Regarding the Revised Kao Business Conduct · 2020-06-16 · 1 Regarding the Revised Kao Business...

1

Regarding the Revised Kao Business Conduct Guidelines (BCG) Casebook

This casebook is designed to provide you, each member of the Kao Group, with an opportunity to reassess whether you and your colleague's conduct complies with the Kao Business Conduct Guidelines (BCG). In this casebook, you will see cases that are similar to those you might encounter when conducting business globally. We hope this casebook will help you deepen your understanding of the BCG and provide guidance on proper conduct.

When you feel unsure of your act /decision at work or find illegal, unethical or other questionable conduct, you should not worry all alone and make a decision on your own. Rather, you should bring them to the attention of a supervisor, appropriate department, the Compliance Committee and /or call the internal / external compliance hotlines.

Furthermore, we expect executives and managers to communicate the rules of the BCG to all members of their department.

April 2014July 2016June 2017

Kao Corporation Compliance CommitteeFor inquiries, please contact : [email protected]

HANAKO TSUKINO（23）She joined the Company two years ago and lately she has gotten accustomed to her job. As her part time job, she has begun working at a beauty salon which is run by one of her friends from her college days.

Profile of the characters

TARO KAO（24）He joined the Company t h re e yea rs ago and currently l ives with his wife, who works for one of Kao's competitors and with their cat. Recently, he made a business trip abroad a lone and has been enjoying ful ly his private and corporate life.

2

CASE 1

CASE 2

CASE 3

CASE 4

CASE 5

CASE 7

CASE 6

CASE 8

CASE 9

CASE 10

CASE 11

CASE 12

CASE 13

CASE 14

CASE 15

CASE 16

CASE 17

CASE 18

CASE 19

CASE 20

CASE 21

CASE 22

CASE 23

CASE 24

CASE 25

CASE 26

Which data should we use?

What should I do if my supervisor leaves the office claiming business reasons but I discover otherwise?

What should I do when I hear about a possible adverse reaction concerning our product?

How should I deal with a comment from my friend?

Should I alert an employee when there is a risk of injury?

In procurement, are price and quality the only priorities?

What should we pay attention to in meeting with Kao's competitors at an industry association conference?

In the process of immigration,is it appropriate to pay some money to a government official in his/her personal capacity?

Is it acceptable for me to work excessive overtime so long as I am content?

Is it necessary to be patient to keep peace at work?

What is meant by a "clean" relationship with public administration?

Can I expense entertainment that was provided this year during next year？

Can I talk about information of the Company that has not been released yet at home?

I would like to post an explanation to alleviate misunderstanding of Kao's products on social media...

Can I use an illustration on the Internet freely without permission?

Do I have to provide information on my previous company?

Can I use the customer list that you have prepared for another purpose?

Is it my fault that I upset my colleague from abroad?

Can I ignore a rumor that a business partner is using child labor?

Can I take home a stuffed animal that was created for a sales promotion?

My spouse works for a competitor.Can I share confidential information of my Company with him/her?

Do I have to notify the Company that I am helping my sister run her company?

Do I have to notify the Company that the company I am working for as my side job starts transactions with one of the Kao Group companies?

Can I leave it to each employee to read and understand the BCG?

Should all the allegations be reported directly to the internal or external compliance hotlines?

Can I provide personal information of an employee to a person outside of the company?

CONTENTS

3

Principles of Corporate Ethics

4

He seems to be very cheerful today...


In developing products, my supervisor instructs me to prepare for an in-house report on safety of the products using only favorable data on the results of safety experiments and disregard unfavorable ones for the evaluation of the products.

My immediate supervisor left the office stating that he/she had a business meeting with Client A, but then Client A called me and informed me that no such meeting had been scheduled. I want to refrain from reporting it because I am afraid he/she might retaliate if he/she hears that I reported it.

What should I do if my supervisor leaves the office claiming business reasons but I discover otherwise?

I feel that I can comply with my supervisor's request so long as I am not manipulating data or values in the results of experiments but just determining which of them we should pick up for the report. Is it acceptable to handle data like this? Please refer to page 5.　

Since my supervisor has not caused any trouble in our department so far, should I refrain from reporting this case？　 Please refer to page 6.　

Q.

Q.

CASE 1

CASE 2

Which data should we use?

5

Reference：BCG（Principles of Corporate Ethics 2 , 5 , Fundamental Rule 01-1）

We shall comply with the BCG and shall not pursue profits at the expense of the ethical principles set out in the BCG.

