京都大学 根拠資料３－２－Ｂ－２

Kyoto University Compliance Guidebook 京都大学 根拠資料３－２－Ｂ－２

Kyoto Univer Compliance G

Contents

1 Message from the President 1 12 Main areas of compliance at the university

2 Kyoto University’s Mission Statement 2 1 Duties (dedication to work, concurrent employment, etc.) 6

3 Qualities Required of Faculty and Staff Members 2 Ethics (interested parties, bribery, etc.) 7 at Kyoto University 3 3 Wrongful Receipt of Allowances 8 4 Who are Quasi-Public Servants? 3 4 Harassment 9 5 The WINDOW Concept 4 5 Respect for Human Rights and the Prohibition of Discrimination 10 6 The 3rd Medium-Term Goals and Plans 4 6 Public Relations Ethics 11 7 Kyoto University’s Basic Policy against Antisocial Forces 4 7 Appropriate Handling of Personal Information 12 8 What is Compliance? 5 8 Prevention of Information Security Incidents 13 9 Why is Compliance Important? 5 9 Appropriate Rating and Handling of Information 14 10 Maintaining Compliance 5 10 Research Misconduct (fabrication, falsification, and plagiarism) 15 11 The Consequences of Compliance Violations 5 京都大学 根拠資料３－２－Ｂ－２ rsity Guidebook

13 University Regulations and Guidelines Relating to Compliance 33

Illegal11 or Inappropriate Use of Research Funds 17 14 University Guidebooks and Other Materials Relating to Compliance 35 Appropriate12 Response to Conflicts of Interest in Industry- Government-Academia Collaboration Activities 19 15 Organizational Chart: Compliance at Kyoto University 36 Acts13 Causing Financial Damage to the University Consultation about Compliance and Where to Report (Prohibition of Breach of Trust) 20 16 Compliance Related Matters at Kyoto University 37 14 Maintaining Ethics and Safety in Life Sciences and Other Research 21 Security15 Export Control 23 Fire16 Prevention and Control 24 What17 to Do in the Event of an Earthquake 25 18 Handling of Chemical Materials (poisonous and deleterious substances, etc.) 27 19 Use of Radioactive Materials (radioisotopes, x-ray devices, nuclear fuels, etc.) 29 Occupational20 Safety and Health 31 Management21 and Disposal Regulated by Environmental Laws (effluent, waste, etc.) 32 京都大学 根拠資料３－２－Ｂ－２

1 Message from the President

Since its foundation, Kyoto University has sought to cultivate a spirit of autonomy, independence, and creativity through its philosophy of academic freedom based on frank and open dialogue. It has pursued excellence in higher education and cutting-edge academic research with the ultimate aim of tackling complex global problems and contributing to peaceful co-existence within the Earth’s human and ecological community. In these times, we have a growing responsibility to foster the capabilities of aspiring scholars from Japan and around the world to gain international competence, pursue diverse research, and share the findings of that research as the common property of all humanity. Kyoto University also has a profound responsibility to society as a national university corporation and a public institution. Considering the social responsibility entailed in our education, research, and medical services, the university’s compliance with laws and regulations is a necessity, and we must ensure that we never allow any violations. In order to ensure fair and equitable university operation and maintain society’s confidence, all executive officers, faculty, and staff members who work for the university must observe all applicable laws and university regulations regardless of their type of employment or status. In recent years, however, various compliance violations at universities have been reported by the Japanese media, including, unfortunately, several that were found at Kyoto University. “Stronger compliance” is one of the strategic priorities included in The WINDOW Concept, a set of goals and guidelines formulated to guide Kyoto University during its current phase. It emphasizes the university’s efforts as follows: “In order to maintain a sound ethical sense among our students, faculty, and staff, and in order to maintain and increase society’s confidence in the university, we will employ a comprehensive framework to enhance compliance education and awareness of compliance responsibilities. We will also develop the university’s systems and infrastructure with an emphasis on risk management and preventative measures.” In line with that strategic priority, The Kyoto University Compliance Guidebook was developed to raise awareness of compliance, prevent the occurrence of any compliance violations, and provide specific guidelines that our faculty and staff members can refer to when necessary. We hope that each of our faculty and staff members will keep this compliance guidebook at hand, and use it to protect the university and themselves from compliance-related risks. If you have any doubts or questions, please do not ignore them, but take appropriate action, such as talking to your superiors or colleagues, or contacting the appropriate division or consultation services within the university. Finally, I would like to ask you to reconfirm your own obligations as a faculty or staff member of Kyoto University, and increase your own awareness of compliance to ensure that you are not involved in any actual or suspected acts of noncompliance with laws or regulations.

Juichi Yamagiwa President, Kyoto University

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2 Kyoto University’s Mission Statement (December 4, 2001)

Kyoto University states its mission to sustain and develop its historical commitment to academic freedom and to pursue harmonious coexistence within the human and ecological community on this planet.

【 Research 】 1. Kyoto University will generate world-class knowledge through freedom and autonomy in research that conforms with high ethical standards. 2. As a university that comprehends many graduate schools, faculties, research institutes and centers, Kyoto University will strive for diverse development in pure and applied research in the humanities, sciences and technology, while seeking to integrate these various perspectives.

【 Education 】 3. Within its broad and varied educational structure, Kyoto University will transmit high-quality knowledge and promote independent and interactive learning. 4. Kyoto University will educate outstanding and humane researchers and specialists, who will contribute responsibly to the world’s human and ecological community.

