Compliance Promotion

Our Basic Policy

The Asahi Group established the Asahi Group Code of Conduct in January 2019 as a means of achieving the Asahi Group Philosophy (AGP), which applies across the Group. In September 2023, to further the penetration of the Code of Conduct throughout the Group, the Asahi Group Code of Conduct was refreshed and localized in 18 languages. It is now available in 18 languages and accessible to officers and employees of all Group companies, including those overseas.

We understand compliance to mean acting in a way that society expects a corporation to act. This includes observing laws and public regulations, company regulations, and other rules in addition to social norms and the like, or in other words, never betraying the relationship of trust with stakeholders. As such, the Asahi Group Code of Conduct defines the specific actions that all officers and employees should take, and by making all personnel fully aware of the Code of Conduct we are working to ensure that they act with compliance as their top priority.

The Board of Directors is responsible for monitoring compliance with the Code of Conduct. The establishment and/or revision (excluding minor changes) of the Code of Conduct shall be resolved and determined by the Board of Directors. In order to maintain a high level of compliance initiatives, we will continue to evaluate and verify the effectiveness of the Code of Conduct and other initiatives regularly and make improvements as necessary.

The Asahi Group Code of Conduct

Compliance Promotion Systems

The Asahi Group established the Asahi Group Ethics/Compliance Policies to promote compliance management. Based on the Policies, we clarify our internal system and operation and promote fair and highly transparent business activities founded on compliance in the broad sense of the term, going beyond the observance of laws and regulations.

The Asahi Group established its Compliance Committee as the highest-order organ to deliberate on compliance. The Committee consists of directors, the head of Legal Section, and other persons of Asahi Group Holdings appointed separately by the Committee. It monitors and works to improve awareness of the Asahi Group Code of Conduct and operation of the Clean Line System (whistle-blowing system) to raise the efficacy of compliance promotion activities.

Furthermore, the chief executives of all of Asahi Group's operating companies are responsible for observing and promoting compliance with the Asahi Group Code of Conduct, while the legal departments of the Group’s operating companies in both Japan and overseas cooperate with one another to structure the Group’s compliance promotion system.

Efforts to Prevent Corruption

In response to tightening restrictions on bribery^※ in countries around the world, the Asahi Group established the Asahi Group Anti-Bribery Principles, which applies to all of the Group’s officers and employees, and is making Group-wide efforts to build a system to prevent corruption.

The Asahi Group Anti-Bribery Principles prohibits such acts, including the direct and indirect provision or receipt of bribery and the provision of facility payments. We require all of Asahi Group companies’ business partners and intermediaries including legal agents to adhere to the Principles, prohibit acts of corruption and ensure their full awareness. In cases of acquisitions, mergers, joint ventures, and other similar arrangements, we will conduct an assessment of the counterparty in advance in accordance with the risk levels of corruption.

In addition to conducting regular self-inspections on the prevention of corruption, we also review the Principles and corresponding procedures on a regular basis and make revisions and improvements as required.

For businesses with high risk of corruption, we have also established guidelines in order to prevent acts of corruption, and we are making our personnel fully aware of the guidelines.

To educate our employees on this issue, we conduct training on the prevention of corruption.

The Board of Directors is responsible for monitoring compliance with the Asahi Group Anti-Bribery Principles, while the Compliance Committee oversees compliance with the Asahi Group Code of Conduct, which includes stipulations on the prevention of such corrupt acts as bribing public officials, providing entertainment or gifts, making inappropriate donations, associating with organized crime elements, or being involved in money laundering. The Compliance Committee reports its findings to the Board of Directors.

• The terms, “Bribe-giving”, “Bribe-taking” and “Bribery” used in the Asahi Group Anti-Bribery Principles are defined as follows:

• "Bribe-giving" means providing, proposing, or promising monetary or other benefits aiming to cause an act or omission by any party in his official capacity such that another would receive an improper interest in connection with business.
• "bribe-taking" means receiving, requesting or being promised to receive monetary or other benefits of personal interest or interest of a third party with the aim to cause an act or omission by any party in his official capacity such that another would receive an improper advantage in connection with business.
• "Bribery" means Bribe-giving and Bribe-taking.

Violations of the Asahi Group Anti-Bribery Principles within the Asahi Group in 2023

The Asahi Group Anti-Bribery Principles

Implementation of Compliance Training

With the aim of enhancing the level of compliance, the Asahi Group develops and conducts group-wide training and awareness activities, such as the Asahi Group Code of Conduct carried out under the leadership of the head office, and implementation of ethics and compliance training with optimized content and method tailored for group companies.

Compliance training conducted in 2023

In September 2023, e-learning course on the Asahi Group Code of Conduct was conducted for all employees of the Asahi Group‘s major operating companies, including those overseas. Each company also made efforts to explain and promote the Asahi Group Code of Conduct during new employee induction training.

Monitoring System

Internal Audit

Asahi Group Holdings checks compliance with legal and company rules in internal audits conducted by our Internal Audit Section every year.

Compliance Survey

The Asahi Group conducts a global compliance survey of major Group companies once a year. The aim is to verify the level of awareness of the Asahi Group Code of Conduct and identify the legal risks present, then apply the findings to making improvements.

Whistleblowing System

In order to detect compliance issues and human rights violations in the early stages and to rectify any issues and provide remedy to the affected parties before the issues evolve, the Asahi Group has adopted a group-wide whistleblowing system called “Speak Up”. This system allows all stakeholders of the Asahi Group, including employees, business partners and communities, to report any suspected misconduct in relation to the Asahi Group through the channel below. Suspected misconduct includes breaches of the Asahi Group Code of Conduct or the law and human rights violations, and a report can be made anonymously, at any time 24 hours/365 days, in various local languages of the areas in which we operate, using the online form or telephone hotlines.

Group-wide reporting channel “Speak Up”
Web: asahigroup.ethicspoint.com
Mobile： asahigroupmobile.ethicspoint.com

All reported cases will be duly considered and investigated as necessary by the Asahi Group’s investigation team, and if the case is substantiated, we will take remedial actions. We will thereafter provide feedback to the reporter. The Asahi Speak Up Policy sets out how to use the system, as well as our commitment on confidentiality and non-retaliation to the reporter.

Asahi Speak Up Policy
Overview of Speak Up

Upon introduction of this Speak Up system, we have provided training to our employees to create awareness.
In addition to the above, each Asahi Group company may have its own whistleblowing channel, as necessary, and reports submitted through such channels are also handled appropriately.

Number of Whistleblowing reports

• Figures for domestic cases only. We plan to provide figures for the entire group from 2024 onwards.