We shall not take any action which violates laws and regulations, goes against the BCG or is otherwise unethical, even if such action is for the purpose of benefitting the company or under the instruction of a line manager. The company does not condone any such action.

In case that you commit the action indicated above, you may be subject to disciplinary actions.

CASE 1 Considerations

No, it is not acceptable.Selecting favorable data only for use in an internal report might cause the Company to make the wrong decision due to such report and it might damage the product's and the Company's reputation. First of all, you should raise your concerns frankly and sincerely with your supervisor. If the problem cannot be solved through discussion with your supervisor, you should raise your concern with your supervisor's supervisor, a department which has jurisdiction over the incident, or the internal/external compliance hotlines.

Answer

6


Reference：BCG（Principles of Corporate Ethics 6 , 7 ）

If you witness an inappropriate action, such as violation of laws, regulations, the BCG or business ethics, you are required to report it immediately.

The company shall protect and safeguard to the fullest extent possible the privacy of anyone who reports information regarding illegal, unethical or other questionable conduct or seeks consultation about such conduct.

The company will not tolerate any form of threat or retaliation against a person who reports suspected illegal, unethical or other questionable conduct, or seeks consultation about such conduct in good faith.

ConsiderationsCASE 2

No.When a person leaves work claiming a business reason, but is actually using the time for a personal reason, he/she is in breach of the BCG and committing fraud. When you encounter such a case, please warn him/her because seniority does not matter when it comes to compliance issues. In case that he/she does not show any remorse or improvement on his/her conduct or when it is hard to warn him/her directly, please consult with your supervisor's supervisor, a department which has jurisdiction over the incident, the Compliance Committee and/or the internal/external compliance hotlines.

Answer

7

Ensure the Safety and High Quality of Products and Services

01

8

01Ensure the Safety and High Quality of Products and Services

One of my acquaintances, who uses a product of the Kao Group for her daily skin care routine claimed that she had gotten a rash on her hands and asked whether the Kao Group's product contains any skin sensitization substances. As I have no specific knowledge regarding the product, I informed her that I did not know whether it did. I did not report the matter to the Company either.

I received a comment from a friend of mine that the warning and instruction on a certain Kao product are not clear.

How should I deal with a comment from my friend?

As I do not know whether my acquaintance's rash was caused by the product of the Kao Group that she had used and as I have no particular information about the product, I decided not to do anything further. Did I handle the case properly?　 Please refer to page 9.　

I have decided not to report the comment to anyone as I know very little about the product and I consider the nature of the comment to be trivial. Is my decision appropriate?　 Please refer to page 10.　

Q.

Q.

CASE 4

CASE 3 What should I do when I hear about a possible adverse reaction concerning our product?

9

Reference：BCG（Fundamental Rule 01-2 ）

A report of a possible adverse reaction from a Kao Group product should not be ignored. Your receipt of such report should be conveyed to the relevant department or your supervisor immediately.

All the comments on safety or quality of products and services are important even if they may seem to be trivial to you.

Any delay caused by failure to communicate reports of possible adverse reactions relating to the Company's products damage to the Company and the brand. Please report such information immediately.


No.You must report the case to the relevant department or your supervisor immediately.

Answer

10

01Ensure the Safety and High Quality of Products and Services

Reference：BCG（Fundamental Rule 01-2, 01-4）

As there is a possibility that behind one comment lurks a serious risk, you should immediately report what you know to the Consumer Communication Department, the Product Quality Management Department and the Legal Department.

It is important to receive the customers' comment sincerely, share the information with relevant departments, decide on action (if any) and provide feedback to the customer.

If it is found that an indication on a product could cause a misunderstanding or is inappropriate, we shall promptly revise such indication.

ConsiderationsCASE4

No.Even if it appears trivial to you, you should not on your own decide to ignore a comment if it concerns product safety or quality. You should immediately report what you know to the relevant departments.

Answer

11

Thoroughly Consider the Environment and Safety

02

12

Is it really right to prioritize cost rather than environmental conservation?

02Thoroughly Consider the Environment and Safety

In a building of the Company, you see an employee at another department run hastily and unstably down the staircases with both his/her hands occupied with lots of product samples.

Products we purchase have been through many steps of processing from their raw materials until they reach you and many people in the world are involved in this supply chain.

In procurement, are price and quality the only priorities?

Should I alert him/her even if he/she is not my acquaintance?　 Please refer to page 13.　

As the only thing that matters is price and quality, there is no need to consider environmental impact of the materials we purchase. Is my understanding correct?　 Please refer to page 14.　

