Suntory Group strives to create an organization and corporate culture that place the highest priority on compliance to fulfill our responsibilities and meet the expectations of our customers and society.
Our Policies and Approach
Suntory Group Code of Business Ethics: The fundamental principles shared by all employees for the realization of our corporate philosophy
Suntory Group Corporate Ethics Code was established in 2003 and indicates the fundamental principles that all employees must share. We are building a compliance promotion system to realize our corporate philosophy from a cross-Group view based on this Code of Business Ethics. We also revised the content by referring to the ISO26000 international standard for social responsibility in 2012 and adapted the content in 2017 to make it more comprehensible for all Suntory Group employees worldwide.
Promotion Structure
Promotion System Rooted in the Frontlines
To promote compliance while bringing together a variety of Group perspectives, we have established the Global Risk Management Committee and the Compliance Department, the latter of which functions as an expert body within our Governance, Risk, and Compliance (GRC) Division. It formulates and implements specific measures in line with GRC Division policies, monitors the status of their implementation at each workplace, and provides suggestions and advice on any issues that arise. It has also established a Compliance Hotline (internal reporting system) and responds to any and all reports in a spirit of fairness, impartiality, and good faith. We have revised some of the rules for the Suntory Group Internal Reporting System Regulations to operate more effectively under this system following revisions to the Whistleblower Protection Act. In addition, specific personnel responsible for promoting compliance are assigned at each Group company around the world. They take an active role in promoting compliance, formulating policy customized for the circumstances in their own company, and informing colleagues about that policy. The Compliance Department also supports Group companies in Japan to promote compliance, including by suggesting measures, providing tools, and running group training sessions.
The Compliance Department consolidates the Group's compliance-related efforts into a Compliance Report, which is presented to management annually. In addition, we have a system in place that prompts reporting of any compliance issues discovered to the Global Risk Management Committee when deemed necessary. The Global Risk Management Committee and Compliance Department will investigate any such report and take measures to both remedy the situation and prevent its reoccurrence. They report action taken to the Board of Directors where appropriate.
Compliance Promotion Structure
GRC Division Internal Audits
To verify Suntory Group employee compliance and that our business is being conducted as it should be, Suntory Group auditing departments conduct internal audits of all departments within the Group as well as of our subsidiaries, reporting audit results to our President and Representative Director as required.
For more information, please see Basic Concepts and Operations for the Internal Control System
Enhancing the Hotline for Early Discovery and Resolution of Issues
The basic rule in Suntory Group is that when an employee discovers actions that breach the Suntory Group’s Code of Business Ethics, they must first report it to the supervisors and seek their advice. However, for situations where such reporting or consultation is not appropriate, we have established an internal whistleblowing system to ensure early detection and resolution of issues.
In Japan, we have set up a Compliance Hotline that can be accessed by all Group staff internally via our Compliance Department or externally via a third-party law firm. A multilingual support system is also available to ensure that foreign-national employees can use the service with confidence regardless of their Japanese level. Additionally, in order to remove any technical or financial barriers to using the service, we have ensured that it is accessible to all of our employees through a range of methods, such as online (including via smartphone), by landlines, and by mail.
The internal awareness of this mechanism is measured every year through initiatives such as the "Employee Awareness Survey" as a way to engage users and assess the current mechanism, and the current awareness rate is over 90%. We also strive to keep improving the awareness rate and accessibility of this mechanism by sharing these results (including comparisons with previous year) with our top management.
In 2024, a total of 178 reports were received through these contact points in Japan.
Compliance Hotline awareness poster
For reports that suggest compliance violations, we take into consideration the privacy protection of all persons involved in accordance with Suntory Group Internal Reporting System Regulations.
During this process, we respect the circumstances of the reporter and promptly have the compliance officer conduct a confidential internal investigation within the company. We involve the relevant executive in charge to swiftly seek corrections and ensure that the necessary actions are taken. This approach helps in addressing the issue and implementing measures to prevent recurrence.
After a certain period following the resolution, we conduct a follow-up to verify the corrective actions taken. This follow-up serves as the closing step for the case, ensuring thorough resolution.
