In order to reinforce compliance, ADEKA Group made the following efforts during fiscal 2005.

1. Compliance Education and Training

♦ Stratified Training

(1)Training for Executives
In October 2005, a lecture, "Compliance Management" was held for executives and related personnel, given by a lawyer who is an external member of ADEKA Compliance Promotion Committee.
(2)Training for New Employees, Assistant Managers, and New Management Level Employees
Compliance training sessions were held for new employees in April 2005 and for assistant managers and new management level employees in May.

♦ Legal and Subject Specific Training

(1)Trade Regulation Seminar
In October 2005, a trade regulation seminar was held for executives and department managers of ADEKA Group. Such seminars are held annually.
(2)Antitrust Legislation Seminar
In October 2005, an antitrust legislation seminar was held for executives and department managers of ADEKA Group.
(3)Other
Various seminars and training on specific legislation, such as "Export Trade Control Ordinance" and "Chemical Substances Law (CSCL)" were held at the initiative of different divisions.

2. Reinforcement of Compliance System and Revision of Compliance Related Manuals

In order to further reinforce compliance system, we established the Operation Auditing Office under direct control of the president in the end of July 2005. Internal auditing on compliance with the law was carried out to all departments and our group companies.
Furthermore, guidelines and regulations were reviewed; such as the Action Charter, the Compliance Action Guideline, and Compliance Regulations, based on results of the attitude survey of compliance and amendment of related laws and regulations.
For example, technical changes were made following the corporate and organization name change. In addition, the contents of Compliance Action Guideline were enhanced, in line with the amendment of Antitrust Legislation, and the Personal Information Protection Law.
In the Action Charter brochure and poster, the e-mail address of a consultation service was clearly noted in order to keep everyone informed, as a response to problems that were brought up in the results of awareness survey on compliance, such as the difficulty of use and the low utilization of the internal consultation service.
As a part of reinforcement of the internal control system, coordination between the Operational Auditing Branch and the Compliance Promotion Committee was added to Group Compliance Regulations. Also, we enacted the new Internal Compliance Reporting Regulation to clarify internal notification obligation, reporting process procedures and reporting security rules for employees along with enforcement of the system of safeguards for those who disclose information in the public interest in April 2006.

3. Approach towards Personal Information Protection Law

In order to comply with the Personal Information Protection Law that was enacted in April 2005, ADEKA Group established an information protection committee as a subordinate body of the Compliance Promotion Committee. As for the safety management at the organization level, a Personal Information Protection Policy was established and various corporate regulations related to information protection were revised, such as the Personal Information Protection and Management Policy. Mr. Sakurai the legal and PR Director, and Director and Managing Operating Officer were elected as personal information managers.
Personal safety management at the personal level was approached with the promotion of training and increased awareness. Information safety was reinforced through strengthened entrance security checks by the personal authentication IC card introduced with the transfer to the new head office.

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