Q.

Q.

CASE 6

CASE 5 Should I alert an employee when there is a risk of injury?

13

Reference：BCG（Fundamental Rule 02-4）, Basic Philosophy and Policies on the Environment and Safety,　　　　 Kao Responsible Care Policy

Under the motto "Safety first," we shall strive to secure a safe working environment through risk assessments and safety activities. If we run hastily and unstably down the staircases with both our hands occupied with lots of product samples, there is a risk that we will be injured by falling off the staircases.

It is very important to reduce the possibility of risk, if any. We must confirm whether there are any problems with facilities and operations and point out possible risks to each other to ensure a safe and comfortable workplace.

A seemingly minor issue can actually result in a big injury. There are several actual cases in Kao Group Companies where such careless action has led to serious injury in the workplace.


Yes. You should talk to him/her to prevent an accident.If you feel that such employee's actions are dangerous, you should help him/her. Conversely a person carrying lots of product samples should ask for help to prevent an accident from happening.

Answer

14

02Thoroughly Consider the Environment and Safety

Reference：BCG（Fundamental Rule 02-1）

Environmental conservation and human safety are essential for the existence and activities of the Company. Every employee is expected to make efforts to promote environmental conservation in their work.

In procuring every product from stationery around you to raw material of products, you are expected to select products considering environmental conservation, as well as their cost and function, etc.e.g. Ｗe have committed to procuring palm oil, from which detergents are produced, and raw materials for diapers and cardboard, that have been certified according to certain environmental standards.

The certification can be a benchmark for you to judge whether those products are eco-friendly or not.

Please proceed with caution if the prices of products are extremely low. Although it may be that supplier is just more efficient in its production, it also may be that supplier is not complying with environmental laws/commitments and/or violating the human rights of its employees.

ConsiderationsCASE6

No.Employees must pay at tention to environmental conservation when selecting suppliers. If you find a material that is certified under a respected green certification, please consider selecting such material.

Answer

15

Maintain Fair and Honest Transactions

03

16

03Maintain Fair and Honest Transactions

You are going to attend an industry association conference in which Kao's competitors will also attend.

On your business trip, you are waiting in a long line to go through immigration at a foreign airport. Then, an airport official comes over to you, asking for US$10 to expedite the procedure for immigration.

In the process of immigration, is it appropriate to pay some money to a government official in his/her personal capacity?

Are you free to talk about anything you want with the other participating companies? Please refer to page 17.　

Is it acceptable to pay such a small amount to speed up the procedure for immigration because of the tight schedule?　 Please refer to page 18.　

Q.

Q.

CASE 8

CASE 7 What should we pay attention to in meeting with Kao's competitors at an industry association conference?

17

When you meet competitors of the Kao Group, it is important to pay attention to what you discuss in order not to infringe antitrust laws. For example, if you exchange information such as the product price, estimation of production volume and production capacity, your actions might be deemed in furtherance of a cartel, which is banned under most antitrust laws.

Kao Group members must be careful not to disclose confidential information (including information that has not yet been made public) to anybody outside the Company until it is officially made public by the Company. Notwithstanding the foregoing, an employee may disclose confidential information to a third party under a confidentiality agreement, if such disclosure is approved by the company's management and the disclosure is in furtherance of a valid business purpose.


No.If you talk with competitors about such information as mentioned above, your action may be deemed in furtherance of a cartel, which is illegal under the antitrust laws or competition laws of most countries. Even if the nature of the conversation is not a violation of antitrust laws or competition laws, you must still be careful not to disclose confidential information of the Kao Group to competitors.

Answer

Reference：BCG（Fundamental Rule 03-1）,　　　　　　Antitrust Checklist

18

Reference：BCG（Fundamental Rule 03-3）, 　　　　　　Kao Anti-Bribery Guidelines

03Maintain Fair and Honest Transactions

Making a small payment to a government official to expedite a routine government action is considered to be a "facilitation payment," which the Kao Group prohibits. Facilitation payments are a type of bribery.

Any payments made to assure the life, liberty or safety of an individual facing immediate risk would not be considered a violation of Kao Group policies.

ConsiderationsCASE8

No.A small payment to an official at an airport for the purpose of speeding up the immigration procedure is deemed a "facilitation payment" that the Kao Group prohibits. However, payments which are specifically authorized by local law, and which are made to a government agency (not to an individual) to speed up routine government actions (such as official immigration fast lanes) are not considered facilitation payments.

Answer

19

Respect Employees' Individual Human Rights and Diversity, and Maximize Their Potential

04

20

04

How should we handle a persistent proposal for dining during business hours?

