Compliance System

The SCREEN Group has established a CSR Charter / Code of Conduct that all group executives and employees should follow and includes principles of conduct based on our corporate philosophy.
Based on the CSR Charter / Code of Conduct, the SCREEN Group will comply with all applicable laws and regulations, as well as standards of ethics in all relevant countries, and will conduct business activities in a fair and sensible manner. To this end, we have appointed a compliance officer in efforts to raise awareness of compliance and make it fully understood across the entire SCREEN Group. Our Legal & Compliance Department takes the lead in promoting abidance with international rules and each country’s laws and regulations and offering compliance education.
The CSR Committee is chaired by the HD Representative Director, President, Member of the Board and comprises the Chief Officer of Sustainability Promotion, Chief Compliance Officer, CSR officers and CSR department General Managers of the business operating and functional support companies. At meetings, members confirm and share information on the state of compliance efforts at each company.

Compliance Education

Through both classroom work and e-learning, newly graduated employees, mid-career hires, and officers and employees at SCREEN companies worldwide receive education including compliance basics, job-level-specific classes, specialist classes, and classes on SCREEN Group’s CSR Charter / Code of Conduct. Education also includes periodic classes on harassment prevention and on compliance with laws related to unfair competition, anti-corruption, subcontracting, personal information protection, worker dispatching and insider trading.
In the fiscal year ended March 31, 2020, we provided education for employees in Japan on revised laws and new laws, such as those related to civil matters, worker dispatch, fixed-term employment contracts, and workplace harassment prevention. For subsidiaries in China and Taiwan, we provided officers and employees with education on information management covering sales secrets and other matters.

Fiscal Year Ended March, 31 2020: Face-to-Face Education      

Course Name     

Participant No. of Sessions Course Content
Stamp Duty Stamp duty officials 4 Basics and practice of stamp duty
Contract and lease agreement On-site cooperation company 2 Contract and lease agreement
Overseas Assignment Education Employees scheduled for overseas assignment 15 Compliance
Subcontract Act Finance and Accounting Dept. staff 1 Subcontract Act
Technical new employee education  Technical new employees 1 Trade secrets, contracting and worker dispatch
Mid-career recruit education Mid-career recruits 10 Compliance, trade secrets
Harassment Contact Education Harassment Contacts

2

Harassment consultation
Business Basics Course General and management-level employees 2 Basic Knowledge and Practice of Contracts
Training for new employees New employees 2 Legal Basics, Compliance
Training for Newly Qualified Appointments Newly appointed supervisors, assistant managers, managers, senior managers 6 Compliance
Fiscal Year Ended March, 31 2020: SCREEN BUSINESS SCHOOL e-Learning
       Course Name                       Course Aim
Antimonopoly Act With regard to the Antimonopoly Act, develop a proper understanding of specific regulatory content aimed at promoting free and fair trade, as well as develop an understanding of the risks arising from violation of this Act.
Product Liability Act (PL Act) Learn the basics of the PL Act and develop a proper understanding of key issues. Be able to identify product liability-related risks and to take action to reduce such risks of liability for damages through business activities. 
Contract Basics Develop an understanding of how contracts/agreements are essential to business operations and of the significance of entering into them. Also, learn the basic points to keep in mind when, and SCREEN Group process for, concluding agreements and put them to use in your own work duties.
Insider Trading Regulations Develop a basic, proper understanding of insider trading regulations. Reaffirm the structures and rules put in place by the SCREEN Group, and facilitate a greater compliance-focused mindset among each and every employee.
Copyright Act Basics Learn the basics of copyright (e.g., an overview of the Copyright Act, points to remember when performing your work duties, etc.). Furthermore, be able to identify hidden copyright-related risks during day-to-day software development, and develop an understanding of the importance of contracts as a means of mitigating these risks.

NDA Basics, Application, and Related Agreements

Learn the basics of NDAs (e.g., key contractual terms, points to remember when applying, relationship to other types of agreements, etc.).
Basic Transaction Agreements Learn the Basics transaction agreement  (e.g., contract  structure , typical issues, points to remember when applying, etc.).

