Basic Policy | Kurita Water Industries

Kurita Group Code of Conduct

The Kurita Group Code of Conduct stipulates the basic actions to be taken by all officers and employees of the Kurita Group. All officers and employees of the Kurita Group vow to understand and comply with this Code of Conduct.

Kurita Group Code of Conduct (PDF: 833KB)

Corporate Governance Policies

You can see Basic Policy on Corporate Governance.

Corporate Governance Policies

Basic Policies for Constructing an Internal Control System

You can view the Basic Policy regarding internal controls .

01. System to ensure that the execution of the duties of Executive Officers and employees conforms with laws, regulations, and the articles of incorporation

The Company and its consolidated subsidiaries (the "Group Companies"), will comply with laws and regulations in accordance with social ethics and have specified actions based on compliance with laws, regulations, and social ethics as a prerequisite for corporate activities to construct transparent and fair relationships with shareholders, customers, employees, local communities, and trade partners at all places in which business activities are conducted. We have also established the Kurita Group Code of Conduct and “Maintain unwavering integrity” as one of our Values that form the foundation of the Kurita Group Philosophy System, with which officers, etc. (collective term for Directors, Executive Officers, Corporate Officers, and other personnel equivalent to them and Directors, members of the Audit & Supervisory Board, and personnel equivalent to them of the Group Companies; the same applies hereinafter) and employees of the Company and the Group Companies should comply, irrespective of differences in language, custom and cultural background, to fully enforce actions based on compliance with laws, regulations and social ethics in our daily business activities. In addition, the Company and the Group Companies will stand up to antisocial forces that potentially pose a threat to social order and safety with a resolute attitude, and work to fight off the unjustified claims of antisocial forces in a determined manner.
The Company sets up the Sustainability Committee, which is chaired by the Executive General Manager of the Sustainability Division, who is a Corporate Officer. In this Committee, the members set out policies and important measures for integrity activities*, and convey them to all employees through the divisions, and a committee, etc. of each Group Company. The responsible Executive Officer or Corporate Officer will regularly report the status of activities and their results to the Board of Directors to continuously raise the compliance level. If the Chairperson of this Committee determines that there is a serious problem or a doubt related to compliance, the Chairperson will immediately report it to the President and Representative Executive Officer and the Chairperson of the Audit Committee, and then formulate and implement remedial actions and preventive measures. The President and Representative Executive Officer and the Chairperson of this Committees will report these events to the Board of Director or the Audit Committee whenever appropriate. *The term "integrity activities" involve activities related to compliance.
The Company establishes the Internal Auditing Department to conduct internal audits on matters such as those related to compliance activities. The Internal Auditing Department is placed under the direct control of the President and Representative Executive Officer in the organizational structure and conducts internal audits based on audit plans approved by the Audit Committee and the President and Representative Executive Officer. The General Manager of Internal Auditing Department shall report audit results to the Audit Committee and the President and Representative Executive Officer periodically or after each audit, depending on the type of audit. Moreover, the General Manager of Internal Auditing Department shall, where there is an emergency or special measures are deemed to be required during audits, immediately report to a member of the Audit Committee, and where necessary, to the President and Representative Executive Officer.
The Company establishes the Operational Regulations for Whistle-Blower Protection Systems as a mechanism for the officers, etc. and employees of the Company and the Group Companies to directly provide information about legally doubtful conducts, etc. In conjunction with these regulations, the Company also establishes the Compliance Counselling Counter. The Company also works to ensure the fairness and transparency of the management of the Company and the Group Companies by regularly reporting the status of the operation of the contact for Public Interest Whistle-Blowing to the Board of Directors.
The Company establishes and operates the "Internal Control Reporting System" in accordance with the Financial Instruments and Exchange Act to ensure the accuracy of the financial reporting of the Company and the Group Companies. Monitoring, advices on improvement, and support for improvement for the operation of the System are implemented, with the Internal Auditing Department as the responsible department. In addition, the Corporate Accounting Department in the Corporate Control and Administration Division shares responsibility for monitoring, recommendations for improvement, and support for improvement related to the "operations process control inside the Company" and the "account settlement and financial reporting process control of consolidated subsidiaries from a company-wide perspective."
In response to the "Corporate Governance Code" set forth in the Securities Listing Regulations of the Tokyo Stock Exchange, the Company establishes policies for corporate governance and strengthens its corporate governance, with the aim of realizing transparent, fair, prompt, and decisive decision-making and more effective management supervision of the Company and the Group Companies.

