Compliance, Fair Competition

  • Facebook
  • tumblr

Mission

Ensure excellence through compliance and integrity
We build trust with all stakeholders by ensuring that ethical decision-making guides responsible business practices across the company’s operations.

The Bridgestone Group’s commitment to ethics, compliance and integrity helps it to continuously achieve its overall mission of “Serving Society with Superior Quality” and supports our overall efforts of building a best-in-class ethics and compliance program. As stated in Bridgestone’s Code of Conduct, the Bridgestone Group’s commitment to integrity requires each of our employees “to hold ourselves and our coworkers to the highest standards in the day-to-day efforts to secure Bridgestone’s global success... We must act with integrity in all aspects of Bridgestone’s business.”

Bridgestone’s global ethics and compliance program consists of a blend of global and regionally-based ethics and compliance initiatives. The program aims to strike a balance between global consistency and the flexibility needed to effectively address localized risks, which can vary significantly due to a wide range of the operations and the variety of geographic, legal and regulatory environments in which it operates. The regional initiatives are guided by the core values and principles and united under a common global framework.

Officer

Left: Hidekazu Kimizu, Vice President and Senior Officer Responsible for Corporate Communications, Intellectual Property and Legal Affairs, Chief Compliance Officer; Concurrently responsible for Corporate Administration, Bridgestone Corporation
Right: Chris Nicastro, Executive Vice President, Chief Legal Officer, General Counsel, Secretary and Chief Compliance Officer, Bridgestone Americas, Inc.

Overseen by the Board of Directors and in collaboration with senior management in each region, the Bridgestone’s Group Global General Counsel and Chief Compliance Officer (CCO) and Global Law Leadership Team are principally responsible for the design, administration, evaluation and enhancement of the Group’s global and regional ethics and compliance programs, including the Bridgestone Code of Conduct. The Bridgestone CCO and Global Law Leadership team are supported in these efforts by the Group’s Compliance and Fair Competition Working Group (WG) and regional teams of dedicated ethics and compliance professionals who work together to identify annual and long-term regional and global ethics and compliance priorities and goals, confirm the progress of overall ethics and compliance activities at the regional and global level and report the results to senior management. Since its establishment, the WG has carefully evaluated the key elements and practices of highly effective corporate ethics and compliance programs and instituted short and long-term strategies to foster a culture of ethics and compliance that is consistent with the Group’s corporate values and principles.

While the ultimate responsibility for maintaining a best-in-class ethics and compliance program and culture starts with senior management, every employee must also own this responsibility. With that in mind, in addition to fostering regular and open communication with and among senior leadership on compliance improvement processes, the Bridgestone Group’s ethics and compliance program focuses on active engagement with employees at all levels within the organization to emphasize their responsibility to perform their roles with integrity and employ ethical business practices at all times. The Bridgestone Group’s ethics and compliance program uses this practical, risk-based approach to promote a true culture of ethics and compliance throughout the business.

Key elements of our ethics and compliance program

The Group’s global and regional ethics and compliance programs are built on the following five pillars:

  1. Leadership – the Bridgestone Group engages leaders, managers and supervisors throughout the organization on ethics and compliance to ensure employees act with integrity in everything they do.
  2. Risk assessment - the Bridgestone Group takes a risk-based approach in designing the ethics and compliance program.
  3. Standards and controls – the Bridgestone Group has a number of standards and controls, including the Code of Conduct, Global Anti-Bribery Policy and other global and regional standards and controls.
  4. Training and communication – the Bridgestone Group communicates with employees and helps employees learn in a variety of ways, including e-learning, in-person and other trainings that are risk-based and designed for targeted audiences.
  5. Monitoring and responding – the ethics and compliance program provides multiple channels for employees and others to report allegations of misconduct or wrongdoing.

Leadership

The success of any best-in-class ethics and compliance program, including the Bridgestone Group’s program, depends on the ongoing and proactive engagement of leaders, managers and supervisors throughout the organization to help build and sustain a culture of compliance. The following briefly highlights how the Bridgestone Group engages leaders at all levels throughout the organization.

Board oversight

Board oversight, supervision and engagement have been hallmarks of Bridgestone Corporation’s ethics and compliance program for many years. This board-level oversight and supervision was strengthened in 2014 with the establishment of a Compliance Committee, consisting entirely of independent directors, as an advisory body to the Board of Directors, and again in 2016, when the Company transitioned to a new corporate governance structure. Now, with independent directors serving on the various boards, board supervision of ethics and compliance efforts and the global and regional ethics and compliance programs is stronger than ever.

