An introduction to the Yamaha Motor Group’s initiatives in the area of compliance.
The Yamaha Motor Group has established a Risk Management and Compliance Committee, chaired by the Company President, to create a structure to ensure legal and regulatory compliance throughout the entire Group. The committee deliberates plans to ensure compliance, and monitors the implementation of those plans and the corporate culture with regard to compliance. The outcomes of these deliberations and monitoring are reported, as appropriate, to the Board of Directors as items deliberated by the Risk Management and Compliance Committee, together with ESG risks, and a structure has been established to ensure their effectiveness.
Specific activities are carried out as per the “Compliance Management Rules,” and the compliance supervising section manages the Group’s overall activities.
As a way to ensure that compliance is incorporated into the corporate culture, Groupwide compliance awareness surveys are carried out annually in Japan to confirm the effectiveness of Group compliance measures, including the degree of understanding and scope of implementation of the Code of Ethics, the extent to which reporting lines and hotlines are used, and the effectiveness of training programs, as we strive to identify and prevent the occurrence of compliance violations. Based on the results of these surveys and social trends, the Code of Ethics Guidebook is updated annually, and the Code of Ethics is reviewed regularly.
Although individual awareness surveys are carried out at overseas Group companies, from 2018 a unified Group compliance awareness survey will be carried out.
Code of Ethics
The Yamaha Motor Group has formulated and disseminated throughout the Group its Code of Ethics, which stipulates standards of behavior to be observed based on the Company Pledge, passed down since the Company’s foundation, and the Management Principles. The Code has been translated into local languages at overseas Group companies, and an educational video has been prepared in 11 languages for use in training at Group companies to familiarize all employees with the Code of Ethics. Group companies also hold training sessions in the Code of Ethics for new employees.
Yamaha Motor’s Code of Ethics
In the 2017 compliance awareness survey (Yamaha Motor Co., Ltd.), in response to the question, “Do you have a full understanding of the contents of the Code of Ethics?”, 71.3% of respondents answered “Yes” while 4.5% answered “No.”
Compliance Risk Assessment
The Yamaha Motor Group’s business activities span the entire world, and these business activities need to comply with various laws and regulations. A Groupwide risk assessment is carried out annually to identify the common risks that need to be identified, covering many compliance risks including bribery and corruption, cartels, and security-related export controls. These risks are then assessed at individual operating divisions and Group companies, appropriate countermeasures are implemented, and their implementation status is monitored.
In the 2017 compliance awareness survey, in response to the question, “When you are unsure of something in the course of your work, do you place top priority on compliance?”, 76.5% of respondents answered “Yes” and 2.5% answered “No.”
Compliance and Legal and Regulatory Training
A compliance activity plan is formulated each year, and compliance training is carried out based on this plan. There are two types of training: level-specific stratified training and specialized training.
a. Compliance training as part of level-specific training
All new employees – both new graduates as well as mid-career hires – and temporary staff take compliance training that focuses on the Code of Ethics when they join the Company. In addition, when an employee is newly promoted to a managerial or supervisory position, division manager, or head of a business site, they take compliance training focused on that position or function annually or as required. This training includes examples of bullying and harassment, and how to respond when cases are brought to their attention for consultation.
b. Annual compliance training for all employees
All persons who work for Yamaha Motor take compliance training, with the aim of each individual employee creating a model that will earn the trust of society for the Company as a whole by practicing compliance. This compliance training is carried out annually (including for temporary staff), and records of attendance are retained. In addition, division managers and executive officers who are primarily engaged in operating activities take annual compliance training in an effort to implement compliance from top management down.
In addition, group training programs covering laws and regulations deemed to entail significant risk in the execution of the Company’s business activities are carried out annually. Legal and regulatory compliance courses in 2017 covered topics including the protection of personal information, cartels, the prevention of insider dealing, import and export management, management of chemical materials, the Subcontract Act, intellectual property rights, disaster prevention and response, risks in information technology, and safety overseas.
In the 2017 compliance awareness survey, in response to the question, “Do you consider the Company’s compliance to be meaningful?”, 76.3% of respondents answered “Yes” and 5.0% answered “No.”
Training in the Code of Ethics and legal and regulatory training is also carried out for new employees of overseas Group companies, and the results are monitored at the head office.