02. System to store and manage information about the execution of the duties of Executive Officers

Information about the execution of the duties of Executive Officers is stored and managed in documents (including electromagnetic records) by appointing a responsible person in charging of managing it and setting the storage period, etc., in accordance with the Document Regulations and the Confidential Information Management Regulations. The Directors may inspect these documents, etc. when necessary.

03. Regulations and other systems for managing the risk of loss

Risks pertaining to the Company and the Group Companies are monitored and risk management is promoted by the Executive General Manager of the Corporate Control and Administration Division. The Executive General Manager of the Corporate Control and Administration Division regularly analyzes and assesses the risks of the Company and the Group Companies, and makes efforts to prevent the occurrence of risks through continuous monitoring. If a risk that may have a material impact on management becomes apparent, the Executive General Manager of the Corporate Control and Administration Division will appoint a responsible official, draw up a system to address the risk, and immediately issue a command after gaining the approval of the President and Representative Executive Officer. The responsible official will immediately implement countermeasures and report the impact of the risk, the status of correcting the risk, and the measures for preventing the risk to the President and Representative Executive Officer, the Executive General Manager of the Corporate Control and Administration Division, and the Board of Directors or the Audit Committee.
In regards to serious risks, the Chairperson of the Sustainability Committee will be the responsible official for risks related to compliance, and the Chairperson of the Headquarters Health and Safety Committee will be the responsible official for risks related to health, safety, and occupational accidents. Risks that are directly related to daily business activities are addressed by the Executive General Managers of the divisions, who acts as the responsible official. Other day-to-day risks related to quality, the environment, information security, and export regulations, etc. are addressed by their respective departments.
The Executive General Manager of the Corporate Control and Administration Division, the Chairpersons of the Committees, and the Executive General Managers of the divisions regularly report the status of activities to promote risk management and integrity to the Board of Directors.
The status of the implementation of risk management and improvements is monitored, with the Internal Auditing Department acting as the responsible department.

04. System to ensure the efficient execution of duties by the Executive Officers

The Company will improve the efficiency of the execution of duties of the Executive Officers based on the following management control system and mechanism.

The Board of Directors specifies the operations delegated to the Executive Officers and the responsible officials of organizations with the rank equivalent to or higher than Executive General Manager of a division.
The Board of Directors determines policies for formulating a corporate vision, a medium-term management plan, and a business plan for a single fiscal year, and the Executive Officers formulate a business plan for a single fiscal year in accordance with the said policies and set out the targets, policies, and focused measures for each organization. The Board of Directors receives reports from the Executive Officers on monthly and quarterly business performance in relation to the consolidated and non-consolidated targets of the Company and the business departments and supervises the performance.
The Board of Directors entrusts the Executive Officers to make decisions on operational execution excluding matters to be resolved by the Board of Directors. In addition, the final decision application system is set up, in line with the Executive Committee and the Final Decision and Examination Regulations, as a system to complement the decision-making.
The Executive Committee consists of the President and Representative Executive Officer and Executive Officers and Corporate Officers appointed by the President and Representative Executive Officer. The committee meets twice a month in principle, and on a temporary basis when necessary. In the Executive Committee, the members make decisions related to the management of the Company and the Group Companies, conduct a monthly and quarterly check of whether targets have been achieved and the status of implementation of policies and measures, and give each Executive Officer and Corporate Officer instructions to correct deviations. The members of the Audit Committee may attend the Executive Committee.
The decision to establish, revise, or abolish the Final Decision and Examination Regulations is made by the Board of Directors. For the Executive Officers and Corporate Officers to conduct their duties more efficiently, internal regulations conforming to the Final Decision and Examination Regulations are established and implemented.

