JSR Group has been endeavoring, by building up and maintaining good relationships with all our stakeholders, to become a trustworthy and indispensable corporate citizen.
We have been vigorously executing our Code of Conduct in order to fulfill "Our Responsibility to our Stakeholders," an essential part of our Management Policies, as well as to ensure compliance with relevant laws and regulations during the course of our business.
2. JSR Group Principles of Corporate Ethics
JSR Group is advancing corporate ethics activities together with all of its Group companies, both in Japan and overseas. To achieve this, we have formulated JSR Group Principles of Corporate Ethics as a concrete and globally-shared guideline that reflects our "Essential Elements*."
The principles represent a Code of Conduct that all directors and employees (full-time, contract, part-time, and temporary employees as well as employees on short-term contracts) of JSR companies should comply with to develop our corporate activities while fulfilling the management policies spelled out in "Our Responsibility to our Stakeholders.” The Group shall never require directors and employees of Group companies to violate this Code of Conduct. Additionally, JSR Group shall not disadvantage any director or employee who refuses to execute an order to violate the Code of Conduct because of that refusal.
* JSR Group’s "Essential Elements": The Essential Elements consist of the Corporate Mission, the Management Policies, and Course of Action: 4C action guidelines.
3. Advancement Structure
The Corporate Ethics Committee spearheads compliance activities (corporate ethics activities). The Committee is responsible for monitoring the Group’s legal compliance, follow-up, and advancement of respecting human rights.
4. Corporate Ethics Activities
JSR Group has been pursuing the following three major corporate ethics activities:
(1) Publication and Education of JSR Group Principles of Corporate Ethics
JSR Group 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 directors 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.
Moreover, each year we provide an e-learning program on JSR Group Principles of Corporate Ethics for all employees of JSR Group companies in Japan. We incorporate the themes of confidential information management, prevention of abuse of power, and prevention of data falsification into the program. We also conduct corporate ethics training for each stratum, such as new recruits and newly promoted managers. With regard to harassment education, we conduct management training on bullying and harassment reports and the handling of actual cases for high-ranking and managerial positions.
JSR Group Principles of Corporate Ethics (Japanese version: revised on Jan. 1, 2023, version in other languages: revised on Jan. 1, 2021)
(2) Corporate Ethics Awareness Survey
JSR Group works to grasp and improve corporate ethics-related issues by conducting annual surveys on corporate ethics awareness that target the directors and employees of JSR Group companies in Japan and overseas. The results are reported at the Corporate Ethics Committee and then to an Officers Committee. They are subsequently fed back to employees as a post containing a message from the assigned officer summarizing the results and explaining issues and other matters gleaned 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.
(3) Hotline (Internal Reporting Channels)
JSR Group has introduced a system of internal reporting channels called the Corporate Ethics Hotline. There are three categories of hotlines; namely, an internal hotline operated by the corporate ethics committees 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. Of these, the external hotline operated by outside professional organizations has staff who speak 16 languages, including Japanese, English, Korean, Chinese, and Thai, making them easily accessible to business offices overseas.
The Corporate Governance Code stipulates that a contact point independent of management should be established as part of developing a whistleblowing system. Accordingly, we have set up the external hotline such that any report that comes through is simultaneously reported to the office of the Corporate Ethics Committee and the standing Audit & Supervisory Board member.
For each report that comes in, the office of the Corporate Ethics Committee in the company concerned requests the relevant department to ascertain the facts. The office then discusses and decides on responses based on the department's findings, implements responses, and later follows up on the results. If the reporter desires feedback, the contact point that initially received the report contacts him/her with the results as well as the responses taken.
We post and display guides for accessing the hotlines on the company intranet and the top page of online internal newsletters to make these hotlines easier to use.
In addition, we also hold yearly meetings between the corporate ethics officers of domestic Group companies and JSR's Corporate Ethics Committee for the purpose of ensuring all Group companies in Japan are on the same page and tackling ethics-related issues.