Leaders, managers and supervisors

Bridgestone regularly engages executive leaders, managers and supervisors to keep them informed and educated about developments in the ethics and compliance program; ensure leaders, managers and supervisors regularly talk about the importance of ethics and compliance; involve leaders in various trainings and communications; and help to ensure that ethics and compliance are at the center of all strategic plans and decisions. Each region has also established a Regional Ethics and Compliance Advisory Panel, consisting of senior leaders from different parts of the business, to help advise on the direction of the ethics and compliance program and ensure the program is effective.

Chief Compliance Officers

The Bridgestone Chief Compliance Officer makes periodic reports to the Compliance Committee, which regularly advises the Board of Directors. Reports pertaining to global ethics and compliance activities are periodically made to the Board of Directors. The global compliance program, as well as the Bridgestone Code of Conduct (including its provisions related to the prohibition of all types of corruption, including bribery), is ultimately subject to the oversight of the Board of Directors of Bridgestone Corporation.

Regional Chief Compliance Officers are responsible for providing similar reports to their respective regional senior leadership teams and their respective Boards of Directors.

Risk assessment

The Bridgestone Group takes a risk-based approach in designing the ethics and compliance program and promotes a true culture of compliance throughout its business. The Bridgestone Group regularly performs risk assessments to understand the evolving risks faced and take appropriate actions to address and mitigate such risks. The following briefly highlights how the Bridgestone Group manages risks relating to bribery, corruption and antitrust.

Global anti-bribery program

BRIDGESTONE INTEGRITY

As a global company, the Bridgestone Group operates in countries with a wide range of risk profiles, making anti-bribery a central focus of its global compliance program, along with regional compliance education efforts. While our Code of Conduct addresses bribery and corruption, the Bridgestone Group decided to reinforce its expectations of all employees and third-parties acting on its behalf by launching its Global Anti-Bribery Policy in 2020. This policy reinforces the Bridgestone Group’s longstanding policy against bribery and corruption and represents another significant milestone toward achieving the Group’s long-term goal of having a best-in-class global ethics and compliance program. The Global Anti-Bribery Policy builds upon the Code of Conduct and conveys the Group's comprehensive policy against all forms of corruption, addressing topics such as bribery, facilitating payments, gifts and entertainment, dealings with third parties, books and records, and political contributions. The Global Anti-Bribery Policy was launched via live and online trainings in each region, together with various other communications from leaders. The Global Anti-Bribery Policy applies to employees of the Bridgestone Group companies across the globe, including joint ventures that it controls, and third parties acting on the Group’s behalf. Where the Group participates in but does not control a joint-venture relationship, it encourages partners to adopt similar requirements and abide by the principles of this Policy in their own operations.

As further described below, the Bridgestone Group also recognizes the bribery risks that exist in working with third parties and conducts due diligence on third parties it engages. In 2020, the Bridgestone Group bolstered its compliance due diligence program with the introduction of a new, third-party screening tool (and related procedures) to identify bribery and trade-compliance risks presented by third parties with which the Group works. The Global Anti-Bribery Policy and the tool together help to significantly strengthen the Group’s global anti-bribery program.

Third party relationships

The Group’s commitment to ethics and compliance extends to third parties with whom it does business. Accordingly, a variety of third parties that the Group engages and works with are subject to the expectations of the Code of Conduct and the Global Anti-Bribery Policy, including the Bridgestone Group’s comprehensive prohibition of bribery and corruption described above.

Bridgestone Group suppliers are also subject to the requirements of the Global Sustainable Procurement Policy, which was established in 2018. The policy’s requirements include the strict prohibition of all forms of corruption, bribery, extortion and embezzlement, as well as a requirement to comply with applicable laws, including those related to competition. As of the end of 2020, more than 99 percent of Bridgestone Group’s Level 1 and 2* suppliers worldwide have acknowledged the policy.

The Group also seeks to mitigate third-party risks by conducting appropriate due diligence, which includes assessing the risks posed by each third party. The risk-based approach to due diligence is designed to ensure that high risk third parties (such as government-owned or affiliated persons or entities, intermediaries or persons or entities operating in high risk locations for bribery, money laundering or other forms of corruption) are subject to enhanced due diligence and subject to ongoing monitoring and audits.

