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Fair Business Practices (CSR Procurement)

POLA ORBIS Group Purchasing and Procurement Policy

The POLA ORBIS Group has set Basic Group Purchasing Policies in a bid to translate sound, fair business practices with suppliers into action.

Basic Group Purchasing Policies

Execution of fair and impartial transactions in Japan and overseas

  1. We decide on our suppliers based on the comparative assessment of points including quality, cost, deadlines, technological capabilities and corporate stance.
  2. We take our actions in compliance with the relevant laws and regulations.
  3. We continue efforts to fulfill our social responsibilities, such as the protection of resources and the environment.

CSR Procurement Guidelines

The POLA ORBIS Group has established the POLA ORBIS Group CSR Procurement Guidelines, compiling what the POLA ORBIS Group should practice for sustaining its growth permanently while continuing fair and free transactions with suppliers in compliance with Basic Group Purchasing Policies. Based on the Guidelines, the Group will conduct monitoring step by step to ascertain the status of its CSR procurement initiatives.

*The POLA ORBIS Group requests for its business partners to implement and adhere to its CSR Procurement Guidelines. The Guidelines cover a range of issues including reducing long working hours at business partner companies, guaranteeing minimum wage, ensuring labor management in adherence with local laws, ensuring safe and hygienic workplace environments, and reducing CO2 emissions (energy consumption), water usage and waste output.

System for Ensuring Fair Relationships with Business Partners

The POLA ORBIS Group builds relationships in compliance with laws and regulations under the responsibility of each company. Even among our relationships with business partners, the procurement of materials has in recent years become a global issue, and in 2019, we established the Procurement Subcommittee as a subcommittee of the CSR Committee. The Procurement Subcommittee investigates procurement issues that may influence the entire Group, looking at responses to these issues together with the employees supervising purchasing at each company. The results of these investigations are reported to the Board of Directors as required.

Enlightenment for Ensuring Fair Relationships with Business Partners

The POLA ORBIS Group hopes that all of its business partners around the world will understand and cooperate with its Group Basic Purchasing Policy and Group CSR Procurement Guidelines. To this end, we are working to make the Group's Basic Purchasing Policy and CSR Procurement Guidelines (which require human rights and environmental initiatives) well known to all business partners, such as by explaining them at purchase briefings hosted by POLA CHEMICAL INDUSTRIES and when requesting cooperation with CSR procurement questionnaires. In addition, contracts with business partners are based on the Basic Purchasing Policies and CSR Procurement Guidelines.

POLA ORBIS Group CSR Procurement Initiatives

At the POLA ORBIS Group, we conduct CSR procurement questionnaires and field audits following our CSR Procurement Guidelines. These activities are aimed at building better relationships with our partners and fulfilling our social responsibilities together with them.

CSR Procurement Questionnaires

We conduct CSR procurement questionnaire surveys at Group business partners once every three years. Through these questionnaire surveys, we ascertain the size of risks and communicate with our business partners to ensure compliance with laws and regulations (compliance, fair trade and anti-corruption, information security, minimum wage), human rights (prohibition of forced labor and child labor, discrimination, etc.), work environment, environment, supply chain and quality maintenance. We also conduct CSR procurement questionnaire surveys to assess risks such as human rights and environment risks for potential new business partners.
Julique, a wholly-owned Group subsidiary which sells premium skincare products in 20 countries around the world–primarily Australia–is a member of Sedex and conducts risk assessments for its business partners through Sedex.

Number of questionnaires collected (plant site units)

2018 243 sites 2019 33 sites 2020 4 sites

* Questionnaires are conducted once every three years for each business partner / supplier site.

Conducting of CSR On-site Audits

The POLA ORBIS Group conducts CSR on-site audits—with focus on materialities—of business partners who have difficulty replacing BCP Group priority items and raw materials, business partners with high transaction rates, and business partners judged to be at high risk based on CSR questionnaire surveys.
In 2020, we conducted on-site audits of five companies. When business partner factories hire employees, we check their age using reliable forms of personal identification. We requested all business partners undergoing on-site audits to make improvements. We requested improvements and reporting on responses with regard to waste management, updates to the latest versions of SDSs and on-site posting There were no cases of violations or findings pointed out with regard to environment-related laws or regulations.

