LIXIL makes pioneering water and housing products that solve everyday, real-life challenges, making better homes a reality for everyone, everywhere.
LIXIL compiled the LIXIL Code of Conduct in April 2015, and revised it from time to time as necessary, to clarify the Group-wide compliance policy and ethical standards. We actively take steps to ensure that all employees and officers across the Group fully embrace and uphold these principles. To enhance the effectiveness of our compliance program across the Group, we have developed concrete policies and guidelines based on the Code of Conduct and we ensure employee awareness and conduct regular reviews.
To promote fair business activities and instil a firm compliance culture, we have established the Compliance Committee, chaired by the Chief Legal & Compliance Officer (CLCO), who provides guidance on structuring and managing appropriate systems to Group companies, monitors compliance with various laws and regulations, and performs periodic checks on the compliance programs. Among the agenda items discussed at the Compliance Committee, for those need to be discussed by higher bodies such as Board of Executive Officers and Board of Directors, we have established a process in our internal policies which stipulate submission of the proposals to the higher bodies to seek each body’s deliberation respectively. In addition, the Board of Directors regularly receives reports from the CLCO and oversees compliance efforts.
To enhance employees' understanding of compliance, we have translated the LIXIL Code of Conduct in 17 languages in addition to Japanese and English, distributed hard-copies to all employees in Japan, and published it on our intranet.
Training sessions are held to deepen employees' understanding of the Code of Conduct, and every year all employees are required to acknowledge the contents of the code and promise to comply with it. As an additional effort, we make case studies available on our intranet, describing correct compliance actions to reflect potential real-life work situations.
The Global Policies and the Detailed Rules aligned with the LIXIL Code of Conduct have been put in place for specific fields posing a high risk to the LIXIL group of companies. The revision or abolishment of these Global Policies are made by a resolution of the LIXIL Board of Executive Officers and are available in 17 languages.
LIXIL established the Global Policy on Anti- Discrimination and Harassment in December 2016. The policy clearly states that any form of discrimination, harassment and bullying is strictly prohibited. Such behavior will not be tolerated.
Discrimination includes direct discrimination, indirect discrimination and discrimination by perception*. LIXIL members must not discriminate against other people.
*Discrimination by perception means treating someone less favorably where a person is perceived, assumed or imputed to have a Protected Characteristic. For example, this can include discrimination of a person based on the perception or assumption that he has a disability, even though he does not.
Harassment is any unwanted verbal or non verbal, visual, physical or other conduct that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive work environment for them. Harassment may involve conduct of a sexual nature, or it may be related to a person having one or more Protected Characteristic. In any event, harassment is unacceptable.
If a LIXIL member is being discriminated against, harassed and/or bullied, (s)he should consider whether (s)he feels able to raise the problem informally with the person responsible. If informal steps are not appropriate or have been unsuccessful, the LIXIL member should raise his/her concern to Legal Department/Compliance or through channels set out in the LIXIL Code of Conduct and Global Policy on Concern Raising.
When discriminatory behavior or harassment is found as a result of the investigation, appropriate corrective action and recurrence prevention measures are taken. Also, it could result in disciplinary action up to and including termination of employment pursuant to each entity’s disciplinary policies and local laws.
Training on the Global Policy on Anti-Discrimination and Harassment is provided across the Group.
LIXIL established the Global Policy on Anti-Corruption in December 2016. The policy clearly states that the Group has zero tolerance towards bribery and corruption, and that the use of illegal or improper means to influence the actions of others is prohibited. LIXIL does not tolerate the giving or receiving of improper payments, including a ban on facilitation payments.
LIXIL members are required to keep accurate and complete books and records. Unofficial agreements or otherwise unapproved agreements, whether written or oral, are prohibited.
In addition to the Global Policy on Anti-Corruption, LIXIL has also established Detailed Rules for Gift and Entertainment which further set out LIXIL's expected behaviors in relation to the giving and receiving of gifts and entertainment, the making of donations to political parties and other organizations such as charities, and the acquiring of sponsorship.
In FYE2023, we did not have any corruption related breaches of the Global Policy on Anti-Corruption which required investigation.
LIXIL's Global Policy on Anti-Corruption incorporates the following requirements which must be followed by all LIXIL members (which includes all employees and officers*).
・As a general principle, no LIXIL member may give money or other benefits to a government official or their relatives.
・No LIXIL members may pay directly or indirectly to any private sector party any money or other benefit to influence, reward, or gain any improper advantage.
・LIXIL members and their relatives shall not request or accept money or other benefits unless specifically authorized to do so under applicable Detailed Rules for Gift and Entertainment.
・Facilitation payments are prohibited. The only exception to this rule is if the life of a LIXIL member is imperiled.
・LIXIL members are not allowed to ask others to perform prohibited actions on their behalf. In addition, under the Global Policy on Anti-Corruption, third parties retained by LIXIL must agree to comply with anti-corruption laws.
・LIXIL requires that its books and records are accurate. No LIXIL member may make inaccurate, misleading, or incomplete entries in the books and records of a Group entity.
・LIXIL members are required to raise concerns if they suspect the Global Policy on Anti-Corruption has been or is at risk of being breached.
Training on the Global Policy on Anti-Corruption is provided across the Group.
*LIXIL members include both employees (including full-time, part-time, contract, fixed-term and all other employees) and officers (including directors and executive officers)
The LIXIL's Global Policy on Concern Raising guarantees confidentiality, clearly prohibits retaliation and sets out procedures to raise a concern. In accordance with the policy, we operate concern-raising processes globally to gather details of compliance violations, ensure early action on any wrongdoings and violations, and enable preventative measures.
A web-based third party concern-raising system is now available in 18 languages to all the employees around the globe. In addition, the system in Japan allows employees to report directly to management and compliance officers, and also provides a reporting structure with external lawyers serving as contacts for some of our Group companies, depending on the needs of each company.
Through either reporting channel, we ensure the confidentiality of the reported concerns and allow those making the report to stay anonymous. Appropriate actions are taken to ensure that individual submitting the report does not experience any retaliation as a result.
Through its corporate activities, LIXIL seeks to be a company that is widely trusted by society.
To support this objective, we welcome information from our external stakeholders such as suppliers and service providers on any potential compliance violations by the Group. By using LIXIL Compliance Hotline – Speak Up! and a law firm for activities in Japan to serve as the contact point to receive such information, we strive to take appropriate actions and prevent further violations.