VALQUA, LTD.

VALQUA’s Policies

As a corporation that contributes to the development of industries and the improvement of people’s life, VALQUA requires high-level ethics of every group employee and, based on them, practices corporate activities.

Privacy Policy

VALQUA’s policy on personal information protection

Details

Disclosure Policy

VALQUA’s policy on information disclosure

Details

Compliance Manual

VALQUA’s basic policy on compliance

Details

Charter for SHE

VALQUA group’s charter established on Safety-health-Environment

Details

Privacy Policy

VALQUA LTD. (hereinafter referred to as “VALQUA”) recognizes the importance of personal information and considers the proper handling of personal information to be an important responsibility. In order to fulfil that responsibility, VALQUA has established the following privacy policy, and we comply with this policy and our rules on the handling of personal information.

Article 1 (Personal Information)

“Personal information” denotes “personal information” as defined in the Act on the Protection of Personal Information (Act No. 57 of 2003, hereinafter referred to as the “Personal Information Protection Act”); i.e., it is information on a living individual that can identify the specific individual by name, date of birth, or other descriptors contained in the information, or includes an individual identification code.

Article 2 (Obtaining and Using Personal Information)

VALQUA obtains personal information and uses the information it obtains for the following purposes within the necessary scope. When using personal information beyond the scope of the following purposes, VALQUA shall obtain consent from the person involved in advance by an appropriate method.

  1. To provide VALQUA or VALQUA Group products and services
  2. To improve or enhance VALQUA or VALQUA Group products and services
  3. To provide or propose information on VALQUA or VALQUA Group products and services
  4. To respond to inquiries or requests for information submitted to VALQUA or the VALQUA Group
  5. To accomplish tasks related to or ancillary to the aforementioned operations
Article 3 (Management and Protection of Personal Information)

Personal information shall be strictly managed, and except in the following situations, VALQUA will never disclose or provide data to a third party without the consent of the person involved. With consideration for safety, we will have devised measures for preventing and correcting the risk of unauthorized access to personal information and the loss, destruction, falsification, or leakage, etc. of personal information.

Exceptions:

  1. When disclosure is necessary in order to protect human life, limb, or property, and it would be difficult to obtain the consent of the person involved
  2. When disclosure is particularly necessary in order to improve public health or promote the sound development of children, and it would be difficult to obtain the consent of the person involved
  3. When it is necessary to cooperate with an agency of the national government, a local public organization, or a party commissioned to act on their behalf in the execution of affairs prescribed by law, and obtaining the consent of the person involved could interfere with the execution of those affairs
  4. When all or part of the handling of personal information has been outsourced within the scope necessary to achieve the purpose of use, in order that business might be executed smoothly
  5. When provision of personal information has accompanied business succession through a merger or for other reason
  6. When personal information is jointly utilized with a specific party, and the person involved has been notified in advance of this fact, as well as of the items of personal information that are jointly utilized, the scope of the parties that jointly utilize the information, the purpose of utilization by said parties, and the name of the party responsible for the management of the personal information, or this information has been made readily available to the person involved
  7. As otherwise permitted by law
Article 4 (Outsourcing of the Handling of Personal Information)

VALQUA may outsource all or part of the handling of personal information within the scope necessary to achieve the purpose of use. In such cases, VALQUA will thoroughly review the qualifications of the contractor, establish a confidentiality obligation in the contract with the contractor, and supervise the contractor as necessary and appropriate.

Article 5 (Joint Use of Personal Information)

VALQUA may engage in joint use of the personal information entrusted to it for the following purposes within the scope necessary to achieve the purpose of use.

    < Purposes of joint use >

  • Same as purposes of use stated above (items of Article 2)
  • < Scope of jointly used personal information >

  • All personal information on the person involved, except as specially requested by the person involved
  • < Scope of parties jointly utilizing personal information >

  • VALQUA, LTD. and its subsidiaries and affiliates
  • < Party responsible for the management of personal information >

  • VALQUA, LTD. (For details about the company, see “Corporate Information”)
Article 6. (Disclosure of Personal Information)

When asked to disclose personal information by the person involved, VALQUA will disclose the information to the said person without delay. However, if any of the following apply to the disclosure of the information, VALQUA may refrain from disclosing all or part of the information. When a decision to refrain from disclosing personal information has been made, VALQUA will notify the person involved of that decision without delay.

