Governance
Compliance
Policies and Our Approach
Suntory Beverage & Food (“the Company”) is committed to meeting the expectations of customers and society and to fulfilling its responsibilities. Accordingly, we are developing an organization and culture that prioritizes compliance, including adhering to laws and regulations, respecting norms and culture, ensuring fair competition, and conducting corporate activities with integrity and fairness and without corruption or conflicts of interest.
The Suntory Group Code of Business Ethics: values shared by all employees for the realization of the corporate philosophy
The Suntory Group Code of Business Ethics defines the basic mindset that everyone working at the Suntory Group must cherish in order to fulfill our corporate philosophy in practice, fulfill our responsibilities to society, and earn societal trust. To ensure all employees across the Suntory Beverage & Food Group act based on common standards for fulfilling our corporate philosophy, the Company has established a compliance implementation system with a Group-wide perspective based on this code. We also revised the code to refer to the ISO26000 international standard for social responsibility in 2012 and adopted the revised code in 2017 for all Group employees around the world to better understand it.
Implementation Structure
At the Company, the Corporate Management Division oversees the overall promotion of compliance in general, including monitoring adherence to the Suntory Group Code of Business Ethics. We report on adherence to the code to the Board of Directors every year, including information based on employee surveys on corporate culture and workplace environment for employees in Japan. The Board of Directors also reviews the effectiveness of the implementation structure and makes revisions when necessary.
In addition to formulating and implementing specific measures, monitoring the status of compliance at each workplace, and providing suggestions and advice on issues, we have also established a Compliance Hotline (whistleblower hotline) to ensure fair, impartial, and sincere responses to reports.
As for the whistleblower system, we have revised the Suntory Beverage & Food Group Internal Reporting System Regulations in line with Japan’s revised Whistleblower Protection Act, effective on June 1, 2022, and are operating the system more effectively. Each Group company in Japan and overseas also appoints a person in charge of promoting compliance and is proactively initiating activities such as formulating and disseminating their own action guidelines in response to issues they face.
Compliance Implementation Structure
Our Initiatives
Communicating the Code of Business Ethics Throughout the Group
To ensure that all executives and employees of the Suntory Group understand the Suntory Group Code of Business Ethics and apply it in their daily activities, we distribute a pamphlet that outlines the Suntory Group Code of Business Ethics and summarizes the Suntory Group Philosophy. The pamphlet is translated into 11 languages.
At the start of each year, employees of Group companies in Japan refreshes their understanding of the Code, and then signs a compliance statement provided at the end of the pamphlet. Meanwhile, we also have workplace discussions on a variety of topics, including compliance-related incidents that occur in the society and issues recognized by the Group and individual companies as challenges, to remind employees of the basics of compliance and to promote ethical behavior.
We conduct employee awareness surveys of all Suntory Group employees in Japan to monitor their compliance with the Code of Business Ethics in their business practices and workplace environment. The results of the survey are reported to management for early detection of potential compliance violations. We also use the results for employee education, formulation of activity plans, etc., while periodically evaluating the effectiveness of the Code of Business Ethics.
Activities to Raise Compliance Awareness Through Communication
To promote the understanding and practice of compliance, we regularly provide information to each Group company in Japan via "Compliance Net" on the company intranet.
The "Compliance Net" features information on subjects related to activities being undertaken, as well as contents that help employees understand the basics of compliance through case studies from around the world. In addition, the "Compliance Net" also includes self-learning materials such as information to supplement basic knowledge about compliance and self-check sheets on harassment so that employees can learn at any time.
Supporting Promotion Activities at Group Companies
Each Group company of Suntory Beverage & Food is engaged in promotion activities led by their promotion managers. The Corporate Management Division supports the promotion activities of each company by proposing measures and providing group training programs tailored to the challenges faced by each company. In addition, we provide training for managers newly assigned to Group companies in Japan to help them better understand their role as the driving force behind compliance management.
We also hold regular meetings with compliance officers of Group companies of Suntory Beverage & Food to provide them with a variety of information and advice, and to share knowledge and expertise.
Conducting Employee Awareness Surveys to Assess and Monitor Compliance and Corporate Climate Commitments
In order to understand compliance status and corporate climate performance as well as to identify individual issues, we conduct an "awareness survey" of all employees of Group companies in Japan. Based on survey results, we identify individual issues at each company and department, and consider initiatives for fostering compliance awareness. The survey results are shared among the management and managers of each company and are utilized by each company and department to resolve issues on their own initiative.
Overseas Group companies also conduct their own surveys, which are used to implement compliance management systems.
Implementing the Suntory Group’s Code of Business Ethics in Business Activities
The Code of Business Ethics clearly states our commitment to compliance. Based on the concept of the Code of Business Ethics, each department establishes and implements policies and voluntary standards regarding compliance issues in their business activities.
Also, we have created the Suntory Group Common Action Guidelines, which provide specific guidelines for actions and decisions to be made in relation to our transactions with business partners and incidents that may occur on a day-to-day basis. These guidelines are posted on the intranet so that all officers and employees of the Suntory Group companies in Japan can review them at any time.