Eleven reports were received during FY2022. Of them, six involved abuse of power. We addressed each report in an appropriate manner.
JSR Group Business Partner Hotline
In Japan, the revised Whistleblower Protection Act came into effect in June 2022. In light of this, we have expanded the supplier hotline for purchasing partners to make reports to the JSR Group Business Partner Hotline for whistleblowing use by a wider scope of business partners of the Group, not limited to purchasing partners.
The JSR Group Business Partner Hotline receives reports from business partners to quickly discover and resolve violations of the law as well as actual and possible violations of corporate ethics in business transactions. Hotline services are entrusted to the same outside organization employed for the employees' hotline. Efforts are being made toward improving reliability, by thoroughly enforcing strict secrecy of reports and prohibiting handling of reports that would be disadvantageous to those reporting.
In FY2022, there were zero reports made to the JSR Group Business Partner Hotline.
5. Legal Compliance Measures
Every JSR Group member defines legal compliance regulations that form the basis of its legal compliance. Each company then uses the regulations to solidify its compliance through regular review and improvement as well as legal training to increase awareness of laws and regulations and instill commitment to compliance. JSR Group establishes specific systems and executes other priority approaches to ensure compliance with laws and regulations that are particularly relevant to the execution of business.
1) Approach to Preventing Bribery and Unfair Competition
JSR Group has formulated “Policy for Bribery Prevention,” “Rules on Complying with Anti-Corruption Laws” and “Standards for Gift-Giving and Entertaining” that specify necessary items for all executives and employees to comply with the Unfair Competition Prevention Act in Japan, Foreign Corrupt Practices Act in the U.S., Bribery Act in the U.K. and other anti-corruption laws when performing their tasks.
In addition, JSR has also formulated “Rules on Antimonopoly Law” (Japan), “Rules on Complying with U.S. 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 Guideline for Proxies, etc.” In line with this, JSR strives to reduce the risk of bribery by conducting surveys through self-checks and external databases.
Participation in Global Incentives
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, exchange of information related to measures for preventing corruption among participating companies, etc. Through these activities, JSR explores, examines and implements effective and ideal corruption prevention measures that are suitable for JSR Group.
Corruption prevention measures have a strong compliance system 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 corruption prevention measures, JSR searches for ideal forms of such measures.
In October 2020, JSR Group endorsed the recommendations of the Task Force on Climate-related Financial Disclosures. For details of our response to these recommendations, please see below.
2) Approach to Taxes (Philosophy)
JSR Group understands that carrying out appropriate tax payments and tax management that follows relevant laws and regulations of each country fulfills an important role in the economic and social development of each country and is linked to supporting and earning the trust of all stakeholders.
JSR Group is engaged in taxes by supporting the following philosophy as provided by the Chief Financial Officer (CFO).
“JSR Group will comply with the taxation laws of each country in which it does business, including regarding transfer pricing and tax havens.”
(1) Reviewing and Improving Legal Compliance
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. The regular sharing of information on cases of non-compliance within JSR Group is useful in preventing legal violations and quickly detecting and improving non-compliant situations. It also helps improve awareness of compliance. In FY2022, no serious legal violations were found during the compliance confirmation process.
(2) Training and Increasing Awareness
The Group is thoroughly publicizing important points that demand legal compliance among employees in Japan, South Korea, and China by issuing Japanese, Korean, and Chinese versions of JSR's Compliance Handbook. The Chinese and Korean versions are issued to not only Group companies in China and Korea but also JSR departments and Group companies that sell products, supply samples, or otherwise engage in business dealings with Chinese and Korean enterprises. Through it, we are working to ensure thorough understanding and practice of legal compliance in China and Korea.
Following the revision of the Japanese version of Compliance Handbook in April 2022, we revised and redistributed the Compliance Handbook in Chinese and Korean in October 2022 based on revisions to related laws.