Respect Employees' Individual Human Rights and Diversity, and Maximize Their Potential

I am in charge of an important project, which requires me to work overtime until late at night on a daily basis and to report to office on weekends too. I have not been warned by my supervisor yet for my overtime. Currently, I am very much satisfied with my job assignment and am in good shape as well. I am about to exceed the working hours allowed under the local labor laws.

One of my colleagues likes to make inappropriate remarks that make others feel uncomfortable. I want that person to stop making such remarks at work, but I am afraid that if I were to ask the colleague in question to stop, it would dampen the atmosphere in the office, and lead to an awkward work environment.

Is it necessary to be patient to keep peace at work?

Can I keep on working like this because my supervisor makes no remark on my circumstances？　 Please refer to page 21.　

Should I report it？　 Please refer to page 22.　

Q.

Q.

CASE9

CASE10

Is it acceptable for me to work excessive overtime so long as I am content?

21

Companies have a responsibility to provide a safe and healthy working environment for their employees in accordance with applicable labor laws.

Although working a lot of overtime might be needed especially during certain seasons, managers have a responsibility to monitor their members' working hours and circumstances and must work to improve them if their working hours become excessive.


No.Although you may feel that you can handle the excessive overtime, if it continues for a long period of time, it may result in various health problems. Please inform your supervisor about the excessive overtime and the likelihood that you will exceed the legal limit with your supervisor. If the problem cannot be solved through discussion with your supervisor, you should raise your concern with your supervisor's supervisor, a department which has jurisdiction over the incident (such as human capital development ) and/or the internal/external compliance hotlines.

Answer


22

04Respect Employees' Individual Human Rights and Diversity, and Maximize Their Potential

Though meant to be jokes, remarks that make others feel uncomfortable cannot be overlooked. To establish a comfortable workplace, measures to solve this issue should be taken.


Yes, of course!The Kao Group does not condone inappropriate jokes or remarks that hurt the feelings of others at the workplace. If possible, you should express your feelings with the person who makes such remarks directly and ask him to stop. If this is difficult, please consult with your supervisor or supervisor's supervisor first, and then in case it does not lead to a solution, bring your concerns to the internal/external compliance hotlines.

Answer


23

Maintain a Fair, Open and Exemplary Corporate Position

06

24

06Maintain a Fair, Open and Exemplary Corporate Position

You received a call from a man claiming to work for a consumer loan company. The man demands in a gruff voice, "Please let me know the phone number of Mr. X at your company to discuss his repayment schedule."

We were advised to hire a local consultant to get all the necessary government approvals and licenses which the Kao Group needs in order to operate a business in a foreign country. The consultant requested a big commission and said he would use the money to move things forward. I do not know where the money is going.

What is meant by a "clean" relationship with public administration?

Can I provide the information requested as it is easily accessible in the company's phonebook？　 Please refer to page 25.　

Can we make a payment to them without confirming the situation？　 Please refer to page 26.　

Q.

Q.

CASE11

CASE12

Can I provide personal information of an employee to a person outside of the company?

Can I pay even if I suspect that the consultant will pay bribes on our behalf?

25

Reference：BCG（Fundamental Rule 06-2, 07-3 ）

You have to refrain from providing personal information without permission to any person outside of the Company. You are required to handle this issue carefully and deliberately.

As the caller might be a member of an anti-social organization, you are required to reject his request decisively and firmly.


No.You must not provide the personal information of anybody in the company, including office phone numbers, even though a caller demands such information. In such a case, you should request how Mr. X can get back to the caller and hang up the phone. Then, you should contact Mr. X, telling him that there has been a call.

Answer

26

06Maintain a Fair, Open and Exemplary Corporate Position

Hiring a third party consultant in order to insulate the company from knowledge about bribes being paid on its behalf is not a viable strategy for avoiding liability. Companies are responsible if they know or should have known based on the facts that a bribe would be paid on its behalf.

You should review the following points before engaging such consultant:- Whether the commission is far higher than the going rate.

- Whether the services are clearly defined or not.

- Whether there is a high risk of corruption in the country/industry.

- Whether the consultant has a close relationship with government officials 　(e.g. a relative, friend or is introduced by a government official )

- Whether the consultant has relevant expertise.

- Whether the terms of transactions such as the method of payment 　are appropriate.


