The Suntory Group strives to create an organization and a corporate culture that place the highest priority on compliance to fulfill our responsibilities and meet the expectations of our customers and society.
We are building a compliance promotion system to realize our corporate philosophy from a cross-Group view based on this.
Policies and Our Approach
Suntory Group Code of Business Ethics: The fundamental principles shared by all employees for the realization of the corporate philosophy
The Suntory Group Corporate Ethics Code was established in 2003 and indicates the fundamental priniples that all employees must share. We are building a compliance promotion system to realize our corporate philosophy from a cross-Group view based on this Code of Business Ethics. We also revised the content by referring to the ISO26000 international standard for social responsibility in 2012 and adapted the content in 2017 for all Group employees around the world to better understand it.
Promoting Structure
Promotion System Rooted in the Frontlines
To promote compliance from a cross-Group perspective, the Compliance Department was established under the Group Governance Division to specifically promote compliance.
The Compliance Department formulates and implements specific measures in line with Group Governance Division policies, monitors the status of implementation at each workplace, and provides suggestions and advice on issues. It also established a Compliance Hotline (internal reporting system) and is responding fairly, impartially, and in good faith. We have revised some of the rules for the internal reporting system to operate more effectively under this system following revisions to the Whistleblower Protection Act.
In addition, specific personnel responsible for promoting compliance are assigned at each Group company, both within Japan and abroad. They take an active role in promoting compliance, formulating policy customized for the circumstances in their own company, and informing colleagues about that policy.
Compliance Promotiing Structure
Enhancing the Hotline for Early Discovery and Resolution of Problems
The basic rule in Suntory is that when an employee discovers actions that breach the Suntory Group’s Code of Business Ethics, he or she must first report it to the supervisors and seek their advice.
However, we have also established a Compliance Hotline both internally (our Compliance Office) and externally (3rd party law firm) as contact point for all of the Group companies in Japan in order to quickly discover and resolve compliance issues when reporting or consulting with a supervisor is not appropriate. A multilingual support system is in place so that foreign employees who are not good at Japanese can use it. Additionally, in order to avoid accessibility issues due to technical or financial reasons, we have made this mechanism accessible to all employees through different methods (digital and analog), including web, smartphones, telephone, and mail.
The internal awareness of this mechanism is measured every year through initiatives such as the "Employee Awareness Survey" as a way to engage users and assess the current mechanism, and the current awareness rate is over 90%. We also strive to keep improving the awareness rate and accessibility of this mechanism by sharing these results (including comparisons with previous year) with our top management.
Compliance Hotline awareness poster
In 2023, a total of 164 reports were received through these contact points in Japan. Roughly 60% of the reports received in Japan were about labor, personnel and management issues, including human rights related issues.
If there is a suspicion of non-compliance based on the content of the report, we take into consideration the privacy protection of all persons involved in accordance with the Suntory Group Internal Reporting System Regulations. In that case, respecting the situation of the reporter, the compliance officer promptly conducts a confidential investigation within the company, and promptly requests that the situation be rectified while escalating to the relevant executive in charge, and then follows up on the measures taken, so as to realize improvements and prevent reoccurrence of the problem. After a certain period of time has passed after the response, we close the case once we receive a report on the state of change from senior management as a follow-up.
Protecting the Reporters
The Suntory Group has established a Compliance Hotline. Internal Reporting System Regulations prohibits any type of negative impact on reporters such as retaliation or the spreading of rumors. In order to achieve this, when the Compliance Office conducts an investigation it identifies the persons concerned and then confirms the "internal reporting system regulations“, protecting thus the rights of the reporter. In addition, during the interviews with the reporter on the closing of each case, we also check that reporters have not suffered any disadvantages during the process. Furthermore, we are working to create a culture in which compliance reports are protected not only by the persons concerned, but also by the entire workplace by proactively disseminating the "internal reporting system regulations" within the company on a daily basis.
Compliance Hotline Response Flow
Our Initiatives
Activities to Ensure Compliance
Disseminating the Code of Business Ethics, and Implementing Compliance Awareness Raising Activities
So that the Code of Business Ethics would be understood and put into practice on a daily basis by all Suntory Group executives and employees, both the Japanese-language and English-language versions of the Code of Business Ethics have been posted on our internal intranet.
Within Japan, every year we provide opportunities for employees to re-familiarize themselves with the content of the Code of Business Ethics by means of workplace discussion sessions and e-learning regarding compliance related incidents that have occurred outside the Group, topics that are recognized as issues in the Group or in individual companies, etc. We also strive to remind employees about the fundamentals of compliance, and to promote ethical behavior.
We disseminate related information at Compliance Net in our intranet on a regular basis, including content that will help employees to understand the essence of compliance, such as content on topics linked to activities being undertaken at the time, as well as content that helps employees understand the essence of compliance through case studies from around the world. The compliance promotion managers in each company play a central role in spreading awareness to all employees.
