To ensure that internationally accepted standards are adopted our global business, the Company formulated the Dentsu Group Code of Conduct, based on the OECD Guidelines for Multinational Enterprises, published by the Organization for Economic Cooperation and Development.
According to Dentsu’s compliance system, directors and executive officers who discover violations of prevailing laws or who encounter other serious compliance-related issues are required immediately to report their findings to the Board of Directors or the Executive Management Committee. The Audit and Supervisory Committee also must be advised of the circumstances without delay.
If the Audit and Supervisory Committee gives an opinion on the Company’s compliance system, or requires that steps be taken to improve the system, directors and executive officers must respond at once and make the recommended changes.
The compliance department develops rules and manuals to maintain and improve the compliance system as it applies to employees. It conducts training programs, led by the CSR Committee, designed to ensure compliance awareness among employees.
A Compliance Line was set up as the designated contact point for the receipt of reports on inhouse legal violations. The line has an in-house and an external contact point, calls to the latter being handled by a law office. Operational and information management structures are in place to ensure that those seeking consultation or reporting violations are not penalized in any way. In FY2016, Dentsu Inc. and Dentsu Group employees submitted seven reports and proposals (FY2015: 15, FY2014: 10; FY2013: 13). All were dealt with by the Company.
Among the activities held by the Dentsu Head Office in its attempt to prevent illicit behavior and raise the level of employee awareness was the showing of an educational video. In addition, to promote understanding of the importance of compliance issues, a compliance website was set up on the Company intranet, and the Compliance Digest booklet was distributed to all Group companies. Each year, compliance training sessions for new and mid-career hires are held at the Company and Group companies.
The Company and all Group enterprises set up a Basic Policy on the Rejection of Organized Crime Groups and Other Antisocial Forces, thereby articulating their determination to take a firm stand against antisocial forces, as groups and individuals seeking economic profit through violence are known in Japan. Business partners have been asked to take the same action.
In accordance with the Dentsu Group Code of Conduct, which underpins our CSR activities, we have anti-corruption policies to ensure that we conduct business in an honest, fair, and transparent manner.In compliance with bribery regulations in the countries and communities around the world where we do business, Dentsu is proscribed from involvement in corrupt acts designed to enable the Company to obtain unfair profits.
In order to meet our social responsibilities and conduct sound business activities, we shall strive always to cultivate compliance awareness through in-house training.
DAN provides compliance training on the intranet for Group companies outside of Japan, the participation rate of which is up to 90%. As a follow-up, each company also holds its own training sessions and strives to raise employee awareness regarding bribery.
The risk of fraud and other wrongdoing is a threat to the Group’s profitability and reputation. DAN thus established an internal reporting program, called Speak Up!, for reporting any incident of concern or that raises suspicions of wrongdoing in the workplace. Employees can make a report to line managers, HR staff or senior managers, or they can follow internal grievance procedures. Appropriate legal and/or disciplinary action will be taken against perpetrators of fraud and other wrongdoing.
DAN also employs Safecall Limited, an independent specialist that employees can contact anonymously on the phone, by email and through a website, 24 hours a day, 365 days a year, and in a number of languages.