Act on the Protection of Personal Information

Learn the basics of the Act on the Protection of Personal Information (e.g., what constitutes personal information, context-specific rules, etc.).

Points to Remember when Concluding Agreements with Other Companies

Learn how to carry out business in line with agreements and how to make use of legal affairs tools available in-house.

Equipment Sales Agreements with Chinese Customers

Develop an understanding of key contractual terms, negotiation-related approaches, and other points to remember when dealing with equipment sales agreements with Chinese customers, and be able to mitigate the risks associated with such agreements.

Software Business-Related Points to Remember

Learn essential information pertaining to the implementation of software business, centering on Copyright Act revisions and open-source software-related basics, and be able to mitigate the risks associated with software business.

Whistleblowing System

We have established Internal Reporting Hotline, a whistleblowing system that helps to prevent improprieties through the early detection of harassment and suspected violations of corporate ethics and corporate regulations. Our global whistleblowing system has Hotlines in all SCREEN worldwide regions to accept inquiries from all Group employees, officers and employees of supplier companies. There are also rules in place regarding anonymity and privacy protection, as well as for ensuring that no one will be given unfair treatment for having used the whistleblowing system. This system is operated by our Legal & Compliance Department. We have also established external hotlines operated by law firms. In the fiscal year ended March 31, 2020, we inspected Corporate Ethics Help Line at overseas companies and made rule revisions and other necessary improvements.
Periodic in-house audits are conducted to see how well we are complying with laws and corporate ethics and how well our Hotlines are operating.

Tax Transparency

Our CSR Charter / Code of Conduct clearly stipulates that the SCREEN Group will implement highly transparent management of our businesses through sound and effective corporate governance and that the Group will comply with all applicable laws and regulations, as well as the ethical standards of all relevant countries, and will conduct our business activities in a fair and sensible manner. In accordance with these directives, each Group company is responsible for full compliance with all local tax laws, filing requirements and tax obligations. Moreover, we will not resort to tax planning or use tax havens to evade taxation.

Security Export Control

The SCREEN Group places a high priority on carrying out security export control. The aim is to help preserve international peace and safety by preventing weapons or goods and technologies that could be converted for military use from falling into the hands of governments or terrorists who could threaten world safety. Our Security Export Control Department gathers the latest information on Foreign Exchange and Foreign Trade Act and other related export rules and disseminates this information throughout the Group. It
also confirms that goods and technologies we export correspond to regulations, and it formulates and checks conformity with in-house rules supporting export control processes that are aimed at confirming end users’ identity and their intended use of goods and technologies.
The Group’s business operating companies have been approved by the Director of Osaka Customs as “authorized exporters” under the Authorized Economic Operator (AEO) program. To ensure ongoing compliance with this program, we disseminate information on relevant laws and regulations throughout the Group and conduct periodic legal audits.

Compliance with Competition Laws and Anti-corruption

The SCREEN Group formulated the Guidelines on Preventing Collusive Bidding by Cartels and conducts education for officers and employees on improper activities. The goal is to prevent collusion, monopolies, unfair advantages to one’s own suppliers, and other actions that violate anti-monopoly and fair competition laws, as well as prevent bribes and other such improper acts. In the fiscal year ended March 31, 2020, there were no instances in the SCREEN Group of anticompetitive or antitrust practices or illegal monopolistic activities.

Exclusion of Anti-Social Forces

The SCREEN Group will ban any relationships with anti-social forces, including organized crime groups, which pose a threat to public order and safety of society. We will stand firm against, and reject, unreasonable demands and requests of anti-social forces.
Furthermore, we will not engage in any transactions or relationships of any kind with anti-social forces. We will also demand that our customers and business partners also eliminate any relationships with anti-social forces.

Providing Appropriate Product Information

Each department involved in public relations, legal affairs, and intellectual property verifies product and service information prior to its external release. In this way, we work to ensure fair and accurate information disclosure. In the fiscal year ended March 31, 2020, there were no significant legal violations by any Group company in areas related to the provision of information about or labeling of products and services or marketing. Going forward, we intend to conduct thorough checks of each Group company to continue to prevent infractions.