Ethics and Compliance

The Kureha Group recognizes compliance – the foundation for sustainability management that pursues sustainable development for society and the company – as a material issue in sustainability. In all aspects of corporate activities, the management and employees of our Group companies comply with domestic and international laws and regulations and conduct activities in line with social norms.

Goals and Vision

  • All employees and members of management comply with laws, regulations, and social norms, as well as the spirit of these, in the conduct of corporate activities, always acting in accord with social decency.

Fiscal Year 2022 Plan

  • Implement compliance education for employees.
  • Implement compliance education at Group companies.

Fiscal 2022 Performance and Outcomes

【Implement compliance education for employees】

  • Raised awareness of compliance by conducting introductory education for new hires, e-learning for new hires and newly promoted executives, etc.

【Implement compliance education at Group companies】

  • Raised awareness of compliance by selecting and implementing e-learning content matched to individual companies' circumstances and by conducting compliance education matched to individual companies' businesses.

Compliance Structure

The Kureha Group has established the Kureha Group Ethical Charter as its code of conduct for management and employees to follow, and has conducted its activities in line with social norms while complying with relevant domestic and international laws and regulations. In recent years, however, the business environment has undergone dizzying changes, as seen in globalization, technological innovation, and the adoption of the SDGs by the United Nations.
In response, in April 2023 we reviewed the Kureha Group Ethical Charter to encourage actions that take ESG (Environment, Society, Governance) aspects into consideration alongside conventional compliance matters, and established the Kureha Group Charter of Corporate Behavior, which seeks to achieve a sustainable society alongside sustainable growth for our Group.
Our Compliance Subcommittee, an organization under our Sustainability Coordination Committee, conducts training using a Compliance Handbook that contains the Compliance Code of Conduct to instill in all employees an awareness of the importance of compliance.
The Internal Audit Department, under the direct control of the President, evaluates and verifies the appropriateness and effectiveness of internal control structures, including compliance, in internal audits of the Group.

In fiscal 2022, there were no employee terminations due to non-compliance and no fines, penalties, or settlements related to corruption.

Initiatives for Compliance Education and Awareness Raising

Through compliance awareness surveys and information exchange meetings on the topics of incident response and education at Kureha and Group companies, the Kureha Group is making efforts to foster a compliance mindset at the Group level and to maintain and strengthen its compliance structure.

  • Compliance awareness surveys (including at Group companies)
  • Information exchange meetings on the topics of incident response and education at Kureha and Group companies
  • Education on security export control
  • Reviews of antitrust law compliance, personal information protection, etc.

Main Educational Initiatives (fiscal 2022)

Category (targeted persons) Content Number of participants
Introductory education (new hires) Compliance structure and whistleblowing system, explanation of items in the Group Ethical Charter, protection of personal information 65
Compliance education
(employees newly promoted to executives)
Compliance structure and whistleblowing system, mechanisms of fraud, initiatives related to antitrust law 20
e-learning (employees promoted to executives) Dai-Ichi Hoki Co., Ltd. "Introduction to Compliance for Working People" 20
e-learning (new hires, seconded employees) JMA Management Center Inc. "Basic Course on Corporate Ethics and Compliance" 73


The Kureha Group has established the Kureha Group Anti-Bribery Policy in order to promote efforts related to preventing bribery in business activities. Based on the policy, the Kureha Group engages in corporate activities in compliance with the laws and regulations in the countries and regions in which it operates its business.

Kureha Group Anti-Bribery Policy

The Kureha Group has set out engaging in appropriate transactions and maintaining sound relationships within the political and government sphere as one of the principles in the Kureha Group Charter of Corporate Behavior and has prohibited bribery in the Kureha Group Code of Conduct. This policy has been established with the objective of implementing and putting these principles into practice, and it applies to all Group officers and employees.

  1. Prohibition on Acts of Bribery
    The Kureha Group does not directly or indirectly provide, offer, or promise bribes to public officials, those in equivalent positions, or business partners in Japan or overseas. Moreover, the Kureha Group does not accept or request bribes or the promise of bribes from public officials, those in equivalent positions, or business partners in Japan or overseas.
  2. Prohibition on Bribery via Third Parties
    The Kureha Group does not give instructions to provide or accept bribes via third parties such as consultants or agents and does not condone bribes via such third parties when it is aware of actual bribery or indications of bribery.
  3. Education
    The Kureha Group provides regular training to officers, employees, and others to further reinforce awareness of ethics to prevent acts of bribery and to ensure the operation of systems to prevent bribery.
  4. System Verification and Review
    The Kureha Group verifies the functioning of systems to prevent bribery based on this policy through regular and irregular audits and makes revisions and improvements as necessary.
  5. Records
    The Kureha Group prepares accounting books and other records accurately based on facts and retains such records appropriately to enable compliance with this policy to be verified and demonstrated.
  6. Reports
    The Kureha Group requires its officers and employees to report any violations or suspicions of violations of this policy to their supervisor or the compliance hotline promptly to enable timely and appropriate action.
  7. Discipline
    The Kureha Group promptly takes appropriate disciplinary action in accordance with work regulations in the event that an officer, employee, or other related person violates this policy.