【 Relationship with Society 】 5. As a university committed to a broad social engagement, Kyoto University will encourage cooperation with local and national society, and will disseminate knowledge informed by the ideals of freedom and peaceful coexistence. 6. As an international institution, Kyoto University will promote foreign academic exchange and thereby strive to contribute to the well-being of the world.

【 Administration 】 7. In order to enhance the free development of learning, Kyoto University will pay due respect to the administrative independence of each of its component institutions, while promoting cooperation among them. 8. Kyoto University will conduct its administration with regard for the environment and respect for human rights and will be accountable to society at large.

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3 Qualities Required of Faculty and Staff Members at Kyoto University (July 20, 2004)

Kyoto University’s faculty and staff members are required to be aware of their duties with regards to education, research, support services, and administration at the university and in its departments, and they must endeavor to fulfill their duties to realize the university’s vision and attain the goals of its mission. Faculty and staff members are expected to make their best efforts to promote the highest possible level of education and research. They must respect academic freedom, the most essential prerequisite for achieving the above objectives, in every aspect of education and research, and with due consideration of social norms and ethics. As education is the process of transmitting knowledge and culture, and developing students’ abilities and personalities, faculty and staff members involved in education must not discriminate on the basis of sex, ethnicity, religion, or other such factors. As research is the process of developing knowledge and culture, and contributing to the accumulation of intellectual assets, faculty and staff members must promote the advancement of research with a high standard of ethics and morals. The work of supporting education and research and the management of the university and its departments is vital to their sustainable development. Faculty and staff members are required to be aware of the university’s social responsibilities, pursue personal-development to fulfill their duties with a high-level of expertise and a comprehensive perspective, and help strengthen the infrastructure for education and research, and assist in the smooth operation and development of the university and its departments.

4 Who are Quasi-Public Servants?

Kyoto University’s faculty and staff members must comply with the regulations regarding employment, duties, and other working conditions, including the Kyoto University Work Rules for Faculty and Staff and the regulations regarding compliance to ensure that they are applied rigorously and appropriately. Article 19 of the National University Corporation Act stipulates that “the officials and employees of a national university corporation are considered employees who engage in official businesses by law, with respect to the application of the penal code and other penal regulations.” As national university faculty and staff members are treated as “quasi-public servants,” the crimes of bribery, abuse of power, and making false official documents apply to national university faculty and staff members in the same way as they do to public servants. At Kyoto University, there have been several instances in the past in which faculty members were arrested for bribery.

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5 The WINDOW Concept

Strategic Priority 3-3: Stronger Compliance In order to maintain a sound ethical sense among our students, faculty, and staff, and in order to maintain and increase society’s confidence in the university, we will employ a comprehensive framework to enhance compliance education and awareness of compliance responsibilities. We will also develop the university’s systems and infrastructure with an emphasis on risk management and preventative measures.

6 The 3rd Medium-Term Goals and Plans

Medium-term goal [54]: We will implement appropriate university administration that conforms to laws and regulations to ensure compliance. Medium-term goal [75]: We will ensure a thorough awareness and understanding regarding compliance with laws and internal regulations by providing diverse training for faculty, staff, and students, including workshops and e-learning programs, and by publicizing the results of audits.

7 Kyoto University’s Basic Policy against Antisocial Forces

In Japan, the term “antisocial forces” is used to refer to individuals or groups who endeavor to profit through the use of force, violence, threats, or dishonest or fraudulent activities. National University Corporation Kyoto University has established the following Basic Policy against Antisocial Forces to ensure that the university develops no relationships with antisocial forces that pose a threat to social order and safety, or prevent healthy social and economic development.

1. The university shall take an organized and institutional approach to any unreasonable demands from antisocial forces, and ensure the safety of its students, faculty, staff, and executive officers from the dangers presented by such forces. 2. The university shall not have any relationships, including business transactions, with antisocial forces, and shall resolutely reject any unreasonable demands from them. 3. In order to be prepared for the possibility of unreasonable demands from antisocial forces, the university shall work closely with external specialist organizations, including the police, lawyers, and the National Center for Removal of Criminal Organizations. 4. The university shall take a firm stance against unreasonable demands from antisocial forces, and shall take legal action under both civil and criminal codes as necessary. 5. The university shall never engage in backdoor deals or provide funding to antisocial forces for any reason, including cases in which the reason is to cover up facts regarding misconduct by the university, its students, faculty, staff, or executive officers.

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8 What is Compliance?

● Compliance is the act of complying with laws, university regulations, codes of ethics regarding education, research, and medical practice, and other standards of conduct. ● Compliance is an obligation to be fulfilled by all executive officers, faculty, and staff members of the university. ● Ensuring and maintaining compliance is of great importance, particularly for Kyoto University as public funding is one if its main financial resources. ● Compliance cannot be ensured without the commitment of each and every executive officer, faculty, and staff member.

9 Why is Compliance Important?

● By ensuring and maintaining compliance, the university is able to be accountable to society, implement fair university administration, and maintain the trust of society. ● Compliance-conscious organizations are highly valued in all fields, both in Japan and in other countries. ● Compliance enables the university to provide a stable environment for education, research, and medical practice.