05. System to ensure the accuracy of operations in a corporate group consisting of the Company and its subsidiaries

The Company and Group Companies perform operations appropriately by the following systems and the frameworks that are in place.

The Company and Group Companies set a medium-term management plan and a business plan for a single fiscal year based on a unified outline for formulating plans.
The overall management of Group Companies is controlled by the Corporate Control and Administration Division. In addition, an Executive Officer, Corporate Officer, and department of the Company in charge of each Group Company are appointed to regularly determine the status of the business performance achieved and the status of risk management based on the medium-term management plan and the business plan for a single fiscal year, and to provide the Group Companies with guidance.
In principle, a Board of Directors is set up in each Group Company. In addition, the Company or Group Companies, in principle, dispatch a (non-standing) director and (non-standing) member of the Audit & Supervisory Board to monitor the management of the Board of Directors, business performance, settlement of accounts, and risks. If a decision needs to be made as the Group Companies, the decision is made in accordance with "7. Matters related to subsidiaries and associates in Japan and overseas," an appendix 1 of the Final Decision and Examination Regulations of the Company.
In regards to the Group Companies' efforts related to integrity, the Sustainability Committee of the Company sets out policies and priority measures, and a committee, etc. of each Group Company formulates and implements specific measures. In addition, the system for ensuring the accuracy of the financial reporting by the Group is considered and established as part of the approaches stated in Article 1, Paragraph 5.
The Group Companies report the status of their management, sales activities, manufacturing, and risk management, etc. to the Company regularly, such as on a monthly or quarterly basis.

06. Matters related to an employee assigned to assist the Audit Committee in fulfilling its duties, matters related to the independence of the employee from the Executive Officers, and matters related to ensuring the effectiveness of instructions issued to the employee

The Secretariat to the Audit Committee is set up as an organization that assists the Audit Committee in fulfilling its duties, and an employee, etc. is appointed as its full-time staff member. The Audit Committee may instruct a certain employee, etc. who belongs to the Internal Auditing Department to assist the Committee.
The employee, etc. who assists the Audit Committee in fulfilling its duties provides assistance independent of the Executive Officers. In addition, the opinions of the members of the Audit Committee are respected regarding personnel changes and evaluations, etc. of the employee, etc.
The employee, etc. who assists the Audit Committee in fulfilling its duties may regularly attend places where opinions are exchanged between the President and Representative Executive Officer and the accounting auditor within the company of a member of the Audit Committee.

07. System for reporting to the Audit Committee

In order to regularly confirm that the Executive Officers, Corporate Officers, and employees of the Company perform operations appropriately, the members of the Audit Committee may attend the Executive Committee and the Sustainability Committee, etc.
The members of the Audit Committee selected by the Audit Committee (hereinafter, the "selected members of the Audit Committee") may inspect documents, etc. necessary for their auditing work at any time, irrespective of the provisions of the Document Regulations, the Confidential Information Management Regulations, and other regulations.
The Executive Officers and Corporate Officers of the Company report important matters related to the execution of duties to the Audit Committee or the members of the Audit Committee whenever appropriate through the Board of Directors meetings and other important meetings.
The officers, etc. and employees of the Company and the Group Companies immediately report matters which may cause significant damage to the operations or financial standing of the Group, matters which are important for internal audits and risk management, matters related to a grave breach of laws, regulations, or the articles of incorporation, and other matters which are important for complying with corporate ethics, laws, and regulations, to the respective departments in charge within the Company. The departments in charge report the details of the reported matter to the Audit Committee or a member of the Audit Committee.
The selected members of the Audit Committee may request officers, etc. and employees of the Company and the Group Companies to report matters related to the execution of their duties and operations, and those who were requested to do so shall immediately submit the report. The selected members of the Audit Committee may also request the accounting auditor to report the status of accounting audits and other necessary matters, and the accounting auditor makes a report related to accounting as needed.
The Company prohibits those who made a report to a department in charge, the Audit Committee or the members of the Audit Committee in accordance with the provisions of the above paragraph (4) from being treated unfavorably on the grounds of making a report, and makes this fact fully known to officers, etc. and employees of the Company and Group Companies.