Established January 1, 2024

Kureha Corporation

Whistleblowing System

We also have a hotline-based whistleblowing system that employees can use if they discover a compliance problem, have a question, or are unsure of how to handle something. Compliance advice on product safety, human rights, the environment, health and safety, fair and free competition, and relations with politics, government, and society is also available through the hotline. Internal rules prohibit disadvantageous treatment of persons for reporting or consulting via the hotline.
To encourage use of the hotline, we have set up an external consultation desk staffed by attorneys and a special harassment desk staffed by female counselors. We have also introduced an in-house leniency program that lessens discipline taken against those who voluntarily report their own violations.

In fiscal 2022, 12 cases of whistleblowing occurred. Five cases were reported to the Board of Directors in light of their severity, and disciplinary action was enacted in accordance with internal regulations for cases that require disciplinary action.

  FY2019 FY2020 FY2021 FY2022
The number of reports* 2 10 6 12
  • *Includes domestic Group companies

Tax Compliance

Kureha has established the Kureha Group Tax Policy to ensure that the Group has a proper understanding of the tax-related laws and regulations, and the spirit thereof, in each country and region where the Group operates, and fulfills its tax obligations appropriately.
By ensuring transparency in taxation along with timely and appropriate payment of our tax obligations under this policy, we aim to contribute to economic and social development in every country and region where we operate.

Kureha Group Tax Policy

  1. Compliance
    The Group complies with the tax-related laws and regulations of the countries and regions in which it operates, appropriately utilizing preferential tax treatment and other benefits recognized under the tax laws of each country, and files and pays taxes accordingly, thereby contributing to the economies of those countries and regions, with the aim of fostering harmony and stable development together.
    In addition, in order to ensure tax accuracy, the Group will perform proper accounting in compliance with applicable statutes and regulations.
  2. Tax planning
    The Group will conduct fair and appropriate tax planning that reflects its business activities. In addition, we will comply with international rules on taxation and the laws and regulations of each country and region in which we operate, and strive to minimize tax risks.
    The Group does not engage in tax avoidance activities by using tax havens or by planning taxes in a manner that does not conform to its actual business situation.
  3. Initiatives to minimize tax risks
    Although the Group makes every effort to comply with the tax laws of each country in which it operates, there is a certain degree of possibility that the tax authorities in any such country may not understand the treatment that the Group deems appropriate.
    The Group will seek advice from external tax specialists when deemed necessary, and will fully investigate, evaluate, and consider multiple alternatives in order to make appropriate decisions. We believe that these measures will minimize the risk of tax litigation and additional taxation.
  4. International taxation
    1. Transfer pricing
      The Group believes that by distributing income internationally in accordance with the contributions of each Group company, appropriate tax payments will be implemented in each country and region. Based on this recognition, the Group applies a transfer pricing methodology based on function and risk analysis to determine the prices of transactions with foreign affiliates in accordance with relevant international regulations such as the OECD Transfer Pricing Guidelines.
      In order to reduce tax risks related to transfer pricing, the Group obtains advice from external experts and utilizes the Advance Pricing Agreement (APA) and other methods with tax authorities.
    2. Elimination of double taxation
      In the event that double taxation occurs on the same economic benefit in more than one country or region, the Group will endeavor to eliminate such double taxation through application of tax treaties or mutual consultation between countries.
  5. Relations with tax authorities
    The Group will respond in a timely manner to inquiries and requests for information from tax authorities and maintain good relationships with them.
    In addition, in order to reduce uncertainties associated with tax operations and ensure tax transparency, the Group will strive to provide tax treatments that can be reasonably explained, and to promptly resolve any differences of opinion with tax authorities in other countries that may arise.
    In addition, for items that have received guidance from the tax authorities in the past, measures will be taken to prevent recurrence of error.

Established June 2022

Kureha Corporation

Administration of Tax Matters

The Group ensures thoroughness in all activities and controls based on its tax policy.
There are no tax risk issues currently identified.

  • We conduct reasonable tax work in compliance with tax-related laws and regulations by following proper accounting practices and seeking advice from external specialists such as certified public tax accountants.
  • Duties related to tax work are carried out by the director in charge of the Accounting Department.
  • The Audit & Supervisory Board and its members audit the execution of duties by directors from an independent and objective standpoint.