Asahi Glass | Compliance

Compliance
CSR Promotion in Cooperation with Business Partners

Concept:

The AGC Group is committed to increasing the fairness and transparency of its business operations, regarding strict compliance as the basis for Our Shared Value, Integrity, and as a premise for its sustainability as a corporate citizen.

Targets for fiscal 2008

To add regional supplements to the AGC Group Code of Conduct and implement the code across the Group
To continue the operation of the Help Lines
To continue the operation of the compliance certificate program for the Code of Conduct
To further strengthen education and audits on compliance with antitrust law
To implement the information security guidelines in Asia
To expand the range of Group companies targeted for self-check on information security in Japan/Asia and launch the same initiative in Europe
To conduct purchasing activities in line with the AGC Group Charter of Corporate Behavior

Results in fiscal 2008

		Self-evaluation
1.	The AGC Group Code of Conduct (11 kinds of regional supplementary rules to be applied to each country and region) was established.	A
2.	The Help Lines received 301 contacts in total for the entire Group.	A
3.	The number of employees who were covered by the program reached about 31,000 (64%).	A
4.	The number of employees who received online education (e-learning) reached about 7,000, that of those who received face-to-face education reached about 1,000, and eight sites were internally audited.	A
5.	The guidelines were translated into six languages and distributed to AGC Group companies in Asia.	A
6.	The number of employees covered increased by about 600 in Japan and by about 800 in Asia (compared with fiscal 2007), and about 6,400 employees were newly covered in Europe.	A
7.	The AGC Group Purchasing Policy was established, and the terms and conditions of the Group's basic purchasing agreement were revised from the viewpoint of CSR.	A

Criteria for self-evaluation
A:Satisfactory level, in which the intended target has been achieved
B:Almost satisfactory level, in which a part of the intended target has not yet been achieved
C:Unsatisfactory level, in which the intended target has not been achieved

Targets for fiscal 2009

To promote compliance with the AGC Group Code of Conduct across the Group (to take necessary measures, including providing training and publishing the pocket editions of the Code)
To increase employees awareness of these Help Lines and to promote an appropriate use of these lines
To expand the scope of the compliance certificate program
To further strengthen education and audits on compliance with antitrust laws and expand their reach
To expand the range of Group companies targeted for self-check on information security and launch the same initiative in the United States
To raise the awareness of the AGC Group Purchasing Policy across the Group and apply the revised terms and conditions of the basic purchasing agreement to more suppliers

Global Compliance System

In order to make all employees of the AGC Group aware of the importance of compliance, we have implemented compliance programs under the global compliance system as shown below. Furthermore, we periodically collect compliance-related information, incorporate the data in our compliance measures, and use them in our compliance monitoring activities. The collected information will be reported to the Board of Directors, shared by the In-House Companies/SBUs through the CSR Committee, and incorporated in their departmental rules.
Any serious noncompliance will be promptly reported to management through the compliance reporting system to take immediate countermeasures.

Global Compliance System

A system to plan, formulate, implement, and monitor compliance programs in the AGC Group

*1 Strategic Business Units (SBUs)

Topic
Global Compliance Meeting

Global compliance meeting

In order to foster compliance across the Group, the AGC Group has been holding a global compliance meeting semiannually (middle and end of the year) since 2005. In the first meeting, the members of the secretariats of the Japan/Asia, European, and North American Compliance Committees gather to report and discuss Group-wide measures and the progress of local measures. In the second meeting which the Global Compliance Leader also attends, the Leader reviews the implemented measures and approves plans for the following fiscal year.

Global Legal Management System

In 2006, we established a system to report disputes and litigations on a monthly and as-required basis. This system is designed for the prompt identification and management of disputes and lawsuits throughout the Group. Through this global legal management system, dispute- and litigation-related information is collected at the Group General Counsel level; the Counsel then reports the information to top management. Utilizing this system, and in cooperation with the Regional General Counsels and related departments, we are working to reduce the Group's legal risks.
In addition, we are implementing both organizational and personnel measures in response to the Group's global legal needs, including the assignment of an employee dedicated to legal issues in Shanghai, and holding legal meetings attended by members from the United States, Belgium, the Czech Republic, Russia, etc., where relevant policies are shared and confirmed. Reports on disputes and litigations and the progress of the global legal management system are submitted regularly to the Board of Directors.

Global Legal Management System

A system to promptly identify and report disputes and litigations occurring across the AGC Group on a global basis, and to reduce legal risks

*1 Strategic Business Units (SBUs)

Code of Conduct

Each of the AGC Group companies used to have its own Code of Conduct based on Asahi Glass's Code of Conduct, but in order to permeate the value of Integrity and emphasize its importance across the Group, we have newly established the AGC Group Code of Conduct for the entire Group.
The AGC Group Code of Conduct is composed of the global common part, which stipulates the specific rules with which all Group companies and employees should comply, and a part describing the regional rules that apply to individual countries and regions. The regional part also includes explanations about the differences in laws, regulations, and commercial customs of the various countries and regions, as well as supplements to the global common part. (The Code of Conduct, including each regional part, has been in place since June 2008.)
We are holding briefing sessions and providing necessary training to make all employees of the Group aware of the AGC Group Code of Conduct and their obligations to comply with it.