Each Group company in Japan undertakes related activities in which the compliance promotion managers play a key role. The Compliance Department provides suggestions and tools tailored to the challenges of each company, implements group training and offers other measures of support for Group companies in Japan. We are also providing training for directors and managers who have been newly appointed at Group companies in Japan to help them develop a more in-depth understanding of the leading role that they need to play in compliance management.
Insider Trading Prevention Systems: Implementation and Communication
The Risk Management Department of Suntory Holdings Ltd. and Suntory Beverage & Food Ltd. and the management headquarters of Suntory Beverage & Food Ltd. are working to comprehensively prevent insider trading by introducing e-learning based on the content provided by the Tokyo Stock Exchange, as Suntory Beverage & Food Ltd. is listed on the Tokyo Stock Exchange.
Implementing the Suntory Group Code of Business Ethics in Business Activities
We have clarified our emphasis on compliance in the Code of Business Ethics. Each department has set and is operating policies and voluntary standards for challenges related to various compliance in their business activities based on the concepts of the Code of Business Ethics.
Ensuring Fair Business Practices
The Suntory Group conducts business fairly, holding integrity as a prerequisite, and abides by all laws and regulations, including the Antimonopoly Act. Since the formulation of the Guideline for Compliance of the Antimonopoly Act in 1992, we have revised and implemented the guideline in accordance with revisions of laws and changes in the environment. We are working to ensure thorough awareness of and compliance with the Anti-Monopoly Act and related laws and regulations by posting on our intranet the Key Points to Consider for the Promotion Campaigns under the Act against Unjustifiable Premiums and Misleading Representations and our Compliance Manual for the Act against Delay in Payment of Subcontract Proceeds and by holding regular briefings for each division and group company.
To ensure fairness in our day-to-day activities with suppliers and customers, our specialized departments are actively involved from the planning stages of product development, sales, and marketing, and verify the response policies and activities of related departments from the perspective of legal compliance.
Establishing Committees to Promote Fair Business for Alcoholic Beverages
A Fair Trade Promotion Committee was established to promote fair business practices at Suntory Liquors Ltd., the Suntory Group company responsible for the sale of alcoholic beverages. This was done in keeping with the Fair Practice Guidelines for the Liquor Business* and to maintain compliance with laws and regulations specific to alcoholic beverages as well as internal proprietary standards.
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*The Fair Practice Guidelines for the Liquor Business are administrative guidelines established by the National Tax Agency in 2006. These guidelines prevent worsening of management of liquor business operators and the reduction of liquor taxes due to dumping caused by excessive competition. We set fair partnership conditions and make rebates more transparent to stabilize management of liquor business operators. This is also coordinated by Fair Business Committee responsible for overseeing the Antimonopoly Act.
Transparency of Business Activities and Prevention of Bribery
The Suntory Group’s Code of Conduct prohibits the provision of excessive business entertainment and gift-giving to any counterpart regardless of whether it is a corporate entity, individual, political or governmental entity, or any other related organizations or companies, and establishes that relationships with all parties should comply with laws and be fair and transparent.
We also regularly provide training opportunities such as e-learning for employees who may be involved in corruption.
For more information on the Anti-Bribery, see Risk Management.
Global Compliance Initiatives
We are working to build a global compliance promotion system and integrate global standards in line with the global expansion of the Suntory Group.
As part of our global risk management system, we have established the Suntory Group Global Hotline, a unified global contact window for whistleblowing which covers Group companies throughout the world.
The Hotline is able to receive reports in multiple different languages, including English, Chinese and Spanish, and can handle reports and requests for consultation from people in many different countries. In 2023, there were 68 reports submitted to the Suntory Group Global Hotline. There were no reports relating to child labor or forced labor.
Educational tool to promote understanding of the Code of Business Ethics (cartoon)
The Compliance Department uses a shared global education platform to implement e-learning aimed at ensuring employee awareness of the Code of Business Ethics and of personal data protection issues, etc., and it provides support for compliance promotion activities at overseas Group companies. The Compliance Department has also produced short manga-style cartoons as an educational tool to strengthen awareness of the Code of Business Ethics in an easy-to-understand way, and these are being effectively utilized by individual overseas Group companies as teaching materials for employees who do not have access to the environment needed for e-learning.
Employee Awareness Survey to Understand the Awareness Towards Compliance and the Organizational Culture
To understand the status of compliance and the organizational culture as well as to determine if there are any individual issues, we conduct awareness surveys for all Group employees in Japan. We investigate initiatives to promote awareness of compliance through the entire Group by understanding the challenges in each company and each department from these results. We share the discovered challenges with directors and managers at each company, and expect that related departments in these companies will take voluntary actions to resolve these challenges.
Overseas Group companies contribute to compliance management by conducting their own independent surveys.