* Please see the Procurement website for definitions of supplier level.

Antitrust program

In addition to the guidance and requirements in the Code of Conduct, all regions currently have their antitrust policies in place for their respective regions and regularly evaluate how to continuously improve and strengthen the antitrust program. This is a topic that the Group takes seriously and makes sure all its new and existing employees understand the requirements.

The Compliance functions in each region work closely with regional departments—including Sales, Marketing, Human Resources, Procurement, Finance and Internal Audit—to understand changes in the marketplace, workplace and overall society and to ensure that overall operations, including global and regional ethics and compliance programs, evolve in parallel. Because the global and regional ethics and compliance programs are intricately linked to all aspects of the Group’s business and operations, the global and regional ethics and compliance functions proactively seek conversations and opportunities to ensure that the global and regional ethics and compliance programs are supportive and reflective of the Mid Term Business Plan. This includes providing ongoing legal and compliance advice on antitrust laws and processes and identifying employees who are most likely to face antitrust risks and provide training (which may be live, e-learning or other types of training) for those employees.

The global and regional ethics and compliance programs also regularly assess and test processes and standards to ensure they are well designed and effective to ensure compliance with applicable antitrust laws.

Standards and controls

The Bridgestone Group aims to provide appropriate guidance for our employees on how to think and act in accordance with the ethics and compliance program by carefully assessing what policies, procedures, and controls can help them do the right thing. The Group regularly reviews existing policies, processes, procedures and controls to ensure that they are effective and working as intended. The following describes some of the key compliance program policies.

The Bridgestone Code of Conduct

In 2018, regional codes of conduct were replaced by the Bridgestone Group’s global Code of Conduct which is intended to provide our employees, suppliers and contractors worldwide with practical guidance for handling a wide range of ethical issues, including anti-corruption, competition/antitrust, conflicts of interest, and corporate charitable and political donations.

Center: A promotional poster for the Bridgestone Code of Conduct / Right and Left: Employees from Bridgestone's Technology Center in Japan

The Code of Conduct covers a variety of topics, including:

  • Promoting respect, dignity and diversity (including prohibitions on harassment and discrimination)
  • Privacy, personal data and confidential information, and integrity of records, disclosures and financial reports
  • Product safety and quality
  • Bribery, corruption, conflicts of interest, and gifts and entertainment
  • Trade restrictions
  • Free and fair competition
INTEGRIDAD BRIDGESTONE

Promotions for the Bridgestone Code of Conduct included leader messaging, training, games, posters, banners, and videos.

The Code of Conduct has been published in 18 languages and is available to employees and the general public through the global corporate website, as well as regional corporate websites. It is also accessible to employees through the company’s regional intranet sites. Paper copies and Code of Conduct Quick Reference Guide brochures are distributed in locations where access to computers may be limited (for example, for plant and retail employees).

Other global and regional policies

The Code of Conduct is supplemented by global, regional and local policies, which are available to employees through a variety of ways, including the Group’s corporate intranet sites and some policies (such as the Global Anti-Bribery Policy) are publicly available on the Bridgestone website. These policies are consistent with the Code of Conduct and provide detailed and practical guidance on key topics, taking into consideration requirements of local legislation. Each region creates additional processes or procedures (for example, processes and approval requirements relating to gifts, meals, entertainment and travel involving third parties) to help ensure the correct application and interpretation of the Code of Conduct and other global policies.

In the spirit of continuous improvement, the Group regularly evaluates the existing policies to address new compliance risks and to identify opportunities where it would make sense to consolidate regional or local policies into global policies.

Training and communication

Over 1200 live compliance training sessions

Over 1200 live compliance training sessions were held for employees in 2019. Here, employees at Bridgestone’s Santo André plant in Brazil participate in Code of Conduct training.

Compliance is the responsibility of every Bridgestone employee. The Group is focusing on effective and risk-based education and employee engagement relating to ethics and compliance. These efforts start at the top, with business leaders regularly speaking about the importance of ethics and compliance and playing active roles in the Group’s compliance training and awareness programs.

In 2020, the Group reinforced the engagement of leaders, managers and supervisors around the world in the ethics and compliance program by issuing various leadership communications and establishing Regional Ethics and Compliance Advisory Panels that involve leaders from different parts of the business who encourage employees to regularly address the importance of ethics and compliance with their teams.