Compliance Training in Japan—No. of Attendees (Aggregate Attendees)
Executive officer training
Division manager training
Laws and regulations training
Level-specific stratified training (division manager, manager, floor manager, new hires, mid-career hires and temporary staff, etc.)
Compliance Training at Overseas Group Companies—No. of Attendees (Aggregate Attendees)
North America, Europe, Australia
Central and South America
China and Taiwan
Whistle-Blowing Systems (Compliance Hotlines)
Yamaha Motor has established its Compliance Hotline for any notification of behavior that could violate the Code of Ethics and for discussion or inquiries regarding compliance in general. The Compliance Hotline has been set up at an external, specialist institution, and is the common contact point for notification and consultation for all domestic Group companies. A Yamaha Motor Group Compliance Hotline has been established at an outside institution as a common contact point for employees of Group companies in Japan to report or discuss issues anonymously. By making it easy to report these issues, we are striving to prevent the occurrence of and detect at an early stage any illegal or unfair practices. Internal regulations also clearly state that any retaliation for the use of the internal notification system is strictly prohibited, and employees are reminded of this in annual compliance training programs.
The Human Resources Division has also established a Harassment Hotline as a contact point and to respond to reports of harassment.
A Yamaha Motor Group Fair Business Hotline was also established in 2017 as a contact point for suppliers.
During 2017, the Yamaha Motor Group Compliance Hotline received 108 reports (including consultations), the subjects of which are broken down below. There were no reports involving violations of human rights or bribery and corruption.
Subject of Reports in 2017
Percent of Total
Human resources and labor relations
Human rights violation
In addition to ongoing activities to promote awareness of the internal notification system, efforts are made through activities including annual workplace compliance training to deepen employees’ understanding of the system and ensure that it functions swiftly and appropriately, as a way of instilling a system and corporate culture that incorporates compliance.
Internal notification systems have also been established and operate at major overseas Group companies, based on the local laws and regulations and other circumstances specific to each respective company.
Internal notifications that are confirmed to point to a problem are handled as cases and are responded to based on the “Rules for Initial Response to an Emergency.” In addition, a global internal notification contact point is being set up at an outside institution from 2018 to enable notification of inappropriate actions being taken by managers of overseas subsidiaries, as we strive to detect inappropriate behavior globally at an early stage.
With regard to bribery, risks evaluated on a common basis Groupwide are included under “corruption” in the comprehensive risk management ledger, and bribery is included in the corrupt practices evaluated by the operating divisions and Group companies. The Board of Directors monitors management status as an ESG issue, while also receiving regular reports from the Risk Management and Compliance Committee. In addition, a Guidebook to Prevent Bribery of Public Officials has been prepared and disseminated throughout the Yamaha Motor Group. Other programs have been established to ensure the thorough prevention of corruption, including training on laws and regulations and training intended for specific groups or individuals (in particular, persons scheduled for overseas assignments or other positions where they may be exposed to potential high risks). A prior consultation system has also been introduced to prevent bribery, and prior consultation with the relevant legal affairs division is mandatory in cases where benefits are provided to public officials in Japan or any other country, or for subcontracting where there are existing possibilities of contact with public officials in Japan or any other country. Mandatory procedures are also in place for political contributions, based on the laws of each country involved.
Thorough Import and Export Management
Because a large proportion of the Yamaha Motor Group’s business activities are conducted outside of Japan, we are constantly engaged in activities which place importance upon the management of imports and exports.
As an initiative related to exports, at Yamaha Motor Co., Ltd., we conduct Security Trade Control (STC) study sessions and liaison meetings based upon compliance with the Foreign Exchange and Foreign Trade Act and other related laws and regulations. For relevant departments and Group companies, regular and comprehensive educational training sessions are implemented. As one aspect of training for those engaged in trade, we encourage employees to take the STC Associate*1 and STC Expert*2 examinations and we have had successful candidates each year.
We continue our initiatives to prevent the order, import, transfer and supply of goods which are confirmed to contain substances prohibited for use in manufacturing*3 or where the inclusion of such substances cannot be confirmed.
A practical accreditation exam for security trade control conducted by the Center for Information on Security Trade Control (CISTEC), a non-profit and non-governmental organization
An accreditation exam demanding a higher level of ability compared to the “STC Associate Examination”
Substances indicated in Item 1, Article 16 of the Enforcement Order of Industrial Safety and Health Law