Establishment of compliance system at a major manufacturing company

The client was a global enterprise that consists of 3 business groups, “Aluminum and metal processing”, “Architectural products” and “Machinery and engineering”, as well as 6 regional headquarters. The project was implemented at the major group companies in the East Asia region.

The client had been working on the enhancement of compliance system at the global level. However, the required details and level of compliance varied by region. The East Asia region, which was an important manufacturing and sales center within the Group, required high level of compliance and region-specific initiatives that respond to the local needs.

Based on the compliance management factors shown below, PFA designed and implemented an approach customized for client needs.

① Operation and support of Compliance Committee

・Establishment of a Compliance Committee with presence of top managements from each group company
・Arrangement of periodical committee meeting (2 or 3 meetings per year)
・The main agenda of the committee include:
－　Reporting the efforts made to date in the group companies regarding compliance and the evaluation for such efforts
－　Proposal and approval for the upcoming tasks

② Preparation of Code of Conduct

・Formulation of the Code of Conduct/Guideline based on the corporate mission, ethics and local laws and regulations, which all the employees are expected to comply with.
・Vocational activities on the Code of Conduct

③ Compliance training

・Basic and advanced trainings for staffs in charge of compliance
・Basic and advanced trainings for middle management
・Training for employees (training on the Code of Conduct)
・Proposal for improvement for developing a continuous training system

④ Assessment of the impact of training

・Analysis of the results of the check test and questionnaire done after the training
・Assessment of the impact based on the analysis results, and proposal for improvement on the future action plan

⑤ Establishment of whistle-blowing system

・Since the contact point for whistle-blowing and counseling was not clearly determined, the project established a single contact point for the whole East Asia region
・Taking necessary measures to inform on and promote the utilization of the whistle-blowing system
・Monitoring of the usage of the whistle-blowing system and proposal for operational improvement

⑥ Improvement of compliance at business partners

・Preparation of a roadmap for developing cooperative relationship with business partners
－　1st phase: Request cooperation for compliance initiatives at the client group companies
－　2nd phase: Inform business partners on a regular basis regarding the latest compliance initiatives at the client group companies
－　3rd phase: Request for a minimum level of compliance efforts on the side of business partners
－　4th phase: Gradually increase the requested level of compliance at business partners
・Implementation of measures envisioned in the roadmap (i.e. requests, publicity, etc.)

・Established knowledge and higher awareness for compliance
・Early detection and management of the breach of compliance through the whistle-blowing system
・Establishment of a PDCA cycle that enables the in-house management of compliance issues
・Raised awareness for compliance at the top management level through the compliance committee