The AGC Group is committed to increasing the fairness and transparency of its business operations, regarding strict compliance as the basis for Our Shared Value, Integrity, and as a premise for its sustainability as a corporate citizen.

Global Compliance System

In order to make all employees of the AGC Group aware of the importance of compliance, we have implemented compliance programs as important components of the global compliance system, which is shown in Fig. 1. Furthermore, we periodically collect compliance-related information in order to utilize it for strengthening our compliance programs and monitoring activities. The collected information, which is reported to the Board of Directors and the CSR Committee, is also shared with the In-house Companies and SBUs.
Any serious noncompliance is to be promptly reported to management through the compliance reporting system so that appropriate countermeasures can be taken in a timely manner.

Global Compliance System

A system to plan, formulate, implement, and monitor compliance programs in the AGC Group

*1 Strategic Business Units (SBUs)

Topic
Global Compliance Meeting

Discussing global measures through regular meetings with top management

In order to foster compliance across the Group, the AGC Group has been holding a global compliance meeting semiannually (middle and end of the fiscal year) since 2005. In the first meeting, the members of the secretariats of the Japan/Asia, European, and North American Compliance Committees gather to report and discuss Group-wide measures and the progress of local measures. In the second meeting which the Global Compliance Leader also attends, the Leader reviews the implemented measures and approves plans for the following fiscal year.

Code of Conduct

The AGC Group Code of Conduct applies to all Group companies and is at the heart of all efforts to achieve the goal of permeating the value of Integrity across the Group.
The AGC Group Code of Conduct is composed of a set of common fundamental global principles that all Group companies and employees must follow and regional supplements that apply to individual regions. Each regional supplement includes explanations about the differences in laws and commercial customs of the various countries that are within that region. All regional supplements are entirely consistent with the Code of Conduct's common fundamental global principles.
We hold briefing sessions and provide necessary training, such as online training, to educate all employees about the AGC Group Code of Conduct and their obligations to comply with it.

Items for the global common part

Compliance education provided in fiscal 2010 (AGC Group)

Compliance activities in Asia

Topic
Strengthening the Compliance Network beyond National Boundaries through a Compliance Meeting of Group Companies Operating in Three Countries (Southeast Asia)

AGC Group companies in Asia hold an annual meeting of compliance managers in their respective countries. In 2010, Group companies in Thailand, Indonesia, and the Philippines held their first joint meeting at AGC Flat Glass (Thailand) Public. At the meeting, participants were briefed on the AGC Group's compliance policies. They also shared information about the measures implemented by each Group company and mutually gave advice on compliance issues. Through these proactive exchanges, Group companies in the three countries have established an exchange network beyond national boundaries. Participants commented that the meeting provided them with a great opportunity to share various information and ideas, which they would utilize to improve their workplaces in their home countries. The companies will further promote and enhance compliance by the use of this network.

The joint meeting held in Thailand	Participants in the joint meeting of compliance managers

Voice
Spreading compliance through dialogue

Masahiro Teraoka
Legal compliance group leader
Business Administration office
AGC Electronics Company

AGC Electronics Company considers the PDCA cycle for boosting compliance awareness to be planning ("Plan"), education ("Do"), audit ("Check"), and dialogue ("Check" and "Action"). Since fiscal 2009, the company has been hosting a "compliance dialogue." In fiscal 2010, we held this educational meeting focusing on the "prohibition of information leakage and data falsification" as the main theme and on "respecting human rights" as the subtheme jointly with Group companies which belong to the electronics general division and newly established companies of the Electronics Company. We also provided Group companies in Thailand, Singapore, and Taiwan with education on information security. By conducting the PDCA cycle, we hope to continue conducting these activities so that compliance awareness will take root throughout the AGC Electronics Company in Japan, Taiwan, South Korea, and Thailand.

Topic
Measures Implemented in AGC Group Companies in Thailand and China

Compliance poster

Initiative in Thailand

In Thailand, seven AGC Group companies jointly created a poster to increase the awareness of the AGC Group Code of Conduct among their employees. The copies of the poster are posted in the workplaces of the companies.

One of the CP-News articles published in 2010

Initiative in China

AGC Group companies in China jointly create and publish a news article on compliance titled "CP-News" on a quarterly basis.

