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Compliance Training/ Awareness Raising Activities

Asahi Denka carries out the following compliance training/ awareness raising activities:

Keep everyone informed through Compliance Promotion Manager
Compliance training is offered for the compliance promotion manager of each division/ branch office. Contents of training are distributed to all employees through the compliance promotion manager of each division/ branch office.

Compliance Education/ Training Structure
Compliance education/ training structure consists of stratified training, and legal and subject specific training.

Stratified Training	Training Contents	Instructor	Timing
Newly Appointed Directors Training	Compliance in general Legal training for directors and mental attitude	External instructor (lawyer)	July (after directors’ entrance into office)
Newly Appointed Managers Training	Compliance in general Sexual Harassment　Training	Legal and PR Department Human Resources Department	April- May
Assistant Division Chief Level	Compliance in general	Legal and PR Group	June
New Employees	Compliance in general	Legal and PR Group	April

Legal and Subject Specific Training		Frequency	Target	Instructor
Corporation Wide	Regulation on Insider Trading	1/ Year	Directors/ Department Directors	Stock broker
	Antitrust Law	1/ Year	Managers of Sales Division	Legal/ PR Department, Lawyer
	Trade Secret Personal Information Protection	1/ Year	Directors Committee Member	Legal/ PR Department
	Debt Management	1/ Year	Directors of Sales Division	Finance/ Accounting Division
	Product Liability Law	1/ Year	R&D Planning, Production Management, Sales Planning, Purchase & Logistics, Legal/ Public Relations Department	Environmental Protection and Quality Assurance Department
Divisions/ Departments　 Specific	Initiative of Different Divisions	Opportunities: Sales conference, factory directors conference, food conference, R&D conference		Staff divisions
Divisions/ Departments　 Specific	Timely topics on specific regulations are chosen. Examples: Chemical and toxic substance regulations (Chemical Substances Law, PRTR Law, etc.), labor safety and sanitation regulation, export trade control ordinance, intellectual property right, environment related regulations, food safety and labeling law.

Complaiance Education and Training Held in FY2004

Stratified Training

(1) Training for Executives
In July 2004, a lecture, “Compliance Management” was held for executives and related personnel, given by a lawyer who is an external member of Asahi Denka Compliance Promotion Committee.

(2) Training for New Employees, Assistant Managers, and New Management Level Employees
Compliance training sessions were held for new employees in April 2004, and for assistant managers and new management level employees in May.

Legal and Subject Specific Training

(1) Trade Regulation Seminar
In August 2004, a trade regulation seminar was held for executives and department managers of Asahi Denka Co. Ltd. and Asahi Denka Group. Such seminars are held annually.

(2) Antitrust Legislation Seminar
In August 2004, an antitrust legislation seminar was held for executives and department managers of Asahi Denka Co. Ltd. and Asahi Denka Group.

(3) Other
Various seminars and training on specific legislation, such as “Export Trade Control Ordinance” and “Chemical Substances Law (CSCL)” were held at the initiative of different divisions.

Compliance Case Book

As a tool for compliance promotion, the “Compliance Case Book” was published in February 2005. It was distributed to all employees and group companies.

The case book contains specific cases of law violation and misconduct. It is an educational material that complements the “Compliance Action Guideline.” It provides 80 cases to be used as discussion materials in compliance training.

The structure of the case book follows the structure of the “Compliance Action Guideline” published earlier as the main textbook for compliance training.

Approach towards Personal Information Protection Law

In order to comply with the Personal Information Protection Law that was enacted in April 2005, Asahi Denka Co. Ltd. established an information protection committee as a subordinate body of the Compliance Promotion Committee. As for the safety management at the organization level, a Personal Information Protection Policy was established and various corporate regulations related to information protection were revised, such as the Personal Information Protection and Management Policy. Mr. Sakurai the legal and PR Director, and Director and Managing Operating Officer was elected as personal information manager. Personal safety management at the personal level was approached with the promotion of training and increased awareness. Facility safety management and technological safety management have been reinforced through the introduction of encryption software and the strengthening of entrance security checks.

Compliance ： ← Part1 | ← Part2

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