08. Other systems to ensure the effective auditing of the Audit Committee

The Audit Committee and the President and Representative Executive Officer exchange opinions regularly. Where the Audit Committee has requested an exchange of opinions, the Executive Officers and other requested personnel provide full cooperation.
The Audit Committee establishes standards for appointing, dismissing, and refusing to reappoint the accounting auditor, and nominates a candidate for the accounting auditor. The Company and the Group Companies secure sufficient amount of time for the accounting auditor to conduct a high-quality audit. The Audit Committee, the Internal Auditing Department, and the accounting auditor promote a cooperation by mutually checking each other’s audit plans and sharing their concerns.
The Audit Committee holds discussions and exchange opinions with the Internal Auditing Department and the accounting auditor when necessary.
The Audit Committee allocates expenses that are deemed necessary for the execution of duties in advance. However, the Audit Committee may charge the Company postmortem for expenses it spent on urgent or provisional matters.

Kurita Group BCM Policy (Business Continuity Management)

*Business Continuity Management

01. Purpose of this Policy

This Policy sets forth the fundamental principle for handling emergencies which pose a risk to the continuation of the business of Kurita Water Industries Ltd. (hereinafter referred to as “KWI”) and its consolidated subsidiaries (“KWI” and its consolidated subsidiaries shall be hereinafter collectively referred to as the “Kurita Group”). Such emergencies may arise due to a large-scale earthquake, wind and flood damage, or pandemic, conflict, cyberattack, security incident, etc. In this way, this Policy aims to enable the officers and employees of the Kurita Group to properly handle such emergencies.

02. Basic Policy

We would like to introduce the basic concept of our initiative.

A. Highest Priority on Ensuring the Safety of Humans

Kurita Group will place the highest priority on ensuring the peace of mind and safety of the officers and employees as well as their family members.

B. Early Restoration of Business

Kurita Group will endeavor to quickly restore the operations at the company's own facilities, completed properties, and properties under construction, etc.. In this way, it will make efforts to supply products and services in a stable manner and to support customers’ recovery efforts.

C. Community Support

While making efforts to prevent secondary disasters at its own sites, the Kurita Group will support the reconstruction of the local community.

Kurita Group Human Rights Policy

The Kurita Group operates businesses globally in the fields of water and the environment in accordance with its corporate philosophy, "Study the properties of water, master them, and we will create an environment in which nature and humanity are in harmony."Our business activities are built on relationships with many related parties and may have various impacts on their human rights. Human rights are fundamental rights that are granted to every human being. As a member of society, the Kurita Group will understand well its duty to protect the human rights of every person affected by its business activities and fulfill its responsibility to respect human rights. This Human Rights Policy complements the Kurita Group Corporate Philosophy and the Kurita Group Code of Conduct. We aim to contribute to the sustainable growth of society by continuing with management and business activities that respect human rights through the implementation of this policy.
This policy applies to all directors, members of the audit & supervisory board, executive officers, corporate officers, personnel equivalent to them (hereinafter referred to as, " officers, etc. ") and employees of Kurita Water Industries Ltd. and its consolidated subsidiaries. Moreover, the Kurita Group will encourage its business partners and other related parties on which it can have an influence to implement this policy.

