The term "compliance" was previously used to mean "observation of laws and avoidance of illegal conduct." However, recently it has come to describe something more like a sense of corporate ethics. It means more than just the observance of laws, and requires that a company refrain from conduct which, even if not actually in violation of laws, is "prohibited," "inappropriate," or "undesirable" for a company that is a sound and proper member of society.
Sumitomo Metals recognizes "compliance" in this broader sense, and the company as a whole, as well as every official and employee as business professionals, shall conduct management and business activities that conform to laws and to other social norms.
Based on the recognition that compliance is at the core of our business management and is a precondition for the sustained existence of a corporation, we are working to reinforce and carry out compliance activities centered on the Compliance Committee.
Sumitomo Metals has long made legally compliant business practices a foundation of our company's operations, and established methods of ensuring them, including a range of internal rules and an employee training system. The Compliance Committee was established in 2002 in order to further reinforce our compliance system. Since that time, Sumitomo Metals has carried out compliance activities that are centered on the Compliance Committee. The history of compliance at Sumitomo Metals since 1997 is as shown below.
History of our compliance structure 
The Compliance Committee conducts compliance activities not only for the company but also for the entire Sumitomo Metals Group.
Each Group company has also created its own compliance system, including the establishment of internal rules and the conduct of self-audits based on the Anti-Monopoly Law, and the Compliance Committee is working to support and promote these compliance activities by Group companies.
(1) Compliance Manual
The basic rules that all company officials and employees must observe from the perspective of compliance in the conduct of their business have been summarized in the Compliance Manual, which is distributed to, understood by, and followed thoroughly by all employees.
In addition to the Sumitomo Metals' compliance system, the manual also lists and explains compliance items regarding relationships with society, shareholders, investors, the company and its employees, and other stakeholders. Training is also conducted using the manual as teaching material in order to ensure complete compliance.
| Reference | |
 Compliance Manual |
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Overview of the Compliance Manual Rules (PDF)
(2) Compliance Reinforcement Month
Sumitomo Metals has designated the month of October each year to be Compliance Reinforcement Month, and during this month conducts a variety of compliance activities to strengthen compliance awareness. For example, each year all officers and management staff submit Compliance Pledge, and the president's compliance message is distributed throughout the company.
(3) Carrying of Compliance Card
All officers and employees carry the Compliance Card with them and work to improve compliance awareness.
Compliance Card
(4) Compliance training
In order to ensure compliance, Sumitomo Metals uses a variety of opportunities to conduct training related to compliance. Lectures on compliance is given at the training for each level that is conducted for new employees, at the time of promotions and other occasions.Training DVDs have also been created and distributed so that training can be conducted at each works whenever necessary.
E-learning and e-training are also conducted as needed for particular areas such as the Anti-Monopoly Law and security export controls.
 Training DVD |
 Training Session |
Sumitomo Metals has established the Compliance Counseling Service both inside and outside the company to allow direct consultations by company employees with the Compliance Committee regarding compliance issues that cannot be resolved at their offices. Beginning from October 2011, these counseling services were also made available to our suppliers and family members of employees.
Each Group company has also established its own Compliance Counseling Service and Group company employees may consult either with the Sumitomo Metals Compliance Counseling Service or the service provided by each company.
When there is a matter for consultation, the Compliance Committee gives instructions for an investigation of the facts related to the matter and takes the necessary corrective action when the Committee judges that there is a compliance violation.
In order to protect the employees who use this service, internal rules have been created concerning the protection of employee confidentiality and the prohibition of disadvantageous treatment in response to use of the service by employees. These rules are always observed during the course of investigations and other activities.
| Internal Compliance Counseling Service | External Compliance Counseling Service | |
| Details on consultation | Matters related to compliance at Sumitomo Metals or the Sumitomo Metals Group | |
| Method of consultation | In general, actual names should be used. However for matters when actual names cannot be revealed, anonymous consultation is also possible. | In general, actual names should be used. However for matters when actual names cannot be revealed, anonymous consultation is also possible. |
| Protection of consulting party | Confidentiality related to the consulting party shall be protected. The party shall not be subject to any disadvantageous treatment due to the fact that he/she utilized the consultation service. | |
| Means of communication | Post, email, or personal interview | |
| Postal address | Compliance Counseling Service, |
Yuji Maruyama, Attorney-at-Law |
| Email address | cps@sumitomometals.co.jp | cps-smigroup@mbg.nifty.com |
Ever since the investigation of our company’s Stainless Steel Marketing Division by the Japan Fair Trade Commission in 2003, Sumitomo Metals has been improving its system for ensuring complete observance of the Anti-Monopoly Law.
Specifically, the "Rules Related to Restrictions on Contact and Exchange of Information With Competing Companies" ("Guidelines for Exchange of Information Related to Observance of the Anti-Monopoly Law") have been established as internal rules, and in general contact with competitors by the sales departments or other company units is prohibited. In exceptional cases when contact is unavoidable, it is required that records be created and stored.
In order to verify that this system is operating correctly, a self-audit system is used to monitor the compliance conditions. Training related to the Anti-Monopoly Law is also conducted as needed in order to improve the level of understanding regarding the law.
| Reference | |
 Manual for observance of the Anti-Monopoly Law |
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Based on the settlement of a shareholder suit that was reached in March 2010, the Compliance Verification and Proposal Committee company established. This committee, composed of three outside members, provided a proposal in April 2011 regarding the establishment of a corporate philosophy focused on compliance, efforts for complete resolution when improper acts are discovered, and other matters.
Sumitomo Metals will respect the contents of the proposal from this committee and enact specific measures to further improve its level of compliance in the future.
