Compliance Promotion Structure and Initiatives
This page describes our compliance promotion structure and compliance promotion initiatives.
Compliance promotion structure
Shionogi promotes compliance in all departments and units, including domestic and overseas subsidiaries, through measures centered on those of the Compliance Committee, which is chaired by the president and for which the General Administration & Subsidiaries Management Department functions as the bureau of the committee.
In order to further enhance the assurance of compliance of which Shionogi's broad definition does not mean only compliance with laws and regulations but also requires ethical behavior, the Company established the Shionogi Group Compliance Policy in April 2012. The Company engages in the following types of activities every year aimed at promoting outstanding compliance consciousness and compliance performance among all employees.
- 1As the designated Compliance Manager, the manager of each department or unit cooperates with an assistant—designated the Compliance Promoter—in undertaking activities, including the preparation of compliance risk management action plans, the promotion of enlightenment activities for compliance consciousness based on these action plans, the preparation of reports regarding the implementation of such activities and improvement measures in order to ensure thorough compliance.
- 2Besides drafting compliance measure proposals, the Bureau of the Compliance Committee provides support for promotion activities of the entire Shionogi Group through such measures as those to implement and facilitate compliance education programs for executives and all Shionogi Group employees, prepare and distribute Shionogi's Compliance Handbook, disseminate messages and reminders regarding compliance, conduct employee attitude surveys, and feed back survey results internally.
- 3Shionogi has established an internal reporting system comprising an internal reporting desk in the General Administration & Subsidiaries Management Department, and an external reporting desk through outside legal counsel. The Company makes efforts to ensure this system is well-known and used, and works to promote the early discovery as well as the prevention and amelioration of compliance violations utilizing the system.
Compliance promotion initiatives
The Compliance Committee meets four times a year to report on and debate compliance-related matters, also preparing reports for the Corporate Executive Meeting and the twice-yearly Board of Directors meetings. Compliance managers work together with compliance promoters on the preparation of compliance risk management (CRM) action plans specific to each department or unit, following a Plan–Do–Check–Act model.
Through these activities, Shionogi aims to achieve company-wide observation of compliance principles.
In order to identify and address compliance issues, we also conduct regular compliance awareness surveys among directors and employees in the Group. These surveys provide insight into the understanding and penetration of compliance, which can then be reflected in the aforementioned CRM planning, for a solution that encompasses the entire corporate culture.
Shionogi moreover offers regular compliance training for compliance managers and promoters, where Compliance Committee chairman expounds on the importance of compliance while seeking to promote greater awareness and understanding. We also regularly provide rank-specific and role-specific training for division heads and executives as well as personal information management officers, in addition to offering periodic training for all employees on such subjects as information security, pharmaceutical safety, harassment, and bribery.