The Kurita Group will respect the human rights as set out in the International Bill of Human Rights and the fundamental rights and principles as set out in the Declaration on Fundamental Principles and Rights at Work. In addition, we will promote efforts to respect human rights in accordance with the Guiding Principles on Business and Human Rights stipulated by the UN.
The Kurita Group will comply with applicable laws and regulations of each country and region in which it performs its business activities. In the case of any conflict between the internationally recognized human rights and any law, regulation or rule of any country or region, the Kurita Group will search for a way to respect the principles of internationally recognized human rights.
The Kurita Group will establish a mechanism for human rights due diligence to identify any adverse human rights impacts and seek to prevent or mitigate such impact.
In the event of any adverse human rights impacts or its revealed involvement in such adverse human rights impacts, the Kurita Group will endeavor to provide a remedy to those affected through proper proceedings.
The Kurita Group will publicize this policy. Furthermore, it will provide appropriate education and training to ensure the effectiveness of this policy.
The Kurita Group will consult with the relevant stakeholders on responses regarding potential and actual impacts on human rights.
The Kurita Group will report the progress of its efforts to respect human rights in its sustainability reports and on its website.

Kurita Group Anti-Bribery Policy

01. Objectives of this Policy

This Policy sets out the basic matters concerning anti-bribery at Kurita Water Industries Ltd. (hereinafter referred to as "Kurita") and its consolidated subsidiaries (hereinafter referred to as "Group Companies"; Kurita and the Group Companies are collectively referred to as the "Kurita Group"), as well as the matters that must be observed by Kurita Group's officers, etc. (directors, Audit, executive officers, Executive Officer and other equivalent persons) and employees (hereinafter referred to as "Officers, etc. and Employees"), with the aim of preventing acts of bribery, etc., acts that may constitute bribery, etc., or acts that may be misunderstood as bribery, etc., and promoting Fairness business activities within the Kurita Group.

02. Policies

A. General Provisions

In accordance with this Policy, the Kurita Group prohibits acts of bribery, etc. of public officials, etc. that are performed by the Officers and Employees of the Group and establishes anti-bribery regulations, etc. in order to define structures and rules that are needed to prevent bribery, etc.
In accordance with this Policy, the anti-bribery regulations, etc. prescribed in (1) above shall be in compliance with laws, rules and regulations and rules that will apply to the Kurita Group in each country or region where the Group operates its business and standards permitted by Local laws and Regulations.
The Officers and Employees shall observe this Policy and anti-bribery regulations, etc. and prevent bribery, etc.
)When any officer or employee of a Group company has paid a bribe, etc. to a public official, etc., has received a demand to pay a bribe, etc. or has conducted an act that may be suspected of being bribery, etc., the relevant Group company shall immediately report to KWI.

B. Definitions

1. Public officials, etc.

Public officials, etc. are persons falling under any of the following items, whether they are in or outside the country.

Officers and employees of the country's national or local government (hereinafter collectively, "Governments, etc.");
Officers and employees of government agencies over which the relevant government, etc. has authority or control; Note that government agencies include national (public) enterprises owned by national governments (public entities) and national (public) enterprises operated by national governments (public entities) as well as private enterprises over which Governments, etc. are deemed to have practical authority or control;
Officers and employees of political parties;
Officers and employees of international organizations;
Officers and employees of an organization which carries out administrative affairs based on delegation from a government, etc. or an international organization;
A Diet member, local assemblyman or chief of a local government (including candidates for public office); or
Officers and employees prescribed in (i) to (vi) above include spouses, children, parents, siblings or any other family members of said officers and employees.

2. Corrupt intent

Corrupt intent means the intention to wrongfully influence public officials, etc. in the performance of their duties for the purpose of obtaining transactions in business activities or favorable treatment. In concrete terms, corrupt intent includes the following cases: Specific examples are shown in the Group Anti-Bribery Guidelines.

3. Bribery, etc.

Bribery, etc. shall include an act of giving bribe to public officials, etc., an act of offering to pay a bribe to public officials, etc. or an act of promising to pay a bribe to public officials, etc., with corrupt intent through the following acts or by pretending to perform the following acts, and also include the case where an Officer or Employee personally bears the relevant expenses. Specific examples are shown in the Group Anti-Bribery Guidelines.

