We have established the “Shiseido Code of Conduct and Ethics” to ensure that all Shiseido Group employees act with a strong sense of ethics in all business activities based on THE SHISEIDO PHILOSOPHY. We provide training to ensure the “Shiseido Code of Conduct and Ethics” is practiced and ensure that our diverse employees respect each other and that we are striving to earn the trust of all stakeholders, including our employees.
In line with the “Shiseido Code of Conduct and Ethics,” we have established a basic policy and regulations to be complied with by the Shiseido Group as a whole and are working to disseminate these internal rules and regulations, together with THE SHISEIDO PHILOSOPHY, to each Group company and business site. We are also preparing an environment in which each Group company and business site can establish detailed internal regulations.
In addition, to promptly detect any conduct that deviates from the “Shiseido Code of Conduct and Ethics” and various laws/internal regulations, we have established Hotlines/Helplines and are responding appropriately by closely examining the content of such conduct.
Through such activities to raise awareness of ethics and compliance and the systems that support them, we have created a workplace environment in which every employee can maximize his or her potential.
In OUR PRINCIPLES（TRUST8）, which serves as the working principles that every Shiseido employee must follow, we have included “ACT WITH INTEGRITY”, calling on Shiseido Group employees to “demonstrate humble confidence, integrity, and ethical behavior to earn trust from all stakeholders.” With this approach, we are striving to achieve both honest and ethical behavior along with business growth.
We have placed the Risk Management Department at the global headquarters which reports to CLO (Chief Legal Officer), and RMO (Risk Management Officer) at each regional headquarters.
Activities related to corporate ethics and compliance are being promoted across the Shiseido Group with the support of Risk Management Leaders assigned to each affiliate at the global level and Ethics & Compliance Leaders in Japan.
Furthermore, by having the CLO coordinate with the legal managers in each region, we are strengthening our compliance system with laws and regulations.
To oversee compliance and risk management for the Shiseido Group, the “Global Risk Management & Compliance Committee”, chaired by the Global CEO and composed of Regional CEOs and HQ Executive Officers, has been established at the global headquarters.
In addition, the “HQ/SJ Compliance Committee” oversees compliance in the Japan region.
Globally, the RMO at each regional headquarters plays a central role in the provision of the “Shiseido Code of Conduct and Ethics” training with globally common content to promote the understanding and practice of the “Shiseido Code of Conduct and Ethics” among all employees. We are also promoting the dissemination of the “Shiseido Code of Conduct and Ethics” to everyone working in the Shiseido Group, including executive officers, full-time employees, fixed-term contract employees or part-time employees, by encouraging temporary employees and others to practice in the training.
Additionally, we regularly conduct the “Shiseido Group Engagement Survey” to continually monitor the status of compliance with the “Shiseido Code of Conduct and Ethics” and reflect this in training and various compliance activities.
We are also working to ensure thorough compliance with each regulation by conducting various training and awareness-raising activities on a regular basis at each regional headquarters related to the “Compliance Rules Regarding Prevention of Bribery” and the “Compliance Rules Regarding Prevention of Cartels,” which are detailed rules within the “Shiseido Code of Conduct and Ethics”.
We conduct human rights awareness training to prevent discrimination in the workplace, and with respect to harassment, training is conducted at least once a year at all Shiseido Group business sites in Japan to eliminate it. We also conduct training sessions to improve communication in various settings to build an open and encouraging workplace culture.
In addition to training for all employees, group training is also provided for Executive Officers, managers, and new employees, with content tailored to the characteristics of each position, job level, and business location.
The “Shiseido Code of Conduct and Ethics” states clearly that ”We do not engage in bribery or corruption, and we do not give or accept material gifts or entertainment that may cause suspicions about our business dealings or interests”. The “Shiseido Group Policy on Anti-Corruption” approved by the CLO highlights that it will promote efforts to ensure anti-corruption measures and fulfil its social responsibilities. Furthermore, we have established the "Compliance Rules Regarding Prevention of Bribery" which stipulate the internal procedures for reporting and applying for the giving and receiving of entertainment and gifts that we must comply with and address in our business activities.
We proactively provide training to ensure that employees are familiar with these policies and regulations, including the internal procedures that are followed when giving or receiving entertainment and gifts. The Risk Management Department monitors regularly to assess whether these policies and regulations are implemented appropriately.