  1. If there is a risk that disclosure could harm the life, limb, property, or other rights and interests of the person involved or a third party
  2. If there is a risk that disclosure could seriously interfere with the proper execution of company business
  3. In other cases where disclosure would violate the law
Article 7 (Correction and Deletion of Personal Information)
  • If the personal information in VALQUA’s possession is incorrect, the said personal information can be corrected or deleted at the request of the person involved, according to the procedure established by VALQUA.
  • Upon receiving such a request from the person involved, VALQUA will consider the request, and if granting the request is judged to be necessary, VALQUA will correct or delete the said personal information without delay and notify the person involved to that effect.
Article 8 (Suspension of Use of Personal Information, Etc.)

In the following cases, VALQUA will, upon being requested by the person involved to suspend or eliminate the user of personal information (hereinafter referred to as “suspension of use, etc.”), perform the necessary investigation without delay and, depending on the results, may suspend the use of personal information, etc. in accordance with the law, and notify the person involved to that effect. However, VALQUA may devise an alternative measure in cases where suspension, etc. of the use of personal information would be difficult because it involves great expense or for other reason, and it is possible to take an alternative measure that is necessary in order to protect the rights and interests of the person involved.

  1. If handling of information has not been within the scope of the purpose of use
  2. If the personal information was obtained through wrongful means
  3. If the personal information has been used by methods that could foster or induce illegal or unjust acts
  4. If VALQUA no longer needs to use the personal information of the person involved
  5. If personal information that includes sensitive information has been or could have been leaked, lost, or damaged (hereinafter referred to as “leakage, etc.”)
  6. If there has been leakage, etc. or potential leakage, etc. of personal information such that its unauthorized use could result in property damage.
  7. If there has been leakage, etc. or potential leakage, etc. of personal information that could have been used for unauthorized purposes
  8. If there has been leakage, etc. or potential leakage, etc. of personal information on a scale involving more than a thousand persons
  9. If there is a risk that the rights or the just and proper interests of the person involved have been violated through the handling of the said personal information
Article 9 (Procedures for Changing the Privacy Policy)

VALQUA will strive to review and improve the content of this Policy as necessary. The content of this Policy will be subject to change except as expressly stipulated by law or elsewhere in this Policy. Stakeholders will be notified of the amended Privacy Policy by VALQUA’s stipulated methods or by posting on the VALQUA website, and the amended Privacy Policy shall take effect as of the time of notification or posting.

Article 10 (Compliance with Laws and Norms)

VALQUA will comply with Japanese laws, ordinances, and other codes or norms that apply to the personal information in its possession.

Article 11 (Handling of Complaints and Consultations)

VALQUA will accept and promptly and appropriately respond to complaints or requests for consultation regarding the handling of personal information that are received from the person involved. Moreover, VALQUA will promptly and appropriately respond to requests for disclosure, correction, addition, deletion, and refusal of utilization or provision of the said personal information that are received from the person involved.

Article 12 (Security Control Measures)

VALQUA takes steps to prevent unauthorized access to personal information and the loss, destruction, falsification, and leakage, etc. of personal information by imposing access restrictions on personal information files and taking organizational, physical, human, and technological measures to create records of access logs and prevent unauthorized access from outside parties. In the unlikely event of leakage, etc. of personal information, VALQUA will promptly report the incident to the competent authorities in accordance with the Personal Information Protection Act and the related guidelines and also take the necessary measures, etc. to prevent recurrence and prevent similar incidents from occurring.

Article 13 (Where to Address Inquiries)

If you wish to request corrected disclosure, correction, suspension of use, or deletion, etc. of your own personal information, or if you wish to submit an inquiry or complaint about the handling of personal information at VALQUA, click here.

Disclosure Policy

VALQUA has established its Disclosure Policy described below. VALQUA makes efforts to infiltrate the policy into the entire group and to provide the stockholders and investors with accurate information in a fair and timely manner.