10 Maintaining Compliance

● Carry out duties fairly and impartially. ● Assure transparency of operations. ● Maintain accountability. ● Protect personal information and fulfill the confidentiality obligations. ● Create and manage official documents appropriately. ● Comply with the laws and the university’s regulations. ● Maintain good communication in the work environment and operate systematically.

11 The Consequences of Compliance Violations

● Disciplinary action: Incidence of noncompliance recorded in the perpetrator’s personnel record and reported to the media. ● Negative impact on research: Termination of research funding, suspension of eligibility to apply for funding, obligation to return research funds, etc. ● Negative impact on income: Reduction or loss of salary, bonus, retirement allowance, and other benefits. ● Legal action: Criminal penalty, administrative (government) penalty, and civil action (including damages lawsuits). ● Negative social impact: Loss of social trust in the university, and reduction or loss of financial support.

COMPLIANCE 5 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２ Main areas of compliance at the university

12-1 Duties (dedication to work, concurrent employment, etc.)

Duties are defined as the obligations to be fulfilled by the university’s faculty and staff members in accordance with its rules and regulations. Faculty and staff members must not violate any obligation of good faith, dedication to work, discipline in the workplace, or compliance stipulated in the university’s work regulations. Employees are not allowed to be concurrently employed or hold a side job without permission. Even if permitted to hold such an additional position, they must handle that work separately from their duties at the university, and must not use the university’s facilities or equipment for work related to the concurrent employment.

Compliance obligations 1. Faculty and staff members are obliged to understand the responsibilities entailed in their work, fulfill their duties reasonably and honestly, and endeavor to contribute to the development of the university. 2. Faculty and staff members are obliged to dedicate themselves to their work during working hours, and never engage in unrelated activities. 3. Faculty and staff members are obliged to follow the instructions of their superiors, maintain discipline in the workplace, and cooperate with each other to fulfill their duties. 4. Faculty and staff members must not conduct any of the prohibited acts stipulated in Article 36 (Compliance Rules) of the university’s work regulations. 5. Before accepting an additional position, faculty and staff members must obtain permission from the president, or the dean/director of their department in advance.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Internal disciplinary action may be taken. If disciplinary action is taken, the incident will be recorded in the perpetrator’s personnel record, and, as a general rule, reported in and outside the university. Even if no disciplinary action is issued, salary or bonus reductions may be implemented. In the case of a disciplinary dismissal, retirement allowances shall not be paid. 2. Legal action may be taken to pay for damages if the incident caused damage to the university. Salary received during a period of absence from work without good reason may have to be returned. 3. Negative social impact: incidents may result in the loss of social trust not only for the perpetrator, but also for the university as a whole.

Incidents at the university I. A reprimand was issued to a faculty member who held an additional position without permission. II. A disciplinary dismissal was issued to a staff member who was absent from work for a considerable number of days without following the appropriate procedures for a leave of absence and without good reason.

◆ Division in Charge: Personnel Division, General Affairs Department ◆ Relevant university regulations and guidelines:  Kyoto University Work Rules for Faculty and Staff  Guidelines concerning Additional Position Held by Faculty and Staff Members Employed by Kyoto University ◆ Relevant manuals, booklets, and websites:  Service Discipline Handbook -For the observance of service discipline-  Examples of Disciplinary Punishment Cases

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12-2 Ethics (interested parties, bribery, etc.)

Faculty and staff members of Kyoto University are expected to take pride in the fact that they work for the university, understand their duties, and act in accordance with the university’s ethical conduct standards as described in Article 2 of Kyoto University Ethical Regulations for Faculty and Staff. They must be sure never to engage in any of the prohibited acts stipulated in Article 5 of the aforementioned regulations. Faculty and staff members employed by national university corporations are not public servants. However, as stipulated by Article 19 of the National University Corporation Act, they are regarded as public servants with respect to the application of the punitive clauses of the penal code and other laws. Therefore, the bribery charge in Article 197 of the penal code is applicable to them.

Compliance obligations 1. Do not receive a gift of money, goods, or real estate from an interested party. 2. Do not receive a loan of goods or real estate, or accept services free of charge from an interested party. 3. Do not allow an interested party to treat you with entertainment (including meals and drinks). 4. Do not receive inappropriate monetary loans or unlisted shares from an interested party. 5. Do not engage in games, sports (including golf), or take a trip with an interested party. 6. Do not allow any business opeator to treat you or pay for entertainment to an inappropriate degree. 7. Do not conduct any other acts prohibited by the abovementioned Ethical Regulations. Note: If it is difficult to determine whether an act is deemed prohibited or not, please consult with the appropriate staff member in the Personnel Division.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Internal disciplinary action may be taken. If disciplinary action is taken, the incident will be recorded in the perpetrator’s personnel record, and, as a general rule, reported in and outside the university. Even if no disciplinary action is issued, salary or bonus reductions may be implemented. In the case of a disciplinary dismissal, retirement allowances shall not be paid. 2. Legal action may be taken. Bribery charges may result in criminal penalties if the perpetrator obtained inappropriate benefits in the course of their work. 3. Negative social impact: incidents may result in the loss of social trust not only for the perpetrator, but also for the university as a whole.