We offer Hotlines/Helplines*1 for the purpose of detecting and correcting violations against the laws and regulations, the Articles of Incorporation, and internal regulations within the Shiseido Group. The Hotlines/Helplines are operated according to internal regulations that specify confidentiality whose primary purpose is to prohibit the disclosure of information learned when responding to a whistleblowing or consultation to third parties not involved in responding to that specific whistleblowing or consultation, prohibition of disadvantageous treatment or reprisals against whistleblowers/consulters, elimination of conflicts of interest, and the process for handling whistleblowing and consultations, etc. These internal regulations are disclosed via the internal intranet so that employees can view them at any time.
Globally, we have established the Hotlines/Helplines at each regional affiliate*2 for employees to voice their concerns about or report on words and/or actions which are or may be unethical or in violation of laws in the relevant countries/regions, the internal regulations, and the “Shiseido Code of Conduct and Ethics”. In Japan, in addition to the above, the “Shiseido Hotline”*3 handles also general workplace issues and reports.
At the global headquarters, the “Shiseido Global Hotline”*4 and the “Shiseido Group Whistleblowing to the Audit Committee”*5 have been established to receive reports related to Directors, Corporate Executive Officers, Executive Officers and hotline staff members directly from any employee in the Shiseido Group.
Except for some Hotlines/Helplines, the initial reception of each Hotline/Helpline is operated by an independent third-parties, such as companies specializing in report handling, from Shiseido Group, and anonymous reports and consultations are also accepted.
The training on the “Shiseido Code of Conduct and Ethics” also covers the promotion of the use of Hotlines/Helplines. In addition, other training sessions educate employees about the main purpose, system, process, usage methods, and contact points of these Hotlines/Helplines, thereby deepening their understanding and encouraging their use.
The division in charge of the Hotlines/Helplines handles whistleblowing and consultations with due care to protect the privacy of those concerned. It accepts whistleblowing and consultations related to all kinds of improper acts, including discrimination, harassment, and bribery, as well as acts that may be regarded as such. And as necessary, a fact-finding investigation of those involved is launched. If improper acts or the like are revealed, we stop such acts immediately and implement corrective measures and reoccurrence prevention measures rapidly in cooperation with the relevant companies, offices, and divisions/departments. We also take disciplinary action against employees who have been involved in such acts in accordance with employment regulations and other internal regulations. If any cases of retaliation, disadvantageous treatment, harassment, etc. toward whistleblowers or consulters are identified, we take appropriate relief/restoration measures immediately in cooperation with the relevant companies, offices, and divisions/departments, and take strict measures including any disciplinary punishment against the persons who have engaged in such retaliation, disadvantageous treatment or harassment.
If the case may pose a risk to our business management, it is promptly reported to management from the divisions/departments. Any serious compliance-related concern is reported to management of the “Global Risk Management & Compliance Committee” and/or “HQ/SJ Compliance Committee”, and we work to eliminate the concern immediately and implement corrective measures and reoccurrence prevention measures rapidly in cooperation with the relevant companies, offices, and divisions/departments.
The number of whistleblowing and consultation cases received through the Hotlines/Helplines and the actual responses to them are reported to the “HQ/SJ Compliance Committee” and Audit Committee on a regular basis annually for the review, management, and supervision of the appropriate operation of the Hotlines/Helplines. In addition, we evaluate the proper operation and feasibility of the Hotlines/Helplines through reviews by external experts such as outside attorneys and make continuous improvements based on such evaluations.
We set up the Shiseido Business Partner Hotline for business partners in Japan to allow them to report on human rights and compliance violations arising from transactions with Shiseido group companies. The same approach is implemented by regional headquarters outside of Japan.
For more details, please refer to "Social Data."
In order to identify and reduce risks related to discrimination, harassment, and compliance in the workplace, in addition to accepting whistleblowing and consultations, we assess workplace conditions using the “Shiseido Group Engagement Survey,” etc., which are periodically conducted throughout the Shiseido Group. For companies, offices, and departments where problems have been identified by the surveys, we propose and implement improvement measures based on the survey results.
In addition to this, we provide employee training on issues identified from the analysis of the survey results to prevent discrimination, harassment, and compliance risks.
The “Shiseido Code of Conduct and Ethics” states the following: “We do not work with individuals or organizations that engage in illegal activities, such as threatening public order or safety. We also do not respond to any requests for money or support from such individuals or organizations.”
In Japan region, a coordination office is established in the Risk Management Department at the global headquarters to effectively gather information. We also maintain manuals on the internal intranet on how to cope with such forces. We are taking measures to strengthen its collection of outside information and cooperation with external organizations by coordinating with local police offices and being a member of an organization that promotes the exclusion of anti-social forces.
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