Protecting the Reporters
Alongside the establishing of our Compliance Hotline, Suntory Group has, in our employment regulations and Internal Reporting System Regulations, prohibited any treatment detrimental to anyone making a report, including retaliatory behavior or the spreading of rumors concerning them. To prevent such occurrences, when the Compliance Department conducts an investigation, it identifies the persons concerned and then confirms the "internal reporting system regulations" to ensure that the rights of reporters are protected and not compromised.
In addition, during the follow-ups with the reporter at the closing of each case, we also check that reporters have not suffered any disadvantages during the process.
Furthermore, by actively promoting awareness of the Internal Reporting System Regulations within the company on a daily basis, we strive to create a workplace culture that ensures the protection of reporters and others, not just the directly involved parties.
Compliance Hotline Response Flow
Our Initiatives
Activities to Ensure Compliance
Promotion of the Code of Business Ethics and Compliance Awareness Initiatives
To ensure the Code of Business Ethics is understood and put into practice on a daily basis by all Suntory Group executives and employees, both the Japanese-language and English-language versions of the Code of Business Ethics have been posted on our internal intranet.
In Japan, every year we provide opportunities for employees to re-familiarize themselves with the content of the Code of Business Ethics by means of workplace discussion sessions and e-learning regarding compliance related incidents that have occurred outside the Group, topics that are recognized as issues in the Group or in individual companies, etc. We also strive to remind employees about the fundamentals of compliance, and to promote ethical behavior.
We share related information on the Compliance Net in our intranet on a regular basis, including themes linked to ongoing activities and content that helps understand the essence of compliance through real-world examples. The compliance promotion managers in each company take the lead in ensuring all employees are informed.
Each Group company in Japan undertakes related activities in which the compliance promotion managers play a key role. In addition to supporting work by Group companies in Japan to promote compliance, our Compliance Department also provides training for newly appointed directors and managers at these companies, to help them develop a more in-depth understanding of the leading role that they need to play in compliance management.
Our Compliance Training
| Theme | Target |
|---|---|
| Raising awareness and ensuring understanding of our Code of Business Ethics | All Suntory Group employees |
| Job level-specific compliance training | New employees, newly appointed managers |
| E-learning on harassment | New employees |
Establishment of Insider Trading Prevention Framework and Internal Awareness Promotion
The GRC Division of Suntory Holdings Ltd. and the management headquarters of Suntory Beverage & Food Ltd. are working to comprehensively prevent insider trading through e-learning and other means based on the content provided by the Tokyo Stock Exchange, as Suntory Beverage & Food Ltd. is listed on the Tokyo Stock Exchange.
Implementing the Suntory Group Code of Business Ethics in Business Activities
We clearly state our emphasis on compliance in the Code of Business Ethics. In our business activities, each department sets and implements policies and voluntary standards to address various compliance issues in their business activities under the principles outlined in the Code of Business Ethics.
Ensuring Fair Business Practices
Suntory Group considers compliance with various laws, including the "Antimonopoly Act," and conducting fair business activities as fundamental prerequisites for our operations. Since the formulation of the Guideline for Compliance of the Antimonopoly Act in 1992, we have revised and implemented the guideline in accordance with revisions of laws and changes in the environment. We are working to ensure thorough awareness of and compliance with the Anti-Monopoly Act and related laws and regulations by posting on our intranet the Key Points to Consider for the Promotion Campaigns under the Act against Unjustifiable Premiums and Misleading Representations and our Compliance Manual for the Act against Delay in Payment of Subcontract Proceeds and by holding regular briefings for each division and Group company.
To ensure fairness in our day-to-day activities with our suppliers and customers, our specialized departments are actively involved from the planning stages of product development, sales, and marketing, and verify the response policies and activities of related departments from the perspective of legal compliance.
Establishing Committees to Promote Fair Business for Alcoholic Beverages
To ensure compliance with alcohol-related laws and internal standards, based on the Fair Practice Guidelines for the Liquor Business*, Suntory Group has established the Fair Trade Promotion Committee within the organization to promote fair trade practices.