No. As there is a possibility that a part of consulting fees may be used for bribing a government official. You should confirm with the consultant what he meant by "move things forward" and conduct due diligence based on the aforementioned factors. You should engage the consultant only after conducting due diligence and you feel comfortable that no bribes will be paid. In case you have questions or concerns, you should consult the issue with your supervisor or Compliance Department at Kao HQ or the responsible Legal Department.

Answer

Reference：BCG（Fundamental Rule 03-3, 06-3）, 　　　　　　Kao Anti-Bribery Guidelines

27

Strictly Manage Information and Assets

07

28

She must be happy to hear this news!

07Strictly Manage Information and Assets

At the end of the year, we were suddenly contacted by our business partner to have dinner with them and we paid all the expenses including theirs. However, because I had heard from my boss that the budget for our department was running short and our entertainment expense for this meal could not be processed this year, I asked the restaurant to issue a receipt without the date of expenditure. Using this receipt, I would like to expense the cost for the next year.

One of my family members is a big fan of the celebrity who will be advertising our company's product. As this information has not been announced publicly yet, I warned her not to discuss this information with anyone until it is announced.

Can I talk about information of the Company that has not been released yet at home?

Is there a problem with my action？　 Please refer to page 29.　

Is there any problem with my action？　 Please refer to page 30.　

Q.

Q.

CASE13

CASE14

Can I expense entertainment that was provided this year during next year？

29


You cannot ask for a receipt without the date of expenditure.

All expenses must be recorded in the period when they have occurred.


Yes.This is a violation of the accounting rules and the BCG. A receipt without date of expenditure enables you to manipulate arbitrarily the time when the cost is expensed, which constitutes inappropriate accounting. Since an expense that has incurred in this year must be treated as such for this year, you have to treat it as per the accounting rule.

Answer

30


Kao Group members must be careful not to disclose confidential information (including information that has not yet been made public) to anybody outside the Company until it is officially made public by the Company. Notwithstanding the foregoing, an employee may disclose confidential information to a third party under a confidentiality agreement, if such disclosure is approved by the company's management and the disclosure is in furtherance of a valid business purpose.

You need to be careful about protecting the company's confidential information not only when dealing with business partners, competitors and mass media, but also with family members, friends and acquaintances.

We have seen several cases at other companies in which employees or their family members carelessly disseminated company's confidential information by way of Twitter or other social media sites.


Yes. There is a problem. You must not reveal the Company's confidential information even to your family members.

Answer

Reference：BCG（Fundamental Rule 07-3）, 　　　　　　Kao Group Social Media Policy

31

I saw some comments on social media that the Kao Group doesn't operate about our product which is false and misleading.

I would like to post my explanation to alleviate misunderstanding about the product without disclosing that I am an employee of the Company. Is this ok?　 Please refer to page 33.　

Q.

CASE15 I would like to post an explanation to alleviate misunderstanding of Kao's products on social media...

32

By using this illustration, my presentation tomorrow will be unforgettable!


I found a beautiful illustration on the Internet, which is just perfect for a PowerPoint presentation I plan to make for the Company in meetings with business partners.

Is it acceptable to use the illustration in presentation materials to be shown in meetings with business partners without confirming usage rights？　 Please refer to page 34.　

Q.

CASE16 Can I use an illustration on the Internet freely without permission?

33

Reference：BCG（Fundamental Rule 07-3）,　　　　　　Kao Group Social Media Policy　　　　［PERSONAL SOCIAL MEDIA COMMUNICATIONS(2,3, and 10)］

You may not post a response on a Kao Group branded message site (unless you are specifically authorized to respond on behalf of the Company).

On social media which the Kao Group doesn't operate, any statements related to some way to Kao Group's business or products may be perceived and criticized as a fraudulent attempt by Kao Group to gain some sort of advantage, or could result in a conflict of interest with the company. Therefore, please think deeply before posting about the company or its products on social media.

For example, if you provide a review or other input regarding a Kao Group product, the fact that you are employed by the Kao Group must be disclosed so that others can factor in that information when evaluating your rating/input.

If you come across a positive or negative comment about the Kao Group or our products in your personal use of social media that you believe should be important to the Kao Group, please share it with us by e-mailing someone who is authorized to deal with social media on the Kao Group's behalf so they can then properly address the comment as necessary.


No.When stating an opinion about the Kao Group or its products, you should specifically state that the posting is your personal statement and not made on behalf of the Kao Group.

Answer

34




START

END

Please confirm whether you need to inform your use to the relevant person or entity, make an attribution of copyright ownership and any other terms and conditions of use.

Yes

No

You cannot use it.