Incident at the university A faculty member was convicted of bribery for doing various favors for a supplier when procuring equipment and supplies to be used for research, and receiving inappropriate benefits from the supplier in return. The faculty member was sentenced to one year and eight months’ imprisonment and a fine of over nine million yen, and gift vouchers received as bribe from the supplier were confiscated. Although the faculty member resigned before the university took internal disciplinary action, it was determined that a disciplinary dismissal would have been issued.

◆ Division in Charge: Personnel Division, General Affairs Department ◆ Relevant university regulations and guidelines:  Kyoto University Work Rules for Faculty and Staff  Kyoto University Ethical Regulations for Faculty and Staff ◆ Relevant laws:  Penal Code: Article 197 (Acceptance of Bribes)  National University Corporation Act: Article 19 (Status of Officials and Employees) ◆ Relevant manuals, booklets, and websites:  Ethics Handbook: -Regulations governing relationships with interested parties in the course of duties-  Examples of Disciplinary Punishment Cases

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12-3 Wrongful Receipt of Allowances

Faculty and staff members must follow the application procedures required for the receipt of allowances (such as commuting allowance, housing allowance, family separation allowance, dependency allowance, and declaration of status of dependents to the mutual aid association). Allowance payments are made or adjusted based on the applications submitted. Faculty and staff members must therefore complete the application procedures promptly and honestly, reporting their actual circumstances. They must not submit false applications.

Compliance obligations 1. Allowance applications must be submitted promptly, and their contents must be accurate and describe the applicant’s actual circumstances. 2. If there is any change in the circumstances relating to allowances, employees must submit a notification of the changes together with the required accompanying documents within fifteen days from the date of the change. 3. Confirm your current circumstances and the mutual aid association’s eligibility requirements for dependents each year to avoid submitting a falsified application. Do not intentionally submit a falsified application in order to receive an allowance.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Internal disciplinary action may be taken. If disciplinary action is taken, the incident will be recorded in the perpetrator’s personnel record, and, as a general rule, reported in and outside the university. Even if no disciplinary action is issued, salary or bonus reductions may be implemented. In the case of a disciplinary dismissal, retirement allowances shall not be paid. 2. Legal action may be taken. The return of the allowances and associated expenses (medical expenses, income tax, etc.) wrongfully received may be demanded retrospectively by the university, and additional charges may also be demanded as a penalty. In cases which were perpetrated intentionally, a criminal penalty for fraud may be imposed. 3. Negative social impact: incidents may result in the loss of social trust not only for the perpetrator, but also for the university as a whole.

Incident at the university In cases in which dependency allowance was wrongfully received, the perpetrator was required to return all wrongfully received allowances and medical expenses, and internal disciplinary action was taken against the perpetrators. Depending on the nature of the incident, the disciplinary action ranged from warnings to salary reductions.

◆ Division in Charge: Personnel Division, General Affairs Department ◆ Relevant university regulations and guidelines:  Kyoto University Work Rules for Faculty and Staff ◆ Relevant laws:  Penal Code: Article 246 (Fraud) ◆ Relevant manuals, booklets, and websites:  Examples of Disciplinary Punishment Cases

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12-4 Harassment

In the course of work or study, relations between those who teach and those who are taught, or between those who give orders and those who follow orders can sometimes develop into inappropriate power relations, which may not only disrupt work or study, but which can cause severe psychological distress. Acts driven by sexual interest can also disrupt the working or learning environment, and cause serious damage to people’s self-esteem. These are just some of examples of harassment. Faculty and staff members must take great care with regards to their words and behavior to ensure that they do not commit an act of harassment.

Compliance obligations Refrain from speech and behavior which could be considered harassment, including: 1. Sexual words and behavior which could make other faculty, staff members, students, or other persons feel bad or uncomfortable. (Sexual harassment) 2. Abuse of positional status, authority, or other superiority in personal relationships through inappropriate words or behavior toward other faculty members or students in the course of research, teaching, or learning. (Academic harassment) 3. Abuse of positional status, authority, or other superiority in personal relationships through inappropriate words or behavior toward other faculty and staff members in the workplace. (Power harassment) 4. Other inappropriate words or behavior equivalent to 1‒3. (Harassment)

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. If a harassment counselor receives a report from a victim of harassment, and the victim wishes for an investigation to be undertaken, the Departmental Human Rights Committee will undertake the investigation. The investigation results will be reported to the dean or director of the relevant department (or faculty consort) and the vice-president in charge. 2. Based on the findings of the investigation, the dean or director of the department (or faculty consort) or the vice-president in charge will take action as necessary, including the issue of an apology, action to keep the offender and victim apart by means of administrative measures, and other necessary measures to address the situation. 3. If, as a result of the investigation, the incident is judged to be an act of harassment requiring disciplinary action, an examination process to determine the appropriate disciplinary action will be undertaken. In some cases, the supervisor of the offender may also be required to take responsibility.

Incidents at the university I. Two students were sexually and academically harassed by a faculty member. The faculty member received a disciplinary suspension from work for two months. As it was decided that the efforts of the faculty member’s supervisor to maintain and improve the management and operation of the laboratory were insufficient, the supervisor also received a caution. II. An associate professor was academically harassed by a professor. The harassment included relentlessly urging the victim to move to a new job and aggressive behavior. The offender was issued a warning as a disciplinary measure.