Seminars and E-Learning
We hold periodic seminars and provide e-learning programs for directors and employees of all JSR Group companies as part of legal education to ensure full organizational knowledge of laws demanding compliance along with related company policies and rules. The main seminars held in FY2022 were as follows.
- June 2022: Seminar on anti-corruption
- September 2022: e-learning on Anti-Monopoly Act, Anti-Corruption Law, And Security Trade Control
- December 2022: e-learning on insider trading prevention
- February 2023: Seminar on Anti-monopoly Act of Japan
- March 2023: Export Control seminar
We also provide e-learning on corporate ethics.
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, anticorruption laws, etc.).
6. Protection of Personal Information
Furthermore, for Group companies that handle personal data covered by the EU's General Data Protection Regulation (GDPR), we are providing support for the development and operation of a GDPR compliance system to be applied to the acquisition, processing, and transfer of covered personal data.
7. Initiatives for Bioethics
(1) Initiatives for Medical and Biological Research Involving Human Subjects
JSR Group conducts life science and medical research on human subjects mainly as it relates to the Life Sciences Business. This research fully complies with the laws and regulations of each country where it takes place.
JSR and Medical & Biological Laboratories Co., Ltd. (MBL) are both subject to the Ethical Guidelines for Medical and Biological Research Involving Human Subjects, co-developed by the Ministry of Education, Culture, Sports, Science and Technology, the Ministry of Health, Labour and Welfare, and the Ministry of Economy, Trade and Industry. Both companies have established internal rules required under these guidelines along with an Ethics Review Committee comprised of internal and external members in order to screen research from ethical and social perspectives. Applicable research is carried out following the research plan deliberated on and approved by this committee. Furthermore, we provide training on bioethics to employees involved in this research to ensure they follow proper research practices.
The member register, regulations, and summary of meeting minutes of each companies’ Ethics Review Committee is recorded in the Research Ethics Review Committee Reporting System (Japanese only) of the Ministry of Health, Labour and Welfare.
(2) Ethical Considerations for Animal Testing
Animal testing compliant with laws and regulations is necessary during the development process for chemicals, pharmaceuticals, and medical materials to confirm their safety and efficacy on humans. JSR Group conducts appropriate animal testing compliant with the laws and regulations of each country as part of the process to support the development of pharmaceuticals. Each JSR Group company has established internal rules compliant with these laws and regulations and set up an Animal Testing Committee. These committees administer animal testing appropriately based on rigorous screening from the perspectives of science, animal ethics and animal welfare, including the 3Rs of Replacement, Reduction and Refinement. Additionally, we conduct self-inspections and evaluations of our animal testing at least once a year to ensure compliance with all relevant laws, regulations and guidelines. Furthermore, JSR Group is working to develop technologies that enable alternatives to animal testing.
Moreover, Group company Crown Bioscience International has obtained certification for its sites in the United States and China from AAALAC International, a third-party assessment institution that promotes the humane treatment of animals in science.
(3) Handling of Genetically Modified Organisms
JSR Group uses genetically modified organisms, adult stem cells, and human-derived samples to engage in contract drug development and manufacturing operations and research on diagnostic agents. JSR Group handles these samples and related applied technologies following the laws and regulations of each country, while also giving consideration to ethical standards.
8. System on the Management and Audit of Public Research Funds and Initiatives to Address Misconduct in Research
JSR 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 for reports regarding the management and audit of public research funds. Under the following structure, we properly manage and administer public research funds, prevent misconduct by researchers, and engage in fair research activities.
|Chief Management Officer
|Chief Technology Officer
|General Management Officer
|General Manager, Research Planning Department II
|Compliance Promotion Officer
Research Ethics Education Officer
|Head of the organization implementing research and development using public research funds
Corporate Ethics Committee Office
22F, Shiodome Sumitomo Building
1-9-2 Higashi Shimbashi, Minato-ku, Tokyo 105-8640
In addition, Group company Medical & Biological Laboratories Co., Ltd. (MBL) has also established a system on the management and audit of public research funds, along with a consultation desk and a whistleblowing desk.