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Compliance, Fair Competition

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

Management Structure

To promote Group-wide sustainability activities, Bridgestone created a structure comprising a global CSR management system, a regional CSR management system, and working groups (WGs) for each area of activity. The global CSR management system prioritizes initiatives in areas pertaining to a variety of global issues, formulates global sustainability strategies, confirms the progress of activities in each area, reports to the Global EXCO,*1 and confirms the in-house imprementation of CSR activities conducted by the Global CSR Enhancement Committee (GCEC).

Within Bridgestone group, “Global Legal Leadership team” was established by leaders of the legal and compliance departments in the Americas, Europe, Middle East and Africa (EMEA), China, Asia and Pacific (CAP) and Japan and the team is taking a lead to design the overall plans.
The Compliance, Fair Competition WG supervises the progress of the compliance activities on a global scale, which activities have been significantly overlapped by initiatives created by the Global Legal Leadership Team. The WG regularly reports the activities to the top management of GCEC and each SBU region.

Since the establishment of the WG in 2016, the WG has created a plan for more effective programs to create a best-in-class compliance culture in the organization globally. These programs are designed consistent with the Bridgestone Essence and the core elements of effective compliance programs recognized by various preeminent government agencies and compliance experts.

Firstly and most importantly, Bridgestone’s top management has clearly identified compliance as a top priority for all members of the organization and has continued to systematically reinforce this message.

Bridgestone Corporation adopted a new corporate governance structure, a “Company with Nominating Committee etc. system” in 2016. Under the new governance structure, a Compliance Committee, which is comprised of independent board members, remains as an advisory committee to the Board of Directors and supervises Bridgestone’s compliance activities, particularly cartel and bribery prevention.

In 2016, the Compliance Committee convened a total of nine times whereby its members shared opinions based on their own experiences and specialties.

In addition to the regular report to the Compliance Committee, Bridgestone’s Chief Compliance Officer (CCO) presents an annual update on the company’s compliance activities to the Board of Directors.

*1 Global Executive Committee: The highest-level committee associated with Bridgestone Global Group business execution

Compliance Activities

The Bridgestone Group takes every aspect of compliance very seriously. Among others, the Group places the highest priority on cartel and bribery prevention for the fair competition, and continues to strengthen its cartel and bribery prevention compliance activities by various means, including, but not limited to standards and rules, training and monitoring activities.

1. Establishment of corporate standards and rules

Some of major The Bridgestone Group companies have their own code of conducts and policies. The Global Legal Leadership Team considers a possibility of a single common Code of Conduct that applies to the entire group, and the project team is working.

In order to clearly show the Bridgestone Group’s commitment to cartel and bribery prevention, Bridgestone established a group-wide policy strictly prohibiting cartel and bribery conduct. Each SBU adopted and maintains a similar code and guideline.

Bridgestone Corporation issued its Cartel Prevention Code in October 2012, which sets out the basic rules of cartel prevention. Bridgestone issued Cartel Prevention Guidelines in December 2014 as a supplement to its Cartel Prevention Code. The Guidelines demonstrate the appropriate course of action to be taken by employees in day-to-day business situations.

Bridgestone also issued its Guidelines on Gifts and Entertainments in October 2012, and renewed the guidelines as “Bribery Prevention Guidelines” in October 2016.

2. Trainings

The Bridgestone Group continues to provide its employees with various types of compliance training. While themes are selected by legal and compliance departments of each SBU, cartel and bribery prevention is a common theme globally. Live, online and workshop style trainings are offered depending on targeted people within the organization.

3. Monitoring

The Bridgestone Group is expanding hotlines throughout the Bridgestone enterprise. In addition to a longstanding general whistleblowing line, Bridgestone established a hotline in 2014 to exclusively receive report related to cartel and bribery as part of its effort to detect any anticompetitive or unfair business conduct at an early stage. The compliance hotlines receive anonymous reports and ensure confidentiality and investigation.

Bridgestone initiated various measures to monitor the status of its internal rules and promptly uncover potential misconduct particularly for cartel and bribery prevention. For instance, the Cartel Prevention Guidelines require its officers and employees to record all contacts with competitors and encourage them consult with legal and compliance department if they have any question or require guidance. In 2016, Bridgestone established its Bribery Prevention Guideline which requires employees to submit an approval form in advance before all payments to official governments. Bridgestone periodically reviews emails of certain employees who have opportunities to come in contact competitors. Furthermore, since 2014, Bridgestone’s CCO regularly interviews officers and division heads to assess level of risks related to legal and compliance.

4. Others

Intercompany compliance meetings for overseas small subsidiaries have been set up to promote compliance activities throughout the organization. In 2016, such meetings were held in Americas, Europe, Asia and Japan. The Global Legal Leadership Team created a plan to strengthen effective legal and compliance oversight over the subsidiaries worldwide and started to take actions to the next phase.

In addition, a variety of initiatives to enhance compliance globally have been started by Global Compliance Practice Team under the guidance of the Global Legal Leadership Team. The Practice Team exchanges ideas and explores opportunities, for instance, an effective means and tools for senior management team to recognize compliance risks around the world, a common training theme and tools, and KPIs for compliance.

Compliance Helplines

Bridgestone Corporation has created two compliance helplines-one internal and one external-to bring compliance-related issues to light and respond to issues as quickly as possible through internal investigations. The compliance helplines ensure the confidentiality of consultations in accordance with the provisions of in-house helpline procedures. The helplines provide the consulting employees with feedback in terms of the results of investigations and the nature of responses while attempting to prevent any adverse consequences for raising a concern. In addition, reports of consultations are regularly submitted to the CCO, who provides advice and takes appropriate measures to ensure the seriousness of responses in the event problems arise.

To encourage employees to use the helpline, we offer helpline contact information during compliance training, use posters to spread compliance awareness, provide helpline contact information on the corporate intranet, and share data on the number and types of cases received. The compliance helplines also accept anonymous inquiries.

In 2015, the Bridgestone Corporation helplines received 98 cases, of which 69% of calls related to understanding Bridgestone policies and 19% were reported concerns.

Compliance Activities for Group Companies

The Bridgestone Group promotes compliance activities globally. In addition to local compliance initiatives, global compliance support teams are sharing best practices and coordinating efforts to promote a common compliance culture.

Compliance Activities for Overseas Group Companies

In 2015, personnel in positions of responsibility in Legal Affairs and Compliance at Bridgestone's major overseas tire business-related SBUs conducted a global meeting aimed at discussing the status of initiatives and issues at each company. In addition to ascertaining the level and details of initiatives at major SBUs, a foundation for initiatives going beyond the SBU was created. Also, a meeting was held for personnel responsible for compliance at non-tire subsidiaries in Europe and the Americas. One initiative that resulted from these efforts was the introduction of an e-learning system at Group companies throughout the Americas in 2015. This progress was the result of sharing best practices from the U.S. tire subsidiary with other Bridgestone Group companies.

Compliance Activities for Domestic Group Companies

Compliance activities are also being promoted at domestic Group companies. For example, in 2015, employees responsible for compliance consultations received training on effective ethics and compliance consulting.

Furthermore, Bridgestone updated regular information exchange meetings and launched a new initiative in the form of an inaugural domestic compliance meeting. At this meeting, information was exchanged regarding compliance initiatives and the communication of Bridgestone compliance-related policies to Group companies.