An extensive training program, including 17 e-learning courses launched in different regions around the world in 2020 and live trainings for targeted groups of employees, is strategically deployed in each region to help ensure Group employees are educated on the compliance risks most relevant to their work. They, including sales team members, receive training on topics such as anti-corruption and antirust/competition. Training on anti-corruption comprehensively addresses the company’s policy against all forms of corruption and addresses topics such as bribery, facilitating payments, gifts and entertainment, money laundering, and political contributions.

The Group is rolling out a series of live and e-learning trainings to targeted groups of employees in support of the launch of the Global Anti-Bribery Policy. In 2020, the average regional completion rate for employees targeted for e-learning was 95 percent. In support of the launch of the Global Anti-Bribery Policy, an additional 1,806 live and online training sessions were held globally, covering a wide range of compliance-related topics. Since 2018, the Group has delivered a significant number of trainings and other communications to employees on the Code of Conduct. Consistent with the Code of Conduct, the course included comprehensive coverage of multiple types of corruption as well as competition law.

Tailored publicity related to Bridgestone’s ethics and compliance program is organized on a regional or local level, with the support of common global tools. The Group is increasingly focusing the communication efforts to incorporate digital messages and resources.

In addition to leadership messaging, regional and local efforts in 2020 included diverse events and programs. Specific examples are provided below.

  • The Group’s operation in Japan conducted a survey of more than 10,000 employees to measure overall knowledge and secure feedback on the ethics and compliance program, the Code of Conduct, the Global Anti-Bribery Policy and the different resources available for sharing concerns.
  • In Europe, Middle East, India and Africa, the Group launched its first-ever Integrity Day in November 2020 with 37 compliance-related events involving more than 3,000 employees.
  • In the China Asia Pacific region, the Group launched a regional conflicts of interest policy via multiple training events and held a variety of Integrity Day events.
  • The Group’s Americas operation was named an honoree for Convercent’s Compliance Innovation Award for its sixth annual Ethics and Compliance Week. Activities included a leadership discussion on compliance attended by 1,100 participants, Leading with Integrity Awards and the Bridgestone Compliance Battle Royale gamification training.
participate in Code of Conduct training

Bridgestone China, Asia Pacific Integrity Day

The Group’s compliance team continues to pursue innovative and interactive methods of sharing information that will enable all employees to conduct business in an ethical and legally compliant manner.

Bridgestone regularly requires management level employees to make certain certifications and reaffirm their commitment to the Code of Conduct and the ethics and compliance program. These compliance certifications are coordinated in each of the regions and employees are periodically (often annually) required to complete these certifications.

Monitoring and responding

Speaking up and reporting concerns

DO THE RIGHT THING

Doing the right thing includes speaking up when something is wrong. As stated in the Bridgestone Code of Conduct, Group employees are expected to report actual or possible Code or policy violations or other ethical concerns, and their managers are required to create an environment where employees feel comfortable raising and speaking openly about ethical questions or concerns.

A wide variety of resources are available to all Bridgestone Group employees and stakeholders to encourage them to speak up with questions or concerns. They can report their concerns through an employee’s supervisor, Human Resources, the regional Chief Compliance Officer, the Law Department, Internal Audit and the BridgeLine ethics hotline.

Bridgestone has established its BridgeLine web-based reporting systems and phone hotlines operated by third party specialists to allow all Group employees and any Bridgestone stakeholder (including, for example, contractors, suppliers, consumers and customers) to confidentially and anonymously report suspected criminal conduct; violations of the Code of Conduct (including bribery, facilitating payments, gifts and entertainment, money laundering and political contributions, and the Code’s provision on anti-corruption and various human rights violations); violations of other company policies, or the law; or other ethical concerns and questions. BridgeLine is accessible to employees and non-employees through the corporate website and is publicly referenced in various documents, including the Code of Conduct. BridgeLine is a 24/7 hotline available in all regions and in multiple languages.
BridgeLine

Internal investigations

Yoshikazu Shida

Yoshikazu Shida, Vice President and Senior Officer; Seconded to Bridgestone Asia Pacific Pte. Ltd.; BSCAP Member of the Board, CEO; Chairman of Bridgestone (China) Investment Co., Ltd.