No

Yes

Have you obtainedpermission of use fromthe copyright owner orthe person responsible

for the website(e.g. photo library)?

Please confirm whether you need to pay a licensing fee, make an attribution of copyright ownership and any other terms and conditions of use.

Does the terms andconditions of the website

allow for yourintended use?

You canuse it.

You canuse it.

No. Illustrations which are publicly available on the Internet are normally copyrighted by the illustrators or a third party. If you use an illustration without the permission of the holder of the copyright, you might be committing copyright infringement and the company may be liable to pay damages to the copyright holder. To confirm whether permission is required to use the illustration or not by checking the terms and conditions of the website where you found the illustration is needed. If approval is required, you should directly contact the person or entity responsible for the website to get approval for use of the illustration. In some cases, a license fee may need to be paid for use of the illustration.

Answer

［Flow chart for judging use of material on the Internet for business purposes］

35

I moved to the Company from one of Kao's competitors and my supervisor requests that I submit a report about business plans and strategies of my previous company.

Do I need to submit the report？　 Please refer to page 37.　Q.

CASE17 Do I have to provide information on my previous company?

36


I have a customer list that I built through a customer satisfaction survey on beverage products. In conducting the survey, I explained to the respondents that the Company would use their personal information for the research and development of beverage products and received a written consent from the survey respondents for such use of their personal information.My colleague who handles cosmetics products is aware that I have a customer list consisting of respondents' names, addresses, sex, age and e-mail addresses, which he/she would like to use to send some e-mail advertising targeted at a particular age-group. Is it OK to provide the customer list to my colleague?

Can I provide it as per her request？　 Please refer to page 38.　Q.

CASE18 Can I use the customer list that you have prepared for another purpose?

37

Reference：BCG（Principles of Corporate Ethics 5 , Fundamental Rule 07-3）

We shall carefully manage the company's confidential information, personal information and intellectual property, as well as that of others. We shall not make illegal use of such information.

The Kao Group shall always collect information in a lawful manner. A supervisor shall not try to elicit trade secret information of a competitor from a new employee that had previously worked for such competitor as it is a violation of the BCG, business ethics and is also likely illegal.

If an employee discloses such information as per the instruction of his/her supervisor, this action might infringe local law concerning unfair competition and trade secrets exposing the company to criminal and civil penalties.


No.You must not submit the information below:- Information about which you have a duty of non-　　disclosure to your previous company.- Trade secret information of your previous company.

Answer

38


Personal information cannot be uti l ized without permission of the respondents to beside use of the original purpose.


No.The survey respondents listed on your customer list provided their personal information for the purpose of research and development for beverage products (“Purpose”). Therefore, use of the personal information must be restricted to the fulfillment of such Purpose. They did not agree to be sent e-mail advertising for cosmetics products. You must, therefore, not provide the customer list to your colleague.

Answer


39

Respect Human Rights and the Diverse Cultures of Individual Countries and Regions and Observe Laws and International Rules When Conducting Business Activities

09

40

09Respect Human Rights and the Diverse Cultures of Individual Countries and Regionsand Observe Laws and International Rules When Conducting Business Activities

One of my Thai colleagues came to Japan on his business trip after he successfully completed a big project and had been made manager of his division. At the welcome party, I congratulated him and as a sign of affection I patted him on his head. For some reason he became furious!

I received an anonymous call claiming that one of our suppliers uses child labor.

Is it my fault that I made him angry？　 Please refer to page 41.　

As this is not a claim that the Kao Group itself uses child labor, can I just ignore this claim？　 Please refer to page 42.　

Q.

Q.

CASE19

CASE20

Is it my fault that I upset my colleague from abroad?

Can I ignore a rumor that a business partner is using child labor?

41

Cultures, customs and religions differ in each country and region. Behavior which is acceptable and normal in a country and region can be rude and disrespectful in another.

We shall respect human rights and diversity in each country and region and shall comply with the laws of the countries and regions in which we operate.


Yes. In Thailand, the head of human's body is considered to be a sacred part where the spirit stays. Since touching someone's head is highly offensive, you have to be careful not to do so. Not only in Thailand but also in other countries and regions there are their own customs that you must know before visiting. To avoid an unexpected trouble, you should make an attempt to understand local cultures before making your visit.

Answer


42

Kao Corporation, as a signatory of the UN Global Compact, has committed to embrace, support and enact, within its sphere of influence, a set of core values in the areas of human rights, labor standards, the environment and anti-corruption. One of the core values is to work for the effective abolition of child labor. The Kao Group has also implemented the Kao Human Rights Policy under which it has committed to respect human rights and address adverse human rights affects in its business activities.

