Governance
Prioritizing compliance and carrying out business in a socially fair and appropriate manner
Corporate Governance
Polyplastics maintains a system of corporate governance that is focused on ensuring efficient business operations while improving administrative transparency in order to earn the trust of society and to satisfy its expectations.
Compliance
Compliance Operational Structure
We implement compliance measures from the two perspectives of “Prevention” and “Response” and strives to ensure an effective compliance operation system.
Kuantan Plant Achieves Silver Status in RBA-VAP
In response to the greater needs for CSR by customers, we began conducting voluntary CSR audits through the RBA Validated Assessment Program (VAP) at each plant as part of our responsible sourcing program in FY 2023. The Kuantan plant, which belongs to the group company in Malaysia, underwent an RBA-VAP audit last fiscal year. As a result, the Kuantan plant acquired Silver Status as a Sustainable Plant.
Last fiscal year, we conducted an RBA-VAP audit at the Fuji plant as well in November and improvement measures addressing issues pointed out in the audit are being carried out. The Responsible Business Alliance (RBA) is an alliance of companies promoting sustainable values for workers, the environment, and business across the entire global supply chain and has set forth standards in its Code of Conduct to make sure that the working environment is safe, that workers are treated with respect and dignity, and that business activities are ethically performed in a responsible manner in terms of the environment impact.
Silver Status in Kuantan plant means that the plant appropriately manages all aspects of labor, health and safety, the environment, ethics, and its management system as set forth in the RBA Code of Conduct. We will continue to further promote corporate activities in line with the RBA Code of Conduct with the aim of ensuring that all Group plants, including the Fuji Plant, are sustainable.
Corporate Sustainability Reporting Directive in Europe
In order to comply with the Corporate Sustainability Reporting Directive (hereinafter referred to as the “CSRD”), which was issued in January 2023 and made applicable to companies operating in the EU, a Daicel Group-wide project was launched last fiscal year. For the Group, TOPAS Advanced Polymers GmbH (TAP) in Germany came within the scope of this directive and will henceforth be required to submit reports containing quantitative data and qualitative statements on environmental, social, and governance (ESG) matters (non-financial areas) beginning in FY 2025.
In undertaking Phases 2 and 3 last fiscal year, we produced a roadmap setting forth actions to be taken to ascertain ESG matters (nonfinancial areas) for disclosure as required by the CSRD, conducting a double materiality assessment (corporate and social impact assessment) and a gap analysis, and grasping the matters to be disclosed to prepare a draft of a first-year disclosure report. We will continue to proactively work on disclosing appropriate information on sustainability to all stakeholders.
Responsible Sourcing
Profits from the mining of and trade in tin, tantalum, tungsten, and gold (commonly referred to as 3TG) in the Democratic Republic of Congo (DRC) and other conflict areas (CAHRAs*1) are used to finance armed groups and rebel groups that engage in serious human rights abuses. In addition to environmental destruction, such as the serious contamination of soil and rivers by mine waste, the cobalt mines in the southern part of the DRC have also been identified as a hotbed of child labor.
The Daicel Group, which includes Polyplastics, recognizes OECD Annex II risks*2, including the international concerns mentioned above, as an important management issue and the Group conducts specific surveys on conflict minerals in addition to the CSR procurement Self-Assessment Questionnaire (SAQ).
If conflict minerals (tin, tantalum, tungsten, and gold) or cobalt, natural mica, copper, natural graphite, lithium and nickel which are similarly feared to involve risks such as human rights abuses, are used in production itself or in the production process, we will examine the extent to which they remain in products, regularly survey our raw material suppliers regarding conflict minerals, confirm the results of those surveys, and endeavor not to use those minerals as raw materials in our products.
We also provide and update our CMRT*3 and EMRT*4 information based on results obtained by regularly surveying raw material suppliers.
- *1CAHRAs: conflict-affected and high-risk areas
- *2Annex II risks: Defined by OECD guidance and includes human rights violations, support for armed groups, the collection of protection money and other illegal activities, bribery, the fraudulent misrepresentation of the origin of minerals, and tax evasion.
- *3Conflict Minerals Reporting Template: An international format to facilitate the collection of information on conflict minerals used through the supply chain.
- *4Extended Minerals Reporting Template: A format that further expands the scope of minerals covered by the CMRT; includes cobalt, natural mica, copper, natural graphite, lithium and nickel.
Risk Management
Promotion of Risk Management
We have established a CSR Committee that regularly conducts reviews in order to help us address the diversity of risks that surround our business activities. The committee categorizes risks as either “Business strategy risks” or “Operational risks” and then develops and deploys risk management activities
according to relative handling priority. We will continue to watch for changes in the business environment and social landscape and will work as a group to implement activities and countermeasures which mitigate risk.
Also, in order to improve the effectiveness of these activities and countermeasures, we conduct interviews with our different departments and group companies to check whether the PDCA cycle is being fully implemented and whether there are any operational issues that need to be addressed. Moving forward, we will continue working to
improve our structures and operations even further.
BCP (Business Continuity Plan)
We have formulated basic BCP documents and various manuals for business continuity in anticipation of a Nankai Trough earthquake or an earthquake directly under the Tokyo metropolitan area.
In addition to these measures, the company has created a record of its responses to actual cyber attacks, plant power outages, and other incidents, and is preparing a system to ensure a quick recovery and continuation of business operations in the event of similar events in the future.
Internal Control
We have established the Internal Control Basic Policy to use as a guide for ensuring suitable business management. In addition, our Group companies conduct self-checks each year, and all divisions and Group companies are asked to submit reports that confirm the effectiveness of their internal control. We also regularly conduct internal audits to evaluate the effectiveness of internal control, and we are working together with our parent company, Daicel Corporation, to put in place a global audit system that will further improve the quality of our auditing.