◆ Division in Charge: Personnel Division, General Affairs Department ◆ Relevant university regulations and guidelines:  Kyoto University Work Rules for Faculty and Staff  Kyoto University Regulations Regarding the Prevention of Harassment, etc. ◆ Relevant laws:  Act on Securing, Etc. of Equal Opportunity and Treatment between Men and Women in Employment ◆ Relevant manuals, booklets, and websites:  Preventing and Coping with Harassment at Kyoto University  Examples of Disciplinary Punishment Cases  Kyoto University Website: Home > About > Human Rights > Harassment Policy at Kyoto University https://www.kyoto-u.ac.jp/en/about/human_rights/harassment-policy-at-kyoto-university.html

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12-5 Respect for Human Rights and the Prohibition of Discrimination

The Japanese constitution and laws guarantee human rights, including respect for individuals and the prohibition of discrimination. In its operations, Kyoto University also maintains a respect for human rights as stipulated in the university’s Mission Statement. The university’s policies and regulations, including the policy on the Qualities Required for Faculty and Staff Members at Kyoto University, require all faculty and staff members to respect human rights and prohibit discrimination against anyone.

Compliance obligations 1. Respect for human rights. 2. Do not discriminate on the basis of sex, ethnicity, disability, etc. Do not discriminate against burakumin. 3. Do not write discriminatory graffiti, distribute discriminatory flyers, or conduct other acts to encourage discrimination. 4. Do not harass anyone. 5. Do not treat students with disabilities in any way which is inappropriate or discriminatory, and show such students appropriate consideration.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. The perpetrator may be subject to disciplinary or administrative action. 2. The perpetrator may be required to make an apology or pay damages to the victim, or may face a lawsuit. 3. The incident may damage the university’s credibility and bring shame on its faculty and staff members.

Incidents at the university I. Discriminatory graffiti, including the victim’s name and defamatory comments, was discovered on a university Co-Op bulletin board. (2012) II. Discriminatory graffiti was discovered on a signboard on Higashi-ichijo Street. (2013) III. A photograph was discovered of a person who appears to be a student or graduate of the university standing outside the graduation ceremony venue wearing a costume which discriminates against people with hearing difficulties and holding a sign saying, “Please speak in a loud voice.” (2014) IV. Discriminatory graffiti was found on a book in the university’s library on Yoshida South Campus. (2017)

◆ Division in Charge: Personnel Division, General Affairs Department ◆ Relevant university regulations and guidelines:  Kyoto University Mission Statement  Qualities Required of Faculty and Staff Members at Kyoto University  Kyoto University Compliance Regulations (currently in Japanese only)  Response Guidelines for Eliminating Discrimination against Disabled Persons at Kyoto University ◆ Relevant laws:  The Constitution of Japan, and other relevant laws  Act for Eliminating Discrimination against Persons with Disabilities ◆ Relevant manuals, booklets, and websites:  Thinking about Human Rights (Brochure)  Kyoto University Website (Japanese): Home > About Kyoto University > Corporate Initiatives > Human Rights (currently in Japanese only) http://www.kyoto-u.ac.jp/ja/about/foundation/human_rights  Kyoto University Website (Japanese): Home > About Kyoto University > Corporate Initiatives > Disabilities (currently in Japanese only) http://www.kyoto-u.ac.jp/ja/about/foundation/shogai

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12-6 Public Relations Ethics

Kyoto University is required to provide accurate and honest information, both internally and externally, about the university’s activities (research results, symposia and other events being held, correspondence with mass media, etc.). If inaccurate information is provided, the university is required to issue a correction. If there is a problem in the information-providing process, it may discredit the reliability of the information, and cause all other information provided by the university to lose credibility. Faculty and staff members must provide or disseminate accurate and honest information in compliance with the relevant laws and regulations.

Compliance obligations 1. Do not disseminate inaccurate, misleading, or distorted information. 2. Do not publicize personal or private information without the consent of the individual concerned. 3. Do not infringe copyrights (including phrases, photographs, etc.). When using other people’s copyrighted materials, employees must acquire the copyright owner’s permission in advance (excluding cases which clearly do not legally infringe any copyright). 4. Do not use any biased or discriminatory expressions (on the basis of ethnicity, sex, etc.). 5. Do not publicize information about specific individuals or organizations without justifiable and sufficient reason that providing the information is in the public interest.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. An apology or damages payment may be required to be issued to the individual or organization that has been infringed against (may result in a lawsuit). 2. The university may be required to report the issue to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 3. The university may be required to implement preventive measures (including improvements to the administrative system, review and improvement of the relevant regulations and manuals, education and training, etc.). 4. The perpetrator and their supervisor may be required to take responsibility for the noncompliance, and their inability to ensure that the regulations were followed appropriately.

Incident at the university After the full text of a speech, in which a phrase from a popular song was quoted, was publicized on the university website, a copyright organization contacted the university regarding its usage fee. However, it was ultimately deemed to be a legally legitimate usage, and the university was not required to pay the fee.

◆ Division in Charge: Public Relations Division, General Affairs Department ◆ Relevant university regulations and guidelines:  Basic Policy for Public Relations (currently in Japanese only)  Guidelines for Public Relations Ethics (currently in Japanese only) ◆ Relevant laws:  Copyright Act  Act on the Protection of Personal Information ◆ Relevant manuals, booklets, and websites:  Kyoto University Website (Japanese): Home > Site Policy > Basic Policy for Public Relations (currently in Japanese only) http://www.kyoto-u.ac.jp/ja/site_policy/houshin.html  Kyoto University Website (Japanese): Home > Site Policy > Guidelines for Public Relations Ethics (currently in Japanese only) http://www.kyoto-u.ac.jp/ja/site_policy/rinri.html

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12-7 Appropriate Handling of Personal Information

The acquisition of personal information should be limited to the minimum required for the university’s operations. The personal information acquired must be handled and managed with meticulous care to ensure that there is no loss or leakage of information. Furthermore, personal information must be used appropriately and provided in compliance with applicable laws and regulations to observe the rights and interests of the individuals concerned.