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*The Fair Practice Guidelines for the Liquor Business are administrative guidelines established by the National Tax Agency in 2006. These guidelines prevent worsening of management of liquor business operators and the reduction of liquor taxes due to dumping caused by excessive competition. We set fair partnership conditions and make rebates more transparent to stabilize management of liquor business operators. This is also coordinated by Fair Business Committee responsible for overseeing the Antimonopoly Act.
Transparency of Business Activities and Prevention of Bribery
Suntory Group’s Code of Business Ethics prohibits the provision of excessive business entertainment and gift-giving to any counterpart regardless of whether it is a corporate entity, individual, political or governmental entity, or any other related organizations or companies, and establishes that relationships with all parties should comply with laws and be fair and transparent. In response to a global strengthening of anti-bribery regulations, such as the Foreign Corrupt Practices Act (FCPA), we announced Suntory Group’s basic approach to anti-bribery action for Suntory Group directors and employees worldwide (our Anti-Bribery Measures) in 2015. We also set regulations and benchmarks, in line with global standards, on business entertainment, gift-giving, donations, political contributions, and corporate sponsorships, and are working to promote awareness and understanding of these issues.
We make particular efforts to proactively promote awareness of and provide e-learning and other resources about our global anti-bribery regulations and benchmarks to employees who could encounter corruption in the course of their duties, as well as conducting regular monitoring of these situations.
Moreover, we have put in place a global Compliance Hotline to create and utilize a system for receiving reports and carrying out consultations. Employees are encouraged to immediately report any instances of known or suspected corruption to the Compliance Hotline.
Risk Assessment for Corruption
Suntory Group openly communicates about its due diligence processes and the nature of relationships with its business partners, working towards the establishment of a robust risk assessment framework that includes due diligence. For areas and transactions identified as high-risk regarding corruption issues, we focus on enhancing our activities.
Where the results of our business partner due diligence show that a business partner presents high risk in this area, we set out anti-corruption and anti-bribery provisions in our contract with them.
Global Compliance Initiatives
With Suntory Group's global expansion, we are committed to building a global promotion framework and aligning with global standards.
As part of our global risk management system, we have established the Suntory Group Global Hotline, a unified global contact window for whistleblowing which covers Group companies throughout the world.
The Hotline is able to receive reports in multiple different languages, including English, Chinese and Spanish, and can handle reports and requests for consultation from people in many different countries. In 2024, a total of 208 reports were received through contact points at our Group companies overseas. There were no reports relating to child labor or forced labor.
Educational tool to promote understanding of the Code of Business Ethics (cartoon)
The Compliance Department uses a shared global education platform to implement e-learning aimed at ensuring employee awareness of the Code of Business Ethics and of personal data protection issues, etc., and it provides support for compliance promotion activities at overseas Group companies.
The Compliance Department has also produced short manga-style cartoons as an educational tool to strengthen awareness of the Code of Business Ethics in an easy-to-understand way, and these are being effectively utilized by individual overseas Group companies as teaching materials for employees who do not have access to the environment needed for e-learning.
Employee Awareness Survey to Understand the Awareness Towards Compliance and the Organizational Culture
To understand the status of compliance and the organizational culture as well as to determine if there are any individual issues, we conduct awareness surveys for all Group employees in Japan. The survey results help identify company-wide and departmental challenges, informing initiatives to foster a compliance mindset throughout the Group. We share the d insights with directors and managers at each company, encouraging proactive measures for addressing identified challenges.
Overseas Group companies contribute to compliance management by conducting their own independent surveys.
Suntory Group Business Partner Compliance Hotline
The Suntory Group Business Partner Compliance Hotline serves as a reporting channel for business partners of Suntory Group companies. Please contact the Suntory Group Business Partner Compliance Hotline if, as a business partner of a Suntory Group company, you become aware of misconduct of Suntory Group officers or employees, including conduct that violates or may violate laws, regulations, or the Suntory Group Code of Business Ethics, in the business with Suntory.