4. Agents, etc.

Agents, etc. mean legal entities or individuals who provide the Kurita Group with information or services, business transaction, representation or meditation by acting as agent, mediator, deputy, consultant or distributor, regardless of their names.

C. Prohibition of bribery, etc.

Officers and Employees may not pay bribes, etc. to public officials, etc., directly or through a third party (including agents, etc.), and may not conduct acts that may be misunderstood as bribery, etc.
In the event that a public official, etc. demands a bribe, etc., the relevant Officer or Employee shall firmly refuse such demand.
If an Officer or Employee faces a demand for a bribe, etc. from a public official, etc. and is compelled to pay the bribe, etc. because, without the Officer's or Employee's immediate compliance with the demand, the life, body, etc. of the Officer or Employee or of a third party will be in imminent danger, then the Officer or Employee may comply with the demand in order to avoid the danger; the Officer or the Employee may comply with such demand in order to avert present danger; provided, however, that the Officer or the Employee shall record the situation and report to the Chief Compliance Officer prescribed in the anti-bribery regulations, etc. immediately after the dangerous situation is over in accordance with the provisions of the Group Anti-Bribery Guidelines.

D. Advance approval procedures

An Officer or an Employee may provide benefits, etc. to, bear expenses for, or provide donations, etc. to a public official, etc. only when the Officer or the Employee obtains advance approval in writing from the Chief Compliance Officer as prescribed in the anti-bribery regulations, etc. The methods for recording and reporting are established in the Group Anti-Bribery Guidelines.

E. Provision of entertainment, gifts, etc. from business partners

Officers and Employees may not receive the provision of entertainment, gifts, benefits or other economic benefits from suppliers, subcontractors or other business partners beyond the scope permitted by Local laws and Regulations.

F. Education and training

The Kurita Group will establish and implement a system for regularly providing Compliance education and training on the prevention of bribery, etc., of public officials, etc.

G. Regular review and continuous improvement of anti-bribery systems

In order to prevent bribery of public officials, etc., the Kurita Group will regularly Audit its bribery prevention system through Audit by the Internal Audit Department or voluntary inspections, etc., and will implement continuous improvements as necessary.

03. Confirmation of status and review of the policy

Kurita Water Industries will continuously monitor the status of efforts to prevent bribery, etc. within the Kurita Group in light of this Policy.
Kurita Water Industries will review this Policy annually and as necessary, taking into account legal and regulatory trends related to this Policy and the status of efforts to prevent bribery, etc. within the Kurita Group.

04. Changes, etc. to this policy

The department responsible for enforcing this Policy shall be the Ethics & Integrity Department of the Sustainability Corporate Strategy Division of KWI.
Any revision or abolition of this policy shall be in accordance with Kurita Water Industries' Management Regulations on Various Rules, etc.

A. Supplemental provision

This Policy shall be established and take effect on March 1, 2017.
This Policy shall be revised and take effect on April 1, 2025.

Kurita Group Antitrust Policy

01. Objectives of this Policy

This policy aims to prevent acts that violate or may violate the Antitrust Laws or acts that may be misunderstood as violation of the Antitrust Laws and to promote fair and free competition by setting forth the following matters:

Basic matters related to compliance with the Antitrust Laws, competition laws , antimonopoly laws and other similar laws and regulations, etc. of each country or region (hereinafter, the "Antitrust Laws") by Kurita Water Industries Ltd. (hereinafter, "KWI") and its consolidated subsidiaries (hereinafter, "Group Companies;" KWI and Group Companies are hereinafter collectively referred to as the "Kurita Group"); and
Matters to be observed by the officers and employees of the Kurita Group (the directors, members of the audit & supervisory board, executive officers, corporate officers, personnel equivalent to them of the Kurita Group) are hereinafter referred to as the "Officers, etc." the employees of the Kurita Group are hereinafter referred to as the "Employees" and the officers and employees of the Kurita Group are hereinafter collectively referred to as the "Officers, etc. / Employees" ).