Compliance obligations 1. Restrict the acquisition of personal information to the minimum required, and collect it in an appropriate manner after clearly identifying and specifying its intended use. 2. Maintain the accuracy of personal information, and implement measures to prevent information loss or leakage. When the personal information becomes unnecessary, erase or dispose of it in an appropriate manner. 3. As a general rule, do not use personal information for purposes other than the intended use specified at the time it was obtained. However, in the case of using it for a different purpose, confirm in advance whether that usage is within the scope of use allowed by the relevant laws and regulations. 4. If a problem occurs, report it to your superior and the information administrator immediately.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. It may be necessary to specify the personal information that was leaked, and provide an apology or damages payment to the individuals affected. 2. The university may be required to report the issue to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 3. It may be necessary to implement preventative measures (including improvement of the administrative system, review and improvement of the relevant regulations and manuals, education and training, etc.). 4. The perpetrator and their supervisor may be required to take responsibility for the noncompliance and their inability to ensure that the regulations were followed appropriately.

Incident at the university A mailing list used for internal work-related communication was left publicly accessible online for approximately eight months due to neglecting to confirm an information sharing setting. As a result personal information about individuals (from within and outside the university) on the mailing list was leaked. The university issued apologies to the individuals, reported the incident to the relevant authorities, held a press conference, and responded to daily press inquiries. The incident caused the university to be criticized by society.

◆ Division in Charge: Legal Affairs Office, General Affairs Department ◆ Relevant university regulations and guidelines:  Kyoto University Regulations for the Protection of Personal Information (currently in Japanese only)  Kyoto University Regulations for the Protection of Individual Numbers and Specific Personal Information (currently in Japanese only) ◆ Relevant laws:  Act on the Protection of Personal Information  Act on the Protection of Personal Information held by Independent Administrative Agencies, etc.  Act on the Use of Numbers to Identify a Specific Individual in Administrative Procedures ◆ Relevant manuals, booklets, and websites:  Kyoto University Website: Home > About > University profile > Disclosure of Information (Requesting disclosure of retained personal information) https://www.kyoto-u.ac.jp/en/about/profile/disclosure-of-information-requesting-disclosure-of-retained-personal-information

COMPLIANCE 12 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-8 Prevention of Information Security Incidents

To ensure stable and efficient implementation of high-quality academic research, education, social engagement activities, and university operations and management, it is essential to understand the vulnerability of electronic information from a security perspective, and enhance the information system to establish and maintain safe operations. All students, faculty and staff members of the university must be aware of the importance of information systems and security. They must use computer software appropriately and protect information assets with respect for the autonomy of the university’s education and research organizations.

Compliance obligations 1. Maintain and develop the security of information systems. 2. Use computer software appropriately in compliance with license terms and conditions. 3. Take e-learning courses on information security. 4. In the event of an information security incident, respond appropriately to the incident in accordance with the Procedures for Response to Information Security Incidents of Kyoto University.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Incidents may interfere with the smooth implementation of research, education, social engagement activities, and university operations and management. 2. It may be necessary to issue an apology or pay damages to an external organization that was attacked or otherwise affected by an incident. 3. The university may be required to report the issue to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 4. The perpetrator and their supervisor may be required to take responsibility for the noncompliance, and their inability to ensure that the regulations were followed appropriately. 5. The university and the perpetrator may be legally liable and have to bear the financial burden of a violation of intellectual property laws, including the copyright act, design act, and patent act.

Incidents at the university I. An individual’s e-mail account information was stolen from the university’s mail server, and a large number of junk e-mails were sent from the stolen account to other universities in Japan. To prevent the problem from worsening, external communication from the mail server in question was shut down as an emergency measure. It took approximately two months until security confirmation and recovery were completed. During that period, none of the mail server’s users were able to use their e-mail. II. An international student had been illegally using software without purchasing a valid license. The incident was discovered when the university received a notification from the software manufacturer. As a result, the university had to pay very expensive license fees claimed by the software manufacturer.

◆ Division in Charge: Information Infrastructure Division, Planning and Information Management Department ◆ Relevant university regulations and guidelines:  Kyoto University Basic Policy for Information Security  Kyoto University Regulations for Information Security Programs  Kyoto University Information Security Program Standards  Procedures for Response to Information Security Incidents of Kyoto University  Procedures for the Implementation of Departmental Security Policies (currently in Japanese only) ◆ Relevant laws:  Basic Act on Cybersecurity  Copyright Act  Design Act  Patent Act  Utility Model Act  Intellectual Property Basic Act

COMPLIANCE 13 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-9 Appropriate Rating and Handling of Information

Information rating is an important fundamental process in ensuring the proper implementation of the university’s Basic Policy for Information Security and Regulations for Information Security Programs. By rating information and restricting its handling, those who created or acquired the information can clarify its importance and the necessary information security measures to be taken, ensuring that others know how the information should be handled.