To put the Kao Group commitment into practice with regard to its supply chain, the Kao Group has established the "Guidelines for Supplier's Assessment". In the guidelines, the Kao Group states that it prioritizes suppliers based on whether they have implemented measures to ban illegal labor. The term "child labor" as defined by the International Labour Organization is"… work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development.


No.Please report and seek the advice of your superior and the responsible division of human rights (the procurement division, the legal department, and sustainability department). It is important for the Company to conduct due diligence of the supplier to determine whether the allegation is true. If it is true, the Kao Group will take necessary action such as terminate the supplier or work with the supplier to stop such practices.

Answer

Reference：BCG （Fundamental Rule 09-1）,　 Kao Human Rights Policy, 　　　　　　Guidelines for Supplier's Assessment

It refers to work that:• is mentally, physically, socially or morally dangerous and harmful to children; and• interferes with their schooling by:• depriving them of the opportunity to attend school;• obliging them to leave school prematurely; or• requiring them to attempt to combine school attendance with excessively 　long and heavy work.”

09Respect Human Rights and the Diverse Cultures of Individual Countries and Regionsand Observe Laws and International Rules When Conducting Business Activities

43

Draw a Distinct Line between Business and Private Matters

10

44

Do I have to be careful about my conversations at home with family?

10Draw a Distinct Line between Business and Private Matters

We created a stuffed animal to be given away as freebies during a sales promotion campaign. Unfortunately, the campaign did not go as planned and we have many of the stuffed animals remaining in our office.

My spouse works for one of Kao's competitors.

As they will be disposed of anyway, can I take one home with me without telling anyone？　 Please refer to page 45.　

Do I have something to pay attention to at home？　 Please refer to page 46.　

Q.

Q.

CASE21 Can I take home a stuffed animal that was created for a sales promotion？

My spouse works for a competitor.Can I share confidential information of my Company with him/her?

CASE22

45

Careful control of the company's tangible and intangible assets, which shall not be used illegally.

All the goods and products produced for business purposes at the expense of the Company are the assets belonging to the Company.


No.Stuffed animals and other freebies may appear to be trivial. However, these are still assets of the Company. You may not take freebies home with you without permission of the responsible person and only in accordance with internal rules at your Company.

Answer

Reference：BCG（Fundamental Rule 07-4, 10-1）

※Misappropriating company property is a violation of laws and regulations 　and may subject the violator to criminal sanctions.

46


It is likely to cause conflicts of interest between the Kao Group and you in case that you leak confidential information for the Kao Group to your spouse. You are required to draw a distinct line between business and private matters and to avoid conflicts of interest.

You must not discuss the confidential information of your company to your spouse and your spouse should not discuss the confidential information of his/her company to you.


Yes.Since your spouse works for one of the competitors of the Kao Group, your discussions at home can give rise to a conflict of interest. You have to avoid actions at home which damage the Kao Group's legitimate interests. For instance, you must not disclose Kao Group's confidential information to your spouse. You must also not obtain the competitor's confidential information from your spouse.If you are an executive of the Kao Group Company, you shall provide notification to your Company that your spouse is employed at a competitor.

Answer

Reference：BCG（Fundamental Rule 10-1）, Kao Guidelines for Avoiding Conflicts of Interest

47

My sister runs a trading company which deals in the importing and sale of merchandise such as hair-care and skin-care products from all over the world. While being employed by a Kao Group company, I am in charge of accounting at her company on an irregular basis on weekends and weekday nights.

Is it required to submit any document for notification of my position？ Please refer to page 49.　Q.

CASE23 Do I have to notify the Company that I am helping my sister run her company?

48

Can I skip this procedure?


I am an employee of a Kao Group company. As a side job, I work part time at a beauty salon, which a friend of mine who I have known for a long time owns. Transactions between the salon and the Kao Group company are scheduled to start.

Do I have to submit any notification of my side job to the Company？　 Please refer to page 50.　Q.

CASE24 Do I have to notify the Company that the company I am working for as my side job starts transactions with one of the Kao Group companies?

49

The Kao Group's Guidelines for Avoiding Conflicts of Interest stipulate that "If a Close Relative or Relevant Acquaintance of an Employee＊1 sells Competitive Products or provides Competitive Services, and if such Employee is personally involved＊2 in such business, the Employee shall provide notification to the Company."