02. General Provisions

In accordance with the Kurita Group Antitrust Policy (hereinafter, this "Policy"), the Kurita Group shall prohibit any act of the Officers, etc. / Employees that violates the Antitrust Laws, construct necessary structures to comply with the Antitrust Laws and establish regulations setting forth the rules and other matters for compliance (hereinafter, the "Regulations for Compliance with the Antitrust Laws").
The Regulations for Compliance with Antitrust Laws shall be in compliance with the provisions of this Policy on violating acts as well as applicable laws and regulations, etc. of each country or region where each company of the Kurita Group operates its business (hereinafter collectively, the "Local Laws and Regulations").
The Officers, etc. / Employees shall observe this Policy and shall not violate the Antitrust Laws. In addition, they shall strive to prevent any violation of the Antitrust Laws.
The Representative Director of KWI or the Chief Compliance Officer appointed by the Representative Director shall oversee the activities of the Kurita Group intended for compliance with the Antitrust Laws.
Any Employee who has any question as to the Antitrust Laws and this Policy in performing his/her duties shall consult with the Compliance Officer stipulated in the Regulations for Compliance with Antitrust Laws (hereinafter, the "Compliance Officer") or the Ethics & Integrity Department of the Sustainability Division of KWI for appropriate instructions.

03. Rules on acts that violate Antitrust Laws and contact with competitors

None of the Officers, etc. / Employees shall engage in any act that falls under any of the items described below. Examples of the main acts and the rules on contact with competitors are as shown in the Group Antitrust Guidelines.

Acts that restrict competition with competitors
Acts that restrict competition with distributors (e.g., stores and retailers) or suppliers
Any act that abuses market-dominant positions; or
Any other act that is regulated by the Local Laws and Regulations.

04. Whistle-blowing

Any Employee who himself/herself has committed any violation of the Antitrust Laws or becomes aware of any violation committed by another person shall consult with and notify the Compliance Manager or the whistle-blowing office of each Group Company or KWI.
Group Companies shall immediately report to KWI if they become aware of the fact that any of the Officers, etc. / Employees has violated the Antitrust Laws or the fact that any of the Officers, etc. / Employees has been asked to commit any act that violates the Antitrust Laws.

05. Response to on-site inspection by authorities in charge of the Antitrust Laws

If any authority in charge of the Antitrust Laws conducts an on-site inspection of the Kurita Group, the Officers, etc. / Employees involved in the on-site inspection shall fully cooperate with the authority in charge of the Antitrust Laws in the inspection.
Actions to be taken by and prohibitions applicable to the Officers, etc. / Employees involved in onsite inspections shall be separately stipulated.

06. Education and training

The Kurita Group shall develop and implement systems for providing compliance education and training concerning the observance of the Antitrust Laws on a regular basis.

07. Periodic review and improvement of systems for compliance with the Antitrust Laws

In order to comply with the Antitrust Laws, the Kurita Group shall periodically confirm the situation of compliance with the Antitrust Laws through such means as self-inspection, inspections by the legal department or audits by the internal audit department and make improvements as necessary if any problem is identified.
The Officers, etc. / Employees shall cooperate with the Kurita Group in its audits relating to the Antitrust Laws or inspections relating to violation of the Antitrust Laws.

08. Department in charge

The department responsible for enforcing this Policy shall be the Ethics & Integrity Department of the Sustainability Corporate Strategy Division of KWI.

09. Changes, etc. to this policy

KWI shall amend or abolish this Policy based on the Management Regulations for Policies and Regulations of KWI in light of trends in laws and regulations related to this Policy and the operation of this Policy within the Kurita Group.

A. Supplemental provision

This Policy shall be established and enforced on November 1, 2017.
This Policy shall be revised and take effect on April 1, 2025.