Compliance obligations 1. Decide the information rating and the handling restrictions when creating or acquiring information. 2. Ensure that the information rating and handling restrictions are clearly indicated. 3. Review the rating and handling restrictions as required. 4. Handle information appropriately in accordance with the rating and handling restrictions.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Incidents may result in an infringement of rights, demands for damages payments, and a loss of trust due to leaked information. 2. Incidents involving the destruction of information may cause a disruption of the stable implementation of research, education, work, etc. 3. Incidents involving the falsification of information may cause a disruption of the stable implementation of research, education, work, etc. 4. The university may be required to report the issue to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 5. The university may be required to implement preventive measures (including improvement of the administrative system, review and improvement of the regulations and manuals, education and training, etc.). 6. The perpetrator and their supervisor may be required to take responsibility for the noncompliance, and their inability to ensure that the regulations were followed appropriately.

Incident at the university Information, including confidential information shared on a blog, was made accessible online without password authentication. The password authentication was usually enabled, but due to the wrong setting being made in error when someone was adjusting the configurations, the system was left functioning with the password authentication disabled for some time. Under these conditions, confidential information was temporarily stored in the browser cache. After the problem was discovered, the university investigated to identify where the information was leaked, and made apologies directly to the persons whose personal information may have been leaked.

◆ Division in Charge: Information Infrastructure Division, Planning and Information Management Department ◆ Relevant university regulations and guidelines:  Kyoto University Basic Policy for Information Security  Kyoto University Regulations for Information Security Programs  Kyoto University Information Security Program Standards  Standards for Rating Information Security at Kyoto University  Procedures for the Rating and Handling of Information at Kyoto University (currently in Japanese only)  Procedures for the Implementation of Departmental Security Policies (currently in Japanese only) ◆ Relevant manuals, booklets, and websites:  Website of Kyoto University’s Institute for Information Management and Communication: Home > Service list > Information security > Related rules and style > Related rules http://www.iimc.kyoto-u.ac.jp/ja/services/ismo/use/regulation.html

COMPLIANCE 14 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-10 Research Misconduct (fabrication, falsification, and plagiarism)

To prevent research misconduct, including fabrication, falsification, and plagiarism, and enhance the university’s system to investigate alleged cases of misconduct, the university formulated the “Promoting Research Integrity Regulations of Kyoto University” and the “Kyoto University Guidelines for the Investigation of Misconduct in Research Activities.” The “Action Plan for the Promotion of Research Integrity at Kyoto University” also describes measures to be taken to ensure honesty in its academic activities, and establishes specific rules, including research data storage and disclosure rules. Research activities must be carried out honestly in compliance with the relevant rules and regulations.

Compliance obligations 1. Maintain a high standard of ethics and self-discipline, comply with the relevant laws, internal regulations, and other regulations, and conduct research activities in an honest manner. 2. Store research data for a certain period using an appropriate storage method, and disclose it as required. Such data also becomes important as evidence to support the validity of research when misconduct is suspected. 3. Those who engage in research activities at the university must take the “Research Integrity Training” e-learning course to raise their awareness of research integrity. 4. If a research misconduct is suspected or discovered, cooperate with the investigation as required.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. An investigation into the alleged research misconduct may be carried out. (In most cases, such investigations take over six months.) 2. The university may be required to report the issue to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 3. The university may be required to implement preventive measures (including improvement of the administrative system, review and improvement of the regulations and manuals, education and training, etc.). 4. The university may be penalized by the funding organizations involved (including the suspension of research funding, reduction of indirect expenses, and imposition of additional requirements to improve management). 5. Disciplinary action may be taken against the perpetrator and their supervisors (including disciplinary action based on the university’s work rules, revocation of academic degrees, revocation of the title of professor emeritus, filing of a claim or lawsuit for the return of funds (including the payment of additional and overdue charges), restriction on the perpetrator’s eligibility to apply for and receive funds, and the filing of a criminal complaint).

Incident at the university A faculty member fabricated and falsified data to make certain key findings more favorable, and the data was presented in graphs in an academic paper. The faculty member was the chief author of the paper. After the misconduct was discovered, a punitive dismissal with no retirement allowance was imposed on the faculty member, their name, affiliation, and other information were disclosed at a press conference, and restrictions on receiving research funds were imposed.

COMPLIANCE 15 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

◆ Division in Charge: Research Ethics and Safety Promotion Office, Research Promotion Department ◆ Relevant university regulations and guidelines:  Promoting Research Integrity Regulations of Kyoto University  Kyoto University Guidelines for the Investigation of Misconduct in Research Activities (currently in Japanese only)  Matters ruled for the Preservation and Disclosure of Research Data as defined in Article 7-2 of the Regulations regarding Promoting Research Integrity of Kyoto University  Action Plan for the Promotion of Research Integrity at Kyoto University ◆ Relevant laws:  Guidelines for Responding to Misconduct in Research  Guidelines on the Proper Implementation of Competitive Funding  Act on Rationalization of Budgetary Spending on Subsidies, etc. ◆ Relevant manuals, booklets, and websites:  Kyoto University Website: Home > Research & Collaboration > Research Compliance & Ethics > Research Integrity Rules & Reporting https://www.kyoto-u.ac.jp/en/research/research-compliance-ethics/research-integrity-rules-reporting/research-integrity- rules-reporting.html

COMPLIANCE 16 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-11 Illegal or Inappropriate Use of Research Funds

Research funds must be used in compliance with the relevant university rules and regulations. Do not use research funds illegally or inappropriately or be involved in such use. If you require clarification on any matter regarding the use of research funds, please consult with the administrative office of your department or read the relevant handbooks or other materials to confirm the regulations̶never rely on your own judgment or assumptions regarding such matters.