Yes.As the Guidelines for Avoiding Conflicts of Interest states as follows, you have to submit a notification to the Company.If a Close Relative or Relevant Acquaintance of an Employee sells Competitive Products or provides Competitive Services, and if such Employee is personally involved in such business, the Employee shall provide notification to the Company.

Answer

Reference：BCG（Fundamental Rule 10-1）, 　　　　　　Kao Guidelines for Avoiding Conflicts of Interest［Ⅰ.2) ］

＊1 "Close Relative or Relevant Acquaintance of an Employee" refers to an individual’s spouse, parents, siblings, grandparents, children and grandchildren, and the spouse’s parents, siblings and grandparents. Close Relatives also include the spouse of an individual’s siblings, children and grandchildren.

＊2“Personally involved” refers to personal involvement in or support of a competitive business by providing purchasing, sales or accounting services, or providing monetary loans or debt guarantees, or being appointed as an executive.

50


Regarding whether a side job is allowed, please refer to the relevant guidelines at your company.

You shall notify the Company in writing as soon as you become aware that a company for which you work (even on a part-time basis) has been transacting with one of the Kao Group companies or that the Company is going to start transactions with one of the Kao Group companies.

You may not take part in the decision-making process for either the Kao Group company or the salon due to a conflict of interest.


Yes.Even if your work at the salon is merely part-time, you are required to submit notification to the Kao Group company where you work as there is a potential for a conflict of interest. You may not take part in the decision-making process for either the Kao Group company or the salon due to an actual conflict of interest.

Answer

Reference：BCG（Fundamental Rule 10-1）,　　　　　　Kao Guidelines for Avoiding Conflicts of Interest［Ⅱ.1).ⅱ)］

51

Executives and Managers shall Take the Lead in Complying with the Kao Business Conduct Guidelines and shall be Good Role Models for all Employees, and be Fully Responsible for Communicating the Kao Business Conduct Guidelines to their Members.

11

52

You should call the compliance hotline to report your concern, as I cannot really help you.

I am willing to listen to your concerns.

The BCG is well-known among all employees of the Kao Group and is available for everyone to access.

An employee wants to talk to you, a manager, about a potential compliance or business ethics issue.

I feel there is no need for me as a manager to stress the importance of the BCG any longer because reference to it is quite easy for all the members. Is this understanding correct？　 Please refer to page 53.　

Since the Kao Group has established the internal/external compliance hotlines, can I direct such employee to bring all his/her concerns to them？　 Please refer to page 54.　

Q.

Q.

CASE25

CASE26

Can I leave it to each employee to read and understand the BCG?

Should all the allegations be reported directly to the internal or external compliance hotlines?

11Executives and Managers shall Take the Lead in Complying with the Kao Business Conduct Guidelines and shall be Good Role Models for all Employees, and be Fully Responsible for Communicating the Kao Business Conduct Guidelines to their Members.

53

Executives and managers shall take the lead in fulfilling social responsibil it ies . They shall always seek to understand changes in the management environment and listen to voices inside and outside the company to effectively improve the managerial system.


No.It is within the scope of executives' and managers' duties.Executives and managers shall fulfill their duty to enhance awareness of the BCG to all the members they manage. The fact that the BCG is accessible to everyone is important, but that does not make it acceptable for you to forego your responsibility to enhance awareness of the BCG among all your members. You are charged to create an environment in your management area where all decisions are made by taking into consideration the BCG.

Answer

Reference：BCG（Fundamental Rule 11）

54

11Executives and Managers shall Take the Lead in Complying with the Kao Business Conduct Guidelines and shall be Good Role Models for all Employees, and be Fully Responsible for Communicating the Kao Business Conduct Guidelines to their Members.

The channels to receive consultation about compliance issues are not limited to the internal/external compliance hotlines.

First, the employee should bring a workplace concern (concerns regarding human relationship, communication, and compliance issues) directly to his/her superior or the HCD manager or other relevant department (e.g. department in charge of legal and/or compliance).

If direct communications fail to result in a satisfactory outcome, employees are encouraged to use the internal/external compliance hotlines.


No.Executive and managers should listen to employees' concerns and should commit themselves to solving concerns. Executive and managers should consult with the HCD department or other relevant department if they have any concerns or are unsure about appropriate action. Handling the issues properly protects not only employees and companies but also the responsible executives and managers.

Answer

Reference：BCG（Fundamental Rule 11）

Regarding the Revised Kao Business Conduct · 2020-06-16 · 1 Regarding the Revised Kao Business...

Documents

Transcript of Regarding the Revised Kao Business Conduct · 2020-06-16 · 1 Regarding the Revised Kao Business...