corporate Ethics for all employees of JSR Group companies. For domestic Group companies, themes for FY2024 include the prevention of abuse of power, prevention of quality fraud, prohibition of bribery, and prohibition of conflicts of interest, while for overseas Group companies, the Code of Conduct and internal reporting channels were made known again. The attendance rate for the Group overall was 90%. We also conduct corporate ethics training for each stratum, such as new recruits and newly promoted managers.

JSR Group works to grasp and improve corporate ethics-related issues by conducting annual surveys on corporate ethics awareness that target the officers and employees of JSR Group companies in Japan and overseas. The results are reported at the Corporate Ethics Committee and then to the Executive Committee. They are subsequently fed back to employees as a post on our company intranet and containing a message from the assigned officer summarizing the results and explaining issues and other matters extracted from the results. Overseas Group companies also strive to build awareness of corporate ethics and legal compliance among their employees, including their locally hired employees, using methods that are appropriate for the local culture.

JSR Group has introduced the JSR Group Hotline (internal reporting channels) as a mechanism for employees to report problems that occur within the organization that are difficult to resolve in the workplace, such as acts in violation of laws and regulations or internal rules, to an appropriate contact person within the company. We place the highest priority on the protection of reporters, rigorously ensure the confidentiality of their reports, and prohibit any disadvantageous treatment (retaliation) for reporting or cooperating in investigations.

Three types of hotlines have been established for employees: an internal hotline operated by the Corporate Ethics Committee of the Company and each Group company, an external hotline operated by an outside law firm or a professional organization, and a business partner hotline for companies and individuals who do business with the Group. A structure has been established where each contact point allows anonymous or name-based reporting, with users being able to choose according to the situation.

When a report is received, the content of the report is organized by the internal or external contact point and shared with the JSR Corporate Ethics Committee (or the Corporate Ethics Committee of each business site or Group company). If necessary, the Committee will conduct interviews with the consent of the reporter to ascertain the facts and obtain additional information, and will instruct the relevant department to investigate and take corrective action. Based on the results of the investigation, the relevant department will implement corrective actions and recurrence prevention measures, and the progress and results will be confirmed by the Corporate Ethics Committee. The final result will be communicated to the reporter through the contact point (internal or external) used at the time of reporting. The establishment and operation of the hotline will be advanced under the leadership of the Corporate Ethics Committee chairperson and executive director, in cooperation with the Corporate Ethics Committees of JSR’s head office, business sites, and Group companies.

To advance the use of this hotline, we have established a structure with the external hotline available in sixteen languages, including Japanese, English, Korean, Chinese, and Thai, making it easily accessible to overseas business sites. In addition, the access points and usage details are posted on our company intranet, and we provide regular updates and notices about the usage status of the hotline.

In Japan, we have also established the JSR Group Business Partner Hotline, which is available not only to our purchasing business partners but also to a wide range of companies and individuals doing business with JSR Group. The objective of this contact is to promptly detect and resolve violations of laws or corporate ethics, or suspicious activities in transactions. We are working to promote its use, including providing information about the contact point at the start of transactions. Operation is entrusted to the same external specialized agency that operates the external hotline for employees, and by strictly enforcing the confidentiality of reports and prohibiting any treatment that could disadvantage the reporter, this achieves highly reliable operation.

JSR Corporation has established a management accountability structure based upon the Guidelines on the Management and Audit of Public Research Funds at Research Institutions established by the Ministry of Education, Culture, Sports, Science and Technology and the Ministry of Health, Labour and Welfare, as well as the Guidelines for Responding to Misuse of Public Research Funds and the Guidelines for Responding to Misconduct in Research established by the Ministry of Economy, Trade and Industry. JSR has also put into place a whistleblowing desk regarding the management and audit of public research funds. Specifically, under a structure where the Chief Management Officer serves as the Executive Officer in charge of Compliance, the General Management Officer serves as General Manager of the Compliance Department, and the Compliance Promotion Officer and Research Ethics Education Officer serve as head of the organization implementing research and development using public research funds, we properly manage and administer public research funds, prevent misconduct by researchers, and engage in fair research activities.

JSR Group has formulated a Policy for Bribery Prevention, Rules on Complying with Anti-Corruption Laws, and Standards for Gift-Giving and Entertaining that specify necessary items for all officers and employees to comply with the Unfair Competition Prevention Act in Japan, the US Foreign Corrupt Practices Act, the UK Bribery Act, and other anti-corruption laws when performing their tasks. In addition, JSR has also formulated Rules on Antimonopoly Law (Japan), Rules on Complying with US Antitrust Laws, Rules on Complying with the EU’s Antitrust Laws, and Rules on Complying with Korean Fair Trade Laws that specify items necessary for complying with each country’s antimonopoly (antitrust) laws.

With regard to due diligence of third parties, such as an important proxy, in preventing bribery, JSR has specified Due Diligence Guidelines for Proxies, etc. In line with this, JSR strives to reduce the risk of bribery by conducting surveys through self-checks and external databases.

• JSR “Policy for Bribery Prevention” (PDF: 31.3KB)

In addition, JSR participates in the Corruption Prevention subcommittee of the Global Compact Network Japan (GCNJ), a local network for the UN’s Global Compact. In this subcommittee, various activities are carried out, such as lectures with invited experts, exchanges of information related to measures for preventing corruption among participating companies, etc. Through these activities, JSR explores, examines, and implements effective and ideal anti-corruption measures that are suitable for JSR Group.
Anti-corruption measures have a strong compliance structure advancement aspect of complying with relevant laws of each country. At the same time, the foundation of such measures is closely linked to global social issues related to human rights, labor, and the environment. In addition to continuing to implement effective anti-corruption measures, JSR searches for ideal forms of such measures.

Based on legal compliance regulations, JSR Group designates laws and regulations that are important in the execution of business as Overall Significant Laws and Legal Regulations. Each year, the Group regularly verifies its compliance by self-checking whether the business operations of all Group companies conform with the Overall Significant Laws and Legal Regulations, and if any issues are identified, improvements are made. The regular sharing of information on cases of non-compliance within JSR Group is useful in preventing legal violations and quickly detecting and improving situations of non-compliance.

1. ①Compliance Handbook

   JSR Group is thoroughly publicizing important points that demand legal compliance among employees in Japan, South Korea, China, and Taiwan by issuing versions of JSR’s Compliance Handbook localized for each country. These Compliance Handbooks are distributed not only to Group companies in each country but also to departments and Group companies that have business relationships with the countries concerned, such as those that sell products and provide samples to customers in those countries. This ensures thorough understanding and practice of legal compliance in each country.

1. ②Seminars and E-Learning

   We hold periodic seminars and provide e-learning programs for officers and employees of all JSR Group companies as part of legal education with the objective of ensuring full organizational knowledge of laws demanding compliance along with related company policies and rules. The main seminars held in FY2024 were as follows.

   • December 2024: e-learning on the Anti-Monopoly Act, Anti-Corruption Law, and Security Export Control
   • February 2025: Seminar on the Subcontract Act
   • March 2025: Seminar on Security Export Control

   In addition to the above, we provide legal education that has been customized to meet the requirements of individual departments and Group companies. This includes individualized education for employees being sent to new assignments (training on anti-trust laws, anti-corruption laws, etc.).