Ensuring Fair Business Practices
The Company regards compliance with the Antimonopoly Act and other laws and regulations as well as the conduct of fair business activities as foundational to its operations. We have established Guidelines for Compliance with the Antimonopoly Act, and they guide our operations. We update them in line with revisions to law and changes in the business environment. We are working to heighten awareness and compliance with the Antimonopoly Act and other related regulations by placing on our intranet the "Essential Things to Know Regarding the Act Against Unjustifiable Premiums and Misleading Representations" and the "Manual on Compliance with the Act Against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors" and by holding regular briefings for each division and Group company.
Furthermore, in order to ensure fairness in our daily transactions with our business partners and customers, our specialized departments are actively involved in all stages from product development, sales, to marketing planning, and review the policies and activities of related departments from the perspective of legal compliance.
Preventing Corruption
In accordance with the Suntory Group Code of Corporate Ethics, we prohibit excessive entertainment and gift-giving to any corporation, individual, or organization, including political, administrative, or related groups or companies. We do not tolerate any form of corruption or misconduct, and we maintain sound and transparent relationships in compliance with laws and regulations.
In 2015, we announced our anti-bribery declaration, which aligns with global standards, in response to stricter regulations against bribery around the world, such as The Foreign Corrupt Practices Act (FCPA), etc. In 2016, we established a global anti-bribery policy, which includes guidelines that prohibit donations and political contributions in addition to entertainment activities and gifts. We are actively working to inform and train employees on the policy and conduct regular monitoring. Moreover, we have put in place a global Compliance Hotline to create and utilize a system for receiving reports and carrying out consultations and encourage employees to immediately contact the compliance hotline if they discover or suspect any corrupt activity.
We report on these activities to prevent corruption in general to the Board of Directors.
Risk Assessment to Prevent Corruption
Suntory Beverage & Food is working to establish a mechanism for risk assessment and due diligence, by informing its employees about effective due diligence and relationships with business partners. We place particular focus on areas and transactions that are identified as being at high risk of corruption and other concerns for preventing corruption in general.
Due Diligence for New Suppliers
When starting new business relationships, the Company requests that potential suppliers join Sedex, the world's largest ethical information sharing platform for suppliers, and to share information, including SAQ* answers.
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*Self-Assessment Questionnaire
Insider Trading Prevention Systems: Implementation and Communication
Suntory Beverage & Food is listed on the Tokyo Stock Exchange. Therefore, we have systems in place to prevent insider trading, including establishing prescribed procedures regarding employees’ trading of the Company’s shares. The Company also works to thoroughly prevent insider trading through efforts such as e-learning for employees.
Internal Reporting Systems
Enhancing Internal Reporting Systems
As a member of the Suntory Group, Suntory Beverage & Food follows the basic rule that, when employees encounter behavior that violates the Suntory Group Code of Business Ethics, including bribery and other forms of corruption, they must first report it to their supervisor and seek advice. However, we have also established the following systems to quickly discover and resolve compliance issues even when such reporting and consultation may not be suitable.
In Japan, we have established a Compliance Hotline as a central contact point in the Corporate Management Division, as well as contact points in the Audit and Supervisory Committee and at a third-party law firm.
Globally, as part of our global risk management system, we have established the Global Hotline, a shared contact point for all employees, including those of Suntory Beverage & Food Group companies outside Japan. This hotline supports multiple languages such as English, Chinese, and Spanish so we can receive reports and consultations from people in various countries. To avoid issues with utilization due to technical or economic challenges, we have set up a reception system accessible to all employees via the web including on smartphones, landlines, postal mail, and other means.
We measure awareness of the hotline contact points annually through our employee awareness survey and other opportunities. Awareness remains above 90%, and we provide feedback including year-on-year comparisons to the Group’s management and organize opportunities to discuss the results. In this way, we make efforts to maintain and improve awareness of the contact points and their usability.
In 2023, Suntory Beverage & Food received 132 reports. Around 60% concerned labor, personnel, and management issues, including some regarding human rights. For reports with suspected compliance violations, we took action with full consideration to protecting the privacy of all related parties in accordance with Suntory Beverage & Food Group Internal Reporting System Regulations. We always respect the reporter's circumstances, have a compliance officer urgently conduct an internal confidential investigation, swiftly demand corrections while involving the management of related parties, and ensure appropriate action is taken. We also provide feedback on investigation results to the reporter and management, and use the outcomes to improve issues and prevent recurrences. Furthermore, we follow a process where management executives report on the situation after a certain time has passed following resolution and close out the case.
Compliance Hotline awareness poster
Protection of Whistleblowers
Along with establishing a Compliance Hotline to address corruption including bribery, the Company prohibits any disadvantageous treatment of whistleblowers, including retaliation or rumor spreading, in its office regulations. As a measure to prevent this, the Corporate Management Division first identifies involved parties and subjects and then proceeds with the investigation, strictly following the Suntory Beverage & Food Group Internal Reporting System Regulations to ensure the rights of reporters are not infringed upon.
In addition, when closing investigation cases, we check with whistleblowers to confirm they have not suffered any disadvantageous treatment.
Moreover, by actively communicating the regulations within the Company on a daily basis, we strive to foster a culture where not only the related parties but the entire workplace protects whistleblowers.
Compliance Hotline Response Flow