Items for the global common part

Compliance with laws and corporate policies and doing business with integrity
Fair trade; compliance with antitrust law
Occupational health, safety and security
Environment protection
Respect for human rights
Product safety and quality specification
Fair financial reporting
Prohibition of insider trading
Proper handling of company property and respect for others
Prohibition of conflict of interest
Proper handling of entertainment and gifts
Relationship with politicians and public officials
International trade control

Discussing global measures through regular meetings with top management

AGC Group Code of Conduct(global common part ) (6820KB)

Compliance education provided in fiscal 2008 (AGC Group)

Number of employees receiving online training (e-learning): approx. 12,700
Number of employees receiving offline communication: approx. 2,800*2

*2 Number of employees receiving the offline communication provided by the Compliance Committee of Asahi Glass targeting domestic Group companies (Excluding education designed for all employees conducted by each Group Company)

Compliance Certificate

The AGC Group has introduced a program whereby employees submit a certificate of compliance with the Code of Conduct on a regular basis. This program is designed to encourage employees to renew their recognition of the importance of compliance and review their operations and workplaces from the viewpoint of compliance. In the future, we aim to collect compliance certificates from all the Group employees.
In fiscal 2008, approximately 31,000 employees, or 64% of all Group employees were covered by the program, whereas 25,000 employees, or 46%, were covered in fiscal 2007. At Asahi Glass, all employees, including part-timers, submitted the certificates.

Compliance Help Lines

The AGC Group's Help Lines, which we have implemented to ensure compliance with local laws and regulations in Asia including Japan, Europe, and North America, serve as contact points allowing employees to report and make inquiries regarding compliance-related issues. In the management of these Help Lines, we are committed to protecting the anonymity of those contacting the Lines, and strictly prohibit acts of retaliation against users in good faith. Furthermore, we promote communication with employees who have made contacts under their own names.
In fiscal 2008, the Help Lines received a total of 301 contacts from employees of the entire AGC Group and 53 from employees of Asahi Glass and domestic Group companies. Also in the same year, we increased the number of regional Help Lines and now have Lines for Japan, South Korea, and Taiwan, in addition to those for Europe, North America, and China.

Help Line Reporting Route (Asahi Glass)

* When the whistle blower isn't anonymous, They are given feedback of the result and process.

Compliance with Antitrust Laws

In February 2005, the European Commission conducted on-site inspections of Asahi Glass's subsidiaries on suspicion of their past anticompetitive behavior in the European glass market. As a result, the Commission imposed fines in November 2007 and in November 2008 for anticompetitive behavior concerning the flat glass sector and the automotive glass sector in Europe, respectively. We sincerely and fully cooperated with the Commission's investigations. Asahi Glass acutely recognizes its social responsibility to supervise the actions of its subsidiaries from a Group management point of view.
The AGC Group has long been committed to preventing violations of antitrust laws through education, Group policies, and monitoring. We take the incident in Europe with the utmost seriousness, and pledge to further implement various measures, including providing reinforced compliance education on antitrust laws to each region and organization, monitoring participation by Group companies in trade organizations, and conducting antitrust law-related audits on pricing histories, in order to prevent the occurrence of similar incidents.

Measures implemented in fiscal 2008 to prevent noncompliance with antitrust laws (AGC Group)

Number of employees receiving online education (e-learning): approx. 7,000*3
Number of employees receiving face-to-face education: approx. 1,000*4
Number of audited sites: eight

*3 Mainly managers and employees in charge of sales
*4 Mainly employees in charge of sales

Information Security

Asahi Glass manages confidential information based on its Information Security Policy and Standard (formulated in 2001) and its information security guidelines (published in 2007). Also, we are steadily implementing a Plan, Do, Check, and Act (PDCA) cycle for information security through education, involving such activities as e-learning, self-checks, and internal audits. We have implemented the Policy and Standard, the guidelines, and other such measures at domestic Group companies and also at some overseas Group companies, thereby improving our information security.
In fiscal 2008, we implemented the information security guidelines at Group companies in Asia and expanded the range of companies targeted for self-check to include Group companies in Europe.
In fiscal 2009, we will continue to implement measures to raise our information management level in consideration of the situations of each of our bases and the regional circumstances.

Information security measures implemented in fiscal 2008 (AGC Group)

Distribution of the information security guidelines

Copies in Japanese, English, simplified Chinese, traditional Chinese, Korean, Thai, Indonesian, and Tagalog were distributed to Group companies in Asia including Japan.

Self-check on information security

Asahi Glass: approx. 3,400 employees
Other Group companies in Japan: approx. 3,600 employees (up 600 from fiscal 2007)
Group companies in Asia: approx. 2,600 employees (up 800 from fiscal 2007)
Group companies in Europe: approx. 6,400

Stakeholder Dialogue

We exchanged opinions with our stakeholders on the challenges and targets to be met to enable the Group to share the concept of compliance and promote an appropriate corporate culture on a global scale.

Third Stakeholder Dialogue: Compliance

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