Compliance Policy
The Rohto Group is recognized as a highly trustworthy company, and we recognize that this trust has supported the company's growth to date. To aim for further growth, we have clearly written out our Code of Conduct so that we can meet the expectations and demands of all stakeholders, including our customers, as a public institution of society, and we use it as a foundation for each employee to comply with laws and regulations and act responsibly.
Compliance Promotion System
Recognizing that promoting compliance is one of the most important management issues, in 2020 we established a Compliance Committee chaired by the Representative Director to comprehensively promote compliance with social norms and strengthen corporate ethics, and have put in place a system in which important compliance matters related to the committee are promptly reported to the Board of Directors.In addition, in March 2023 we launched the Compliance Promotion Department to strengthen our compliance promotion system.
Initiatives to instill compliance awareness
ROHTO Group Compliance Code of Conduct
The Rohto Group has established the "ROHTO Group Compliance Code of Conduct" which summarizes and explains the ethics and values that employees should uphold. This serves as a guideline for how to interact with customers and business partners, and for when employees are unsure of how to proceed in their daily work.
ROHTO Group Compliance Code of Conduct
Compliance Awareness Survey
We regularly conduct employee awareness surveys to understand the current situation and track changes over time to confirm effectiveness and to periodically review compliance standards of conduct.
Training for managers and employees
Compliance training is conducted at each hierarchical level with the aim of instilling a sense of responsibility and value formation based on one's role.
Furthermore, in 2022, we started training programs and tests for all employees to ensure they understand the importance of legal compliance and our company's systems. In fiscal year 2023, we distributed the "ROHTO Group Compliance Code of Conduct" as a booklet to all employees to promote understanding of compliance and to inform them about the consultation and reporting channels. While drug-induced harm education was previously limited to employees in related departments, it is now conducted for all employees as part of compliance training. We will continue to promote understanding throughout the company in the future.
Rohto Group Compliance Code of Conduct Booklet
Strengthening the dissemination of compliance information
We issue a "Compliance Newsletter" to all employees every month to share information on compliance issues, including laws and regulations and harassment, and we also publish a "Compliance Quiz" in our email newsletter every month, providing employees with the opportunity to learn about many case studies. In fiscal 2024, we sent out a total of 48 email newsletters. We also create and distribute original videos every month to help employees solidify compliance knowledge and raise awareness in their daily lives. As managers need to have a higher level of ethics and knowledge, we introduce compliance case studies every week.
Anti-corruption efforts
We aim to realize a truly healthy and progressive society. To that end, we prohibit any involvement in corrupt practices, including bribery, discrimination, harassment, conflicts of interest, insider trading, and money laundering. Furthermore, we conduct business in over 115 countries. When we do business overseas, we must abide by local laws and common sense and conform to the culture and customs of that country. However, we will not engage in practices such as bribery that are considered wrong by international standards. We strive to contribute to the economic, social, and cultural development of each country through our corporate activities.
Rohto Pharmaceutical signed the United Nations Global Compact in 2018. We are now working harder than ever to fulfill our corporate social responsibility, and with regard to anti-corruption, we respect and adhere to Principle 10, which states that "Businesses should work against corruption in all its forms, including extortion and bribery." We also aim to achieve sustainability for society as a whole, and will ask our domestic and overseas suppliers to take this into consideration.
This policy is also applied to the selection of business partners such as suppliers and business partners, and during due diligence, we always check for the presence of any inappropriate gifts or gratuities in accordance with our company guidelines.In addition, even after starting business, we strictly prohibit the acceptance of any inappropriate gifts or gratuities.
To prevent all forms of corruption, including not only monetary bribery but also non-monetary favors, Rohto Pharmaceutical has established a comprehensive internal whistleblowing system (Rohto Group Hotline and Rohto Group Web Hotline). The Rohto Group Hotline ensures that whistleblowers will not suffer any disadvantages, as they can speak directly with an external lawyer by telephone from the outset. The Rohto Group Web Hotline is managed by our Compliance Promotion Department and allows whistleblowers to submit reports via a web form. This ensures ease of reporting, as reports can be submitted 24 hours a day from home or other locations. Furthermore, in the event of an internal whistleblowing incident at a subsidiary or group company, including overseas subsidiaries, the Internal Audit Office promptly gathers the information, thus establishing a group-wide risk management system.
Since July 2023, we have established an external reporting system (Business Partner Hotline) through our Compliance Promotion Department, allowing our business partners, their officers, and employees to consult with us and report any misconduct or violations of laws and regulations by individuals associated with the Rohto Group.
These policies and systems are outlined in ROHTO Group Compliance Code of Conduct and communicated to all employees. Furthermore, as part of the group's internal audits, annual audits are conducted at key subsidiaries to regularly verify the effectiveness of governance and compliance.
United Nations Global Compact
Rohto Group Anti-Corruption Policy and Anti-Bribery Regulations
Anti-corruption data
There were no cases in which employees were dismissed due to corrupt practices such as bribery in fiscal 2024. There were no cases in which legal action was taken due to corrupt practices such as bribery in fiscal 2024, nor were there any costs incurred for settlements, etc.
Tax Transparency
The Rohto Group properly understands and respects the tax laws and regulations, as well as the spirit thereof, of each country and region in which it operates, and fulfills its appropriate tax obligations. We will implement highly transparent and appropriate tax procedures, strive to optimize tax expenses, and contribute to the development of local communities and the improvement of corporate value.
Tax Policy
Political donations
The Rohto Group will not make any political donations in fiscal year 2024.
Internal and External Reporting Systems
Main steps when a report or consultation is made to the reporting hotline
Whistleblowing system
The Rohto Group has established an internal reporting system and an internal reporting hotline with the aim of promptly detecting violations of laws and regulations, internal regulations, human rights violations, and acts contrary to social norms, thereby preventing misconduct and implementing necessary improvements to enhance the soundness of group management.
Our internal reporting system includes an external hotline that connects you to an external lawyer (telephone: Rohto Group Hotline) and an internal hotline that connects you to our Compliance Promotion Department (web: Rohto Group Web Hotline).
From January 2022, the "Rohto Hotline" was expanded to include group companies and renamed the "Rohto Group Hotline." Furthermore, from July 2023, the "Rohto Group Web Hotline" was established as a reporting channel via web form, further strengthening the reporting system. A global hotline with multilingual support has also been set up for employees of overseas group companies. Anonymous consultations and reports are accepted, and in responding, the wishes of the person making the consultation are respected, and fair investigations are conducted under strict confidentiality to resolve the problem. In addition, from the perspective of protecting those making consultations and reporting, retaliatory or other detrimental actions are prohibited by regulations.
Whistleblowing form for Rohto Group personnel only
External reporting system
The Rohto Group has established a compliance consultation and reporting hotline (Business Partner Hotline) so that executives and employees of business partners can consult with and report compliance violations within the Rohto Group. By reporting compliance issues that cannot be grasped or recognized internally through the external reporting hotline, we aim to detect and correct compliance violations at an early stage.
External Reporting Form for Business Partners