Regardless of how an allegation of misconduct is raised, each report is thoroughly investigated by Bridgestone’s Compliance team or other departments (such as Human Resources or Audit) when appropriate depending on the subject matter. Each region has detailed investigation procedures and protocols to help ensure the quality and consistency of investigations. Each region has developed and tracks certain data and metrics to identify risk areas and trends as well as assess the effectiveness of internal investigations. The results are provided regularly to executive boards at Bridgestone and other board and senior management teams across the global subsidiaries.

Substantiated or partially substantiated reports of wrongdoing may lead to disciplinary or corrective actions, including up to termination of employment.

Yoshikazu Shida

BridgeLine posters in multiple languages

Each region makes significant efforts to promote BridgeLine and encourage a culture in which employees feel comfortable disclosing potential compliance issues. In 2018, a network of local hotlines in the China, Asia Pacific, Europe, Russia, Middle East and Africa regions were consolidated into region-wide, centralized BridgeLine reporting systems. This consolidation and rebranding were used as an opportunity for well-coordinated and highly successful regional awareness campaigns centering on the Speak Up! message.

Reporting lines are only effective if employees feel secure that whistleblowing activity will not negatively impact their employment. The Group prohibits retaliation when business conduct or ethical issues are reported in good faith. This longstanding policy is incorporated into the new Code of Conduct and is reflected in numerous regional and local policies.

In 2020, a total of 1,579 BridgeLine reports and questions were received worldwide. The majority of reports and questions (30 to 65 percent depending on the region) related to human resources issues. A breakdown of the categories of reports and questions received globally appears below. Upon investigation, over 40 percent of reports were substantiated or partially substantiated. All confirmed violations resulted in appropriate corrective and mitigating action, including disciplinary measures up to and including termination. There were no significant confirmed reports in 2020 for the key areas of corruption and antitrust/competition.

2020 BridgeLine Matters per Category

2020 BridgeLine Matters per Category

2020 BridgeLine Reports - Anonymity

2020 BridgeLine Reports -
                                Anonymity

Audits

In addition to BridgeLine reports, Bridgestone reviews compliance with the Code of Conduct and identifies non-compliance through various methods, including periodic audits related to key compliance areas such as fraud, corruption and money laundering, as well as the oversight of approximately 200 legal and compliance professionals through the company’s global operations.

Evaluating the compliance program and compliance risks

An effective ethics and compliance program must constantly evolve and be evaluated to ensure the company is addressing current risks and expectations. The Bridgestone Group actively monitors resources such as the Transparency International’s Corruption Perceptions Index (CPI) to understand the key compliance risks in the places where it does business.

Key compliance issues, including anti-corruption, antitrust, fraud, discrimination and other compliance risks, have long been included in annual enterprise risk assessments, and breaches of regional codes of conduct and/or anti-corruption policies have been tracked on a regional basis. Since 2018, tracking has been consolidated on a global basis and formal and informal compliance-specific risk assessments have been conducted in each region in 2019 and 2020 for a deeper view of compliance risks.

Key risks identified through these processes are communicated to senior leadership on a regional and global basis. Controls are implemented to address critical risks, including corruption risks (such as risks related to facilitating payments, gifts and entertainment, money laundering, and political contributions) in high-risk locations. These controls are carefully considered and strategically implemented to effectively counter significant risks without placing an undue burden on Bridgestone’s business.

The effectiveness of key controls, including those related to fraud, corruption and money laundering, are reviewed within the scope of periodic enterprise audits. In the spirit of continuous improvement (kaizen), processes and controls are frequently reviewed and optimized. Bridgestone’s new global compliance structure has created many opportunities for reviewing existing processes, identifying best practices and gaps, and implementing enhancements.

Similarly, the global compliance framework creates opportunities for reviewing and optimizing policies related to key compliance risks. When preparing Bridgestone’s global Code of Conduct, the company's Global Compliance team considered the effectiveness of existing regional policies and codes of ethics and sought to address any existing gaps. The Code of Conduct is a living document, and the global team will continue this practice of periodically reviewing its effectiveness and adjusting it, or the compliance program more generally, as needed to meet the goal of maintaining a best-in-class compliance program.

Serving society through ethical business practices

The Group has long embraced the mission of “Serving Society with Superior Quality” and the idea that the best companies not only perform for their stakeholders, but also contribute to a better world. The ethics and compliance program embodies this commitment to integrity and helps ensure that all the employees understand their responsibility to act with integrity in all aspects of Bridgestone’s business.

Relevant information

Sustainability