Compliance
Sumitomo Warehouse will not only conduct business in compliance with laws and regulations, but also realize fair and appropriate management in accordance with social norms and corporate ethics, increase transparency and fulfill its social responsibility in the future.
Sumitomo Warehouse Group Business Conduct Guidelines
As the basic policy of Sumitomo Warehouse with regard to compliance, we have established the Sumitomo Warehouse Group Business Conduct Guidelines.
Sumitomo Warehouse Corporate Standards of Conduct
Based on Sumitomo Warehouse Group Business Conduct Guidelines, we have established the Sumitomo Warehouse Corporate Standards of Conduct which form the basis of actions when employees perform their duties.
Compliance System
Within Sumitomo Warehouse, the Internal Control Subcommittee, which is an organization under Sustainability Committee chaired by the President, is in charge of matters pertaining to compliance.
The subcommittee drafts rules related to compliance, prepares and distributes compliance manuals, plans and implements education and training related to compliance in coordination with the relevant departments, and also tracks and analyzes compliance risks throughout the Group and implements measure to prevent them.
AEO (Authorized Economic Operator)
AEO is a system in which an operator that has established cargo security management and legal compliance systems is authorized and certified by customs authorities and granted preferential treatment such as alleviation or simplification of customs procedures. Following the terrorist attacks on the United States in 2001, it has been necessary to balance security and smooth operation in international logistics, and the system has been introduced in over 70 countries and regions worldwide.
The Sumitomo Warehouse Group has received authorization and certification under the AEO system as follows, and is strengthening legal compliance efforts in international logistics such as bonded warehouse operations and customs clearing operations.
Acquisition of AEO Authorization and Certification in Japan
| AEO Warehouse Operator |
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|---|---|
| AEO Customs Broker |
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Responses to AEO Systems Overseas
- Sumitomo Warehouse (U.S.A.), Inc. (C-TPAT)
- Sumitomo Warehouse (Europe) GmbH (AEO)
- Sumitomo Warehouse (Singapore) Pte Ltd (STP)
- Union Services (S'pore) Pte Ltd (STP-Plus)
- Rojana Distribution Center Co., Ltd. (AEO)
- Shanghai Sumiso International Logistics Co., Ltd. (GCE)
※The certification names in each country are indicated in parentheses.
Initiatives Aimed at Raising Awareness of Compliance
Preparation and Distribution of the Sumitomo Warehouse Group Compliance Manual
A compliance manual summarizing matters related to the Company’s compliance system including the Sumitomo Warehouse Group Business Conduct Guidelines and the Sumitomo Warehouse Corporate Standards of Conduct, in addition to systems for reporting and consultation related to compliance has been established and the booklet is distributed to employees within the Group. The manual is also prepared in languages such as English, Dutch, Malay, Chinese and Thai, and distributed to employees of overseas subsidiaries to promote understanding.
Implementation of Internal Control Liaison Meetings
Sumitomo Warehouse has established Internal Control Liaison Meetings attended by directors, etc. of the Company and its subsidiaries. Meetings are held for domestic subsidiaries and overseas subsidiaries to provide information and guidance and to exchange opinions on matters related to compliance. Instructors from outside the Company are invited to each of these meetings to conduct legal seminars on legal and compliance themes.
Implementation of Education and Training on Compliance
Instructors from outside the Company are invited to periodically conduct top management seminars for senior executive officers and legal training for management personnel. In addition, legal seminars on different themes are also held as needed for specific departments.
Compliance training (including e-learning) is conducted once per year for all employees including temporary employees. It covers themes that are current at the time such as cyber security, management and collection of receivables, revision of the Civil Code (law of obligations), harassment, fraudulent accounting, prevention of corruption, and foreign economic sanctions and export controls.
In addition, workshops on the Subcontractors Act and the Antimonopoly Act that need to be understood when dealing with many partner companies and suppliers, and education on relevant legal knowledge and procedures required for conducting business in bonded warehouse and operations related to importing and exporting are also periodically carried out in each workplace.
Legal and compliance training is also provided as needed for officers and employees of subsidiaries.
The company newsletter published quarterly also contains articles on compliance in every issue in an effort to provide knowledge and to disseminate and raise awareness of compliance.
Prevention of Legal Violations and Improprieties, and Responses in the Event of Their occurrence
The Audit Department performs internal audits including domestic and overseas subsidiaries to prevent the occurrence of compliance violations, etc.
Furthermore, company rules have been established for prompt reporting and consultation according to the office organization if a problem related to compliance occurs in everyday operations, or if it is found that there is a risk of such occurrence.
When a problem arises, it must be promptly reported to the branch or department overseeing the business location where the problem occurred. Reports and inquiries from partner companies are received by the departments that handle them. In the event of a report or inquiry, the relevant departments such as the General Affairs Department coordinate to determine the facts, identify the causes and take steps to prevent a recurrence. Key issues are reported in Sustainability Committee and the details are shared over the intranet to prevent similar problems arising.
Company rules stipulate that a person who makes a report or an inquiry will not be treated disadvantageously due to making the report or inquiry.
Helpline
The Sumitomo Warehouse Group has established a helpline as a means of making reports and inquiries in case it is difficult to do so through the office organization. Awareness of the hotline is raised throughout the Company by providing information over the intranet and internal newsletters, in addition to preparing cards mentioning the helpline contact details (back: Sumitomo Warehouse Group Business Conduct Guidelines) and distributing them all to officers and all employees. Similar helplines have also been set up in domestic and overseas subsidiaries.