Setting up the Business Partner Hotline

POLA ORBIS Group accepts complaints and consultations from business partners to the Group via its Business Partner Hotline. The hotline covers compliance violations (including human rights issues) based on the POLA ORBIS Group Code of Conduct and CSR Procurement Guidelines.

POLA CHEMICAL INDUSTRIES: Purchasing Activities

A scene from a briefing on Basic Group Purchasing Policies

The POLA ORBIS Group has established original environmental standards for cosmetics raw materials and container packing materials in order to promote eco-friendly procurement and purchasing activities with POLA CHEMICAL INDUSTRIES in the center. The POLA ORBIS Group is making efforts to procure and purchase raw materials in conformity with the established standards for matters, such as endocrine-disrupting chemicals and pollutant release and transfer registers (PRTRs), bearing the protection of resources and environmental preservation in mind.
The Group is choosing appropriate container packing materials, such as those in which recycled materials are used, and is undertaking eco-friendly design and purchasing activities to promote the conservation of raw materials and resources.
Furthermore, the Group is communicating closely with its suppliers to strengthen cooperation with them. The Group is communicating its philosophy and management policies to them by organizing briefings on Basic Group Purchasing Policies on demand.
We invite suppliers of raw materials, suppliers of packing materials, and outsourcees to briefings. We explain important matters to them, such as the building of alliances with suppliers, initiatives for globalization, the evolution of supply chain management, and the enhancement of BCP initiatives.
Furthermore, the Group is organizing events such as study meetings on external investigations by the relevant organizations, voluntary audits, laws and regulations associated with purchasing activities and social ethics, in order to observe the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors, other laws and regulations.

Fair Competition

POLA ORBIS Group Fair Competition Policy

POLA ORBIS Group employees act with a strong sense of ethics in accordance with the prohibition of anticompetitive practices prescribed in the POLA ORBIS Group Code of Conduct. The POLA ORBIS Group engages in fair and free competition among companies without performing acts that violate the Antimonopoly Act, such as the maintenance of cartels, bid-rigging and resale prices and the abuse of dominant bargaining positions.

Prevention of Corruption

POLA ORBIS Group Prevention of Corruption Policy and Initiatives

The POLA ORBIS Group has set the POLA ORBIS Group Code of Conductpdf and Guidelines Concerning Gifts and Entertainment (established in 2008), both of which prescribe rules of conduct for realizing the Group philosophy and controlling self in a global society. The Code of Conduct and Guidelines prescribe the observance of laws, regulations, in-house guidelines, standards and the like in relationships with customers, suppliers, operational, manufacturing and other contractors, and public servants in the relevant government ministries and agencies, and prohibit the offering of gifts, entertainment and the like to such parties and receiving them from the same parties, in principle.
Detailed rules established by the respective Group companies set upper limits for exceptions to the rules stated above, including inexpensive items, such as promotional supplies, and items socially accepted as necessary for operations, such as parting gifts and gratuities. However, they also stipulate advance approval and ex post facto reports as mandatory requirements.
In addition, the respective POLA ORBIS Group companies have established management systems and measures to ensure that their employees observe the substance of these rules properly. They are conducting self-audits and offering instructions related to gifts, entertainment and the like on a periodic basis. The respective POLA ORBIS Group companies are periodically offering e-learning programs to all their employees and trying to give the widest possible publicity to those programs.
Regarding supply chains, the POLA ORBIS Group has established the CSR Procurement Guidelinespdf, which summarize the matters the Group needs to sustain its development permanently while continuing fair and free transactions with suppliers based on Basic Group Purchasing Policies. Based on these Guidelines, the POLA ORBIS Group is asking suppliers to undertake their business activities in compliance with laws, regulations and ordinances in the respective countries and regions and refrain from involving themselves in transactions whose fairness is questionable, bribery and corruption. Moreover, the POLA ORBIS Group supported the United Nations Global Compact, which set 10 principles in the four areas of human rights, labor, the environment and anti-corruption, and signed the Compact in February 2017.

ESG Information
Corporate Report2020
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