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Strengthened Competition Law Compliance System
1. Developed Competition Law Compliance Rules
In June 2010, new Competition Law Compliance Regulations, including rules that restrict contact with competitors, were
established and put into effect. While subsidiaries in Japan have implemented similar rules and regulations, key subsidiaries
outside of Japan have also adopted them and many other subsidiaries have been introducing them.
2. Formed Dedicated Organizations and Established Auditing System
In June 2010, Sumitomo Electric established a Competition Law Compliance Office in its Corporate Staff Group that is solely
dedicated to promoting compliance with competition laws. We also established a Sales Compliance Office in electric wirerelated
sales unit and assigned a Competition Law Compliance Promotion Manager and Promotion Leader at each of other
business units. In March 2011, we set up an Automotive Compliance Office in the Automotive Business Unit.
Under the Compliance Committee, the Competition Law Compliance Office closely collaborates with the dedicated
organizations or managers assigned at each unit that actually engages in businesses activities. By operating the rules to
restrict contact with competitors based on Competition Law Compliance Regulations and promoting related activities such
as monitoring and auditing of compliance with the Competition Law and Competition Law Regulations, we will establish an
effective system involving the front-line players.
The Sales Compliance Office and the Automotive Compliance Office have been set up in the respective business units
subject to the investigation by competition authorities. These offices promote more rigorous on-site measures, such as holding
periodical interviews on competition law compliance and monitoring the status of orders. Measures that have been proven
effective will be implemented in other business units.
3. Enhanced and Continuous Competition Law Training
Instead of the regular compliance training seminars for administrative members organized every year, special training programs
on compliance with competition laws were conducted intensively in spring of 2010 for all members of Sumitomo Electric and
its subsidiaries in Japan, excluding those working at manufacturing sites (81 sessions held in 40 locations nationwide for 5,000
participants in total).
The Company continues to raise employee awareness by providing compliance training sessions on a regular basis that
more strongly focus on competition law compliance issues.
4. Established Action Guidelines for Competition Law Compliance
Sumitomo Electric has been considering competition laws to be a priority matter to be observed in the Compliance Manual.
To more clearly specify prohibited conduct and rules of compliance and to also address foreign competition laws, new salesrelated
Competition Law Action Guidelines were established in October 2010. Training sessions were organized in October
and November 2010 to familiarize the guidelines to all employees involved in sales activities. Sumitomo Electric will continue to
make efforts to ensure compliance with these guidelines.
Annual Report 2012
SUMITOMO ELECTRIC
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