Compliance activities in Europe

Voice
We Contribute to a Culture of Ethical Behavior

Michel Charles
Vice-President, CSR & Legal Affairs
AGC Glass Europe
Member of the European Compliance Committee

The European Compliance Committee aims to develop a culture of ethical behavior and to play an active role in the AGC Group's global compliance organization, in cooperation with the CSR Office newly established within AGC Glass Europe. Among the main initiatives taken in 2010, we developed an e-training course in compliance for white-collar workers throughout Europe which is available in 10 languages. This program turned out to be very popular since it deals with compliance as the important issue in the accessible form such as using cartoon. In addition, we pursued our antitrust training program, which in 2010 was aimed in particular at all newcomers and professionals involved in the automotive glass business. We also provided the newly hired managers with a compliance program as an integral part of the introduction education.
Finally, in addition to further developing a KPI (Key Performance Indicator) for compliance, we expect to share our recent "Conflict of Interest" policy and our new European procedure for handling cases on a global basis.

Topic
Conducting the compliance education for all European shop floor

Compliance education for shop floor

Following its compliance e-learning for white collar, AGC Glass Europe (AGEU), which manufactures and sells raw float glass and processed glass for the construction, automotive and solar industries, conducted the training for shop floor such as briefing on the Code of Conduct in every European country where there are AGEU bases. However, the training process varies from country to country, as attested by the cases of Italy and Hungary.
In Italy, all the shop floor receives the relevant summary of the Group Code of Conduct. They are then asked to fill in a questionnaire and sign it for checking their comprehension of the Code. In the automotive glass factory in Tatabanya, Hungary, shop floor sign a record sheet to demonstrate their understanding of the Compliance education for shop floor Code and commitment on it after classroom training by the specialized staff.
In early 2010, AGEU aims to establish the standard compliance training basis for all shop floor, whatever the country in order to spread the shared compliance culture throughout the organization.

Compliance activities in North America

Topic
Topic�FFocusing on Adherence to U.S. Government Guidelines for Compliance Programs (United States)

Members of the project team

In the U.S., there are government guidelines urging companies operating in the U.S. to conduct compliance activities. These guidelines are based on the principle that if companies have comprehensive and effective compliance programs, they are far less likely to violate criminal laws such as antitrust and anti-bribery laws. One requirement of these guidelines is that companies have a compliance risk assessment and risk management system. For about ten years, the AGC Group (North America) has had such a risk assessment/management system in its compliance program. This year the AGC North America Compliance Committee has established a project team to assure that the region's risk assessment/management system will meet the guidelines' requirements for the future. Already this team has begun leading an initiative designed to achieve this goal.

Compliance Certification

The AGC Group has a program whereby employees submit certifications of compliance with the Code of Conduct on a regular basis.
This program is designed to encourage employees to renew their recognition of the importance of compliance and to review their companies' operations and workplaces for adherence to compliance requirements. In the future, we aim to collect compliance certifications from all Group employees.
In fiscal 2010, a new system which combines training and submission of certifications was launched in North America. As a result, the percentage of employees who submitted certifications increased to 99% from 27% in fiscal 2009. Accordingly, approximately 37,900 employees, or 75% of all group employees, submitted compliance certifications, whereas 32,700 employees, or 68%, did so in fiscal 2009. At Asahi Glass, all employees, including part-timers, submitted certifications.

Compliance Help Lines

The AGC Group's Help Lines, which we have in place to enhance our entire compliance program in Asia including Japan, Europe and North America, serve as contact points allowing employees to report and make inquiries regarding compliance-related issues. We are committed to protecting the anonymity of those contacting the Help Lines. We strictly prohibit acts of retaliation against persons who in good faith use the Help Lines.
We also encourage employees to make contacts to the Help Lines using their own names so that we can contact them for more information and are able to provide feedback to them as appropriate.
In fiscal 2010, the Help Lines received a total of 614 calls from employees of the AGC Group, 58 of which were made to the regional Helpline in Japan. We have regional Help Lines in Japan, South Korea, and Taiwan, as well as in Europe, North America, and China.

Help Line Reporting Route (Asahi Glass)

* When the whistle blower isn't anonymous, They are given feedback of the result and process.

Stakeholder Dialogue

In January 2008, we exchanged opinions with our stakeholders on the challenges and targets to be met to enable the Group to share the concept of compliance and promote an appropriate corporate culture on a global scale.

• Stakeholder Dialogue 3rd: Compliance