The HOYA Group has established the Headquarters Compliance Group under the HOYA Group Chief Compliance Officer (CCO), and appointed a Compliance Officer in each business division. In addition, the Headquarters Compliance Group operates a hotline for receiving whistleblowing complaints (HOYA Help Line). However, the Audit Committee is directly in charge of whistleblowing complaints related to Executive Officers and the CCO, who constitute the upper organization of the Compliance Group, and the Audit Committee Office serves as the point of contact for receiving such complaints. The content of and responses to whistleblowing complaints made to the HOYA Help Line are reported by the CCO to the Audit Committee on a regular basis. Of note, any unfair treatment of whistleblowers and persons seeking advice (including any retaliatory measures such as dismissal, salary reduction, personnel transfer and harassment) is prohibited.
As part of our internal control systems, the HOYA Group established the HOYA Help Line in 2003 as a whistleblowing and consultation system for the Group. This is a framework that protects whistleblowers when there have been violations of laws, regulations, or the HOYA Code of Conduct so that problems can be known at an early stage and smoothly communicated to top management in an aim to ensure the soundness of the entire Group through quick and appropriate responses to such issues. Information on whistleblowing complaints is also reported to the Audit Committee on a quarterly basis.
We are creating an environment in which advice can be sought easily, including establishing an external point of contact for consultation in each country, accepting whistleblowing complaints and consultation requests 24 hours a day on the Web in multiple languages, making consultation available in the local language, and allowing anonymity of whistleblowers. Having established rules on the operation of the HOYA Help Line in compliance with laws and regulations, we protect whistleblowers by prohibiting any acts that constitute the unfair treatment of whistleblowers and respond to whistleblowing complaints by giving consideration to the confidentiality of information to ensure their anonymity.
In fiscal 2021, there were 180 whistleblowing complaints made to the HOYA Help Line, of which 48% were related to the workplace environment and 30% were related to HOYA’s system.
In fiscal 2021, there were no whistleblowing incidents inflicting a serious impact on HOYA’s businesses.
| FY2017 | FY2018 | FY2019 | FY2020 | FY2021 | |
|---|---|---|---|---|---|
| Number of whistleblowing incidents | 111 | 105 | 146 | 135 | 180 |
| Percentage of employees＊ | 0.30% | 0.27% | 0.38% | 0.35% | 0.49% |
* Ratio of whistleblowers to the total number of employees in the country where the whistleblowing and consultation system has been introduced
For our business partners outside the HOYA Group, we have established a point of contact for making inquiries and reports in respect of the HOYA Supplier Code of Conduct. We also investigate and respond to incidents in an appropriate manner in consideration of the protection of the informer and the confidentiality of information.
Point of contact for inquiries and reports related to the HOYA Supplier Code of Conduct:
supplierconduct@hoya.com
HOYA believes that if each and every employee acts fairly with high ethical standards in good faith, not to mention complying with laws and regulations, it will translate into “stakeholders’ trust.” Based on such a view, in 1997 we established the HOYA Code of Conduct, which clearly defines the standards of conduct for each and every employee. We have since repeatedly revised the Code while reflecting the enactment of new laws and regulations and the amendment and abolition of existing ones, as well as changes in society. Also, we check the behavioral guidelines in workplace activities and utilize the Code to raise employees’ awareness as our basic policy for compliance.
Having translated the Code into 27 languages in consideration of the circumstances of HOYA, which operates businesses on a global scale, we are making the Code thoroughly known within the Group by such means as making employees do a read through in the group to which they belong once a year and conducting online education and verification tests. In fiscal 2021, the participation rate in online education and verification tests targeted at all employees in the HOYA Group was 98%.
We have established the HOYA Group Policies and Guidelines for Measures to Prevent Harassment, which set forth measures and guidelines to prevent harassment, protect the dignity of employees as an individual and prevent workplace disorder and any obstacles to work. Based on the Guidelines as well as laws and regulations in each country, we conduct education and training on harassment prevention measures targeting all employees of the HOYA Group. For managers in Japan, we conduct training on manager-oriented harassment prevention measures. In fiscal 2021, the participation rate in online training and verification tests in Japan (rank-and-file employees and managers) was 97%.
Furthermore, we conduct initiatives to instill and ingrain compliance on an ongoing basis, such as posting information via the intranet and on bulletin boards, etc., and creating awareness-raising pamphlets and posters. From time to time, we post self-check tests (Q&A) on noncompliance incidents that are likely to occur in familiar situations as well as contents for understanding the essence of compliance through in-house case studies via the intranet and on bulletin boards, etc., so that employees can check compliance again when given the opportunity to do so and thereby gain a higher level of awareness.