To prevent the misuse of research funds obtained through competitive bids as well as other research funds from public sources (hereafter, “public research funds”), or in any R&D activities carried out with public funds (hereafter, “R&D activities”), Seiko Group Corporation (hereafter, “the Company”) has established the following basic policies:
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To ensure the proper management of public research funds and the promotion of proper R&D activities, the Company shall appoint the following personnel as responsible officers.
Chief Executive Officer President Presides over the whole company and takes ultimate responsibility for the operation and management of all R&D activities using public funds General Manager Director in charge of the Research and Development Dept. Assists the Chief Executive Officer and has substantial responsibility and authority throughout the company pertaining to measures for preventing and responding to fraud or misuse of public research funds Compliance Promotion Officer Head of top-level group within the Research and Development Dept. Has substantial responsibility and authority for the implementation of prevention measures and direction of improvements for the proper management of public research funds and proper R&D activities within the Company’s Research and Development Department. Deputy Compliance Promotion Officer Head of the Research and Development Dept. Assists the Compliance Promotion Officer -
The Company shall clearly specify the duties, authority, and rules pertaining to administrative processing of public research funds and re-evaluate them as necessary in order to ensure clear and uniform operation. The Company shall inform all executives and staff (including temporary transfer employees, contract employees, commissioned employees, part-time employees, and temporary employees; hereafter, “staff”) about the rules pertaining to the management of public research funds.
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To prevent the misuse of funds and promote proper R&D activities, the Company shall conduct research ethics training for all executives and staff involved in R&D activities.
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The Company shall take steps to understand the causes of misuse of funds and develop and implement prevention plans. Based on those prevention plans, the Company shall establish a system to properly carry out budgeting and allocation of funds.
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The Company shall establish an effective monitoring system in order to minimize the risk of misuse of funds. In addition, the Company shall analyze the causes of such improper use of funds, perform risk-approach auditing, and constantly expand and strengthen its system of organizational checks.
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The Company shall establish an office to provide advice about the rules pertaining to the use of public research funds and to receive information from both inside and outside the firm regarding suspected misuse of funds. (*Currently, this service is only available in Japanese.)
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In the event that the Company discovers any kind of misuse of public research funds, it shall immediately report same to the relevant ministries, investigate the cause, and take steps to prevent any recurrence. If Company executives or staff are found to be involved in this behavior, the firm will take strict disciplinary action against them; if a business partner is found to be involved, the Company shall suspend business dealings with that partner and take other measures as deemed appropriate.
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