Re: Investigations on Improper Payments to Foreign Agents and an Interim Report
Tokyo (May 23, 2008) - Since disclosing on February 12 this year incidents of improper monetary payments to foreign agents, all or a part of which may have been provided to foreign governmental officials, the CEO of Bridgestone Corporation, Mr. Shoshi Arakawa, has directed the continuation of an investigation through the Investigation Committee, which is made up of external attorneys (“the Committee”). Further, preventative measures have been adopted and enforced in order to prevent the reoccurrence of any improper payments. This week is approximately three months since making this announcement, and so we present an interim report from the Committee.
1. Investigation
Since the announcement on February 12, the Committee has conducted the investigation vigorously. However, the scope of this investigation is extensive, it includes some of our overseas subsidiaries, and the subject of this investigation has now expanded to the entirety of Industrial Products. Moreover, since the Committee needs to consider not only the Unfair Competition Act of Japan but regulations of other countries, this report is not a final report but remains an interim report.
In the course of the investigation, the Committee has discovered more questionable incidents. There have been some cases where further investigations were required and cases where suspicions were cleared up. However, the investigation is still ongoing and sufficient evidence to amend the number of incidents and the amount of improper payments reported previously has not been confirmed. The Committee has pointed out that both the number of incidents and the amount of improper payments are likely to increase especially as suspicious transactions have been found in other products as well as in other regions.
At the same time, we have worked in cooperation with the relevant authorities, reporting on the results of our investigation to the US Department of Justice and the Japanese Public Prosecutor's Office. We will continue to report on cartel issues pertaining to marine hose in connection with the current investigation as appropriate. As to agents where suspicions of improper activity has been identified, we are in the process of terminating or, where appropriate, reforming our relationships with these agents, to establish new sales channels that comply with Bridgestone's company policies and applicable laws.
2. Preventative Measures
We have also acted swiftly to adopt preventative measures regarding the making of improper payments, as announced on February 12 and detailed below:
We believe that we need to continue the investigation by the Committee. We will receive results of the investigation from the Committee and will announce when new important discoveries are reported. We will continue to fully cooperate with and report results to the relevant authorities about our Committee investigations.
1. Investigation
Since the announcement on February 12, the Committee has conducted the investigation vigorously. However, the scope of this investigation is extensive, it includes some of our overseas subsidiaries, and the subject of this investigation has now expanded to the entirety of Industrial Products. Moreover, since the Committee needs to consider not only the Unfair Competition Act of Japan but regulations of other countries, this report is not a final report but remains an interim report.
In the course of the investigation, the Committee has discovered more questionable incidents. There have been some cases where further investigations were required and cases where suspicions were cleared up. However, the investigation is still ongoing and sufficient evidence to amend the number of incidents and the amount of improper payments reported previously has not been confirmed. The Committee has pointed out that both the number of incidents and the amount of improper payments are likely to increase especially as suspicious transactions have been found in other products as well as in other regions.
At the same time, we have worked in cooperation with the relevant authorities, reporting on the results of our investigation to the US Department of Justice and the Japanese Public Prosecutor's Office. We will continue to report on cartel issues pertaining to marine hose in connection with the current investigation as appropriate. As to agents where suspicions of improper activity has been identified, we are in the process of terminating or, where appropriate, reforming our relationships with these agents, to establish new sales channels that comply with Bridgestone's company policies and applicable laws.
2. Preventative Measures
We have also acted swiftly to adopt preventative measures regarding the making of improper payments, as announced on February 12 and detailed below:
| (1) Withdrawal from Marine Hose Business | |
| We established a Marine Hose Business Withdrawal Project Team. The function of this team is to assist with the withdrawal from the marine hose business, and also answer customer queries. We are also carefully considering the potential harm that may be caused to customers and society as a result of the withdrawal. | |
| (2) Provision of Comprehensive Compliance Training | |
| We have been providing training and seminars focusing on compliance related to the present issue and competition laws, and giving high priority to issues including the export of Industrial Products. We are planning to provide such training to all relevant employees including those at our subsidiaries. | |
| In addition, we have held seminars for top management and will continue to hold them in the future as the leadership of top management is required to prevent re-occurrence of the same problem. | |
| (3) Strengthening Measures against Improper Acts | |
| We have reviewed our internal Retail Sales Calculation System, and set up a system that prevents the sales team from solely determining sales prices. We have also strengthened our head office's monitoring of commission payments made to agents by the sales subsidiaries in issue. Further, we have tightened our head office's surveillance of agents who have business relationships with our subsidiaries and are reviewing the businesses. | |
| (4) Corporate-wide Organisational Change and Tightening of Internal Controls | |
| We have dissolved the International Engineered Products Department (“IEPD”), which was in issue. The business operations of the Chemical and Industrial Products Division have also been consolidated. In addition, we have reinforced our management and audit system by establishing an Industrial Products and Construction Materials Business Administration Department and a CSR and Audit Unit. These will serve as internal mechanisms to strengthen the administrative, human resources and audit systems within each division and strengthen the management audit framework. Further, we have appointed a vice president and senior officer who is responsible for the diversified products business and for providing strengthened control over the Chemical and Industrial Products Division. | |
We believe that we need to continue the investigation by the Committee. We will receive results of the investigation from the Committee and will announce when new important discoveries are reported. We will continue to fully cooperate with and report results to the relevant authorities about our Committee investigations.