1. Criteria of disclosure

When disclosing information, VALQUA complies with Securities Exchange Law and “Rules on Timely Disclosure of Company Information by Issuers of Listed Securities” (referred to as “Disclosure Rules”) laid down by Tokyo Stock Exchange. VALQUA may disclose such information that is not defined by the Disclosure Rules as information to be timely disclosed, provided that VALQUA deems that the information should be disclosed. Disclosure of the information is made in a fair manner on the Web site or by any other suitable means.

2. Method of disclosure

When disclosing information to which the Disclosure Rules apply, VALQUA publishes such information on the Timely Disclosure network (TDnet) provided by Tokyo Stock Exchange, in compliance with the provisions of the Disclosure Rules. Although information published on the TDnet is posted also on the VALQUA’s Web site promptly, this can be significantly later than the publication on the TDnet for a reason of the system. It should also be noted that not all information published on the TDnet is posted on the VALQUA’s Web site.

3. Forecast of business results

VALQUA makes efforts to increase the accuracy of forecasting business results and, whenever any change in forecast arises, the change will be promptly disclosed. It should be noted, however, that disclosed information is worked out on the basis of data available at that time, and actual results may differ from the disclosed information, affected by various factors. VALQUA is not liable for any damages that may occur on the basis of disclosed information.

4. Quiet period

Although VALQUA defines the period from the date of quarterly, interim or annual settlement to the date of its announcement as the “quiet period” (self-restraint IR period), VALQUA restrains itself from making comments or response about the content of settlement, results or forecast of business to particular stockholders, investors or the press. However, in case any discrepancies exist between the disclosed forecast of settlement and updated forecast of settlement is found during the mentioned period, VALQUA according to the Disclosure Rules, discloses the information as revised settlement forecast.

Compliance Manual

VALQUA worked out the Compliance Manual in April 2003 as the guideline for compliance management (law-abiding management).

Basic stance

Compliance management (law-abiding corporate management) refers to as the execution of work, observing inside and outside rules surrounding the company, such as laws, ordinances, and in-house regulations while conducting corporate management. Compliance management is Code of Conduct or ethics that must be followed by responsible companies acting as members of society.

Compliance system

In order to work out a basic policy of compliance and to supervise management, VALQUA has organized standing Compliance Committee, involving directors. Under the Compliance Committee is operating Compliance Promoting Committee composed of managers of major divisions to work out compliance rules, to plan enlightenment and education, and to promote compliance activities.

Distribution of Compliance Manual (booklet)

Each VALQUA group member receives Compliance Manual (booklet) as a guideline for work execution, and is guided and enlightened on compliance.

Contents of Compliance Manual

Compliance Manual (booklet) is composed of (1) manual on general matters such as environmental preservation and proper use of information systems; (2) sales activities manual on observance of anticompetitive act, export and trade control, specified chemical substance control, etc.; (3) manual on workplace environment, such as sexual harassment; and (4) manual on private actions such as insider dealing and interest conflict actions. The entire manual outlines individual items, referring to instances that should be avoided.

Enlightenment and education

The Compliance Manual (booklet) is distributed to newly employed members. Enlightenment and education activities on law-abiding corporate management are carried out, utilizing in-house training and other occasions.

Charter for SHE

SHE Philosophy

Based on The Valqua Way, we recognize that safety, health, and the environmental are among the key topics shared by humanity and consider all aspects of company activities.

SHE Action

Based on the SHE philosophy, the following behavioral guidelines will be established, and activities will be addressed together as a single group consisting of each individual’s self-awareness and responsibility.

1.

Hold a SHE Conference to raise awareness of safety, health, and the environment, and make it the starting point for accident-free, health maintenance, and environmental conservation activities.

2.

Improve continuously by strengthening and maintaining and improving the safety, hygiene, and environment-related management systems, acting in a planned manner, and reviewing them.

3.

Comply with all laws, regulations, conventions, agreements, internal rules, and voluntary standards both domestic and abroad, and make prompt and appropriate improvements with awareness.

4.

Improve understanding and awareness of safety, health, and the environment through educational training, and strive to reduce risk.

5.

Cooperate with other industries and society to create products and provide services that take into consideration health, safety, and the environment.

6.

Strive for mutual understanding among all stakeholders, including employees, by disclosing the objectives and results of SHE activities.

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