Compliance obligations 1. Maintain a high standard of ethics and integrity, and comply with relevant laws, internal regulations, and other rules to ensure the appropriate utilization and management of research funds. 2. Proactively prevent misconduct in accordance with the Guidelines on the Use of Funds. 3. Be sure to take the e-learning course “Proper Use of Research Grants” (an educational course on compliance), and submit the pledge after completing the course. 4. If an investigation into a suspected misuse of research funds is launched, cooperate with the investigation as required. 5. Do not misuse research funds or be involved in any misuse, and never allow or overlook any misuse by persons around you.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. An investigation of the alleged illegal or inappropriate use of research funds may be carried out to discern the facts. (In most cases, such investigations take over six months.) 2. The university may be required to report the issue to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 3. The university may be required to implement preventive measures (including improvement of the administrative system, review and improvement of the regulations and manuals, education and training, etc.). 4. The university may be penalized by funding organizations (including suspensions of research funding, the imposition of additional requirements to improve management, or the reduction of indirect expenses). 5. Disciplinary action may be taken against the perpetrator and their supervisors (including disciplinary action based on the university’s work rules, revocation of the title of professor emeritus, filing of a claim or lawsuit for the return of funds (including the payment of additional and overdue charges), restrictions on eligibility for applying for and receiving funds, or the filing of a criminal complaint).

Incidents at the university I. A faculty member claimed a reimbursement for fictitious travel expenses and a fictitious remuneration payment to a student. The faculty member had the student return the payment to them, and embezzled the reimbursed money as a pooled fund, which they used for private purposes, including meals at the laboratory’s parties. After the misuse was discovered, a punitive dismissal with no retirement allowance was imposed on the faculty member. Their name, affiliation, and other information was revealed at a press conference, a restriction on receiving funds was imposed, and the faculty member was required to return the misused funds and pay a large amount of additional charges. Ⅱ. A faculty member submitted a fictitious travel expense application after a business trip and claimed reimbursement for the (fictitious) travel expenses. The faculty member embezzled the money received, and used it for private purposes. After the misuse was discovered, a punitive dismissal with no retirement allowance was imposed on the faculty member. Their name, affiliation, and other information was revealed at a press conference, a restriction on receiving funds was imposed, and the faculty member was required to return the embezzled funds and pay a substantial punitive charge.

COMPLIANCE 17 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

◆ Divisions in Charge:  Research Ethics and Safety Promotion Office, Research Promotion Department  Accounting Regulatory Division, Department of Financial Affairs ◆ Relevant university regulations and guidelines:  Regulations on Proper Management of Competitive Funds at Kyoto University  Guidelines for Investigation into Misconduct relating to Competitive Funds, etc.  Basic Policy as Defined in Article 4-2 of the Regulations on Proper Management of Competitive Funds at Kyoto University (currently in Japanese only)  Rules for Specifying Scope of Competitive Research Funds under Article 3.1 of the Regulations Concerning the Proper Management of Competitive Research Funds at National University Corporation Kyoto University (currently in Japanese only)  Guidelines on the Use of Funds ◆ Relevant laws:  Guidelines for Managing and Auditing Public Research Funds at Research Institutions  Guidelines on the Proper Implementation of Competitive Funds  Act on Rationalization of Budgetary Spending on Subsidies, etc. ◆ Relevant manuals, booklets, and websites:  Kyoto University Website: Home > Research & Collaboration > Research Compliance & Ethics > Research Integrity Rules & Reporting > Research Integrity Rules & Reporting https://www.kyoto-u.ac.jp/en/research/research-compliance-ethics/research-integrity-rules-reporting/research-integrity- rules-reporting.html

COMPLIANCE 18 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-12 Appropriate Response to Conflicts of Interest in Industry-Government- Academia Collaboration Activities

Faculty members may be suspected of having a conflict of interest if they are not fulfilling their education and research duties at the university, or if they are giving an unreasonably high priority to the interests of specific companies or individuals, etc. The issue of conflict of interest can arise even if the faculty members are engaged in research collaboration or concurrent business after completing the necessary internal procedures and obtaining the necessary approval. In order to avoid situations in which industry-government-academia collaboration activities are viewed with suspicion by society, the university takes the following measures: ● Provision of a counseling service by dedicated staff members. ● Review by the Conflict of Interest Review Board / the Conflict of Interest Review Board for Clinical Research based on self-declarations submitted before starting activities. ● Confirmation of the status of ongoing activities based on reports submitted on a regular basis (once a year). Compliance obligations 1. Undergo a review by the Conflict of Interest Review Board (for Clinical Research) in the following cases:  If, after filling out a pre-judgement sheet, it is determined that a self-declaration is required in advance of medical research.  When creating a start-up based on research results, or engaging in industry-government-academia collaboration or concurrent business with a partner company or organization.  If an economic conflict of interests arises between the work of a committee within a public organization and a private company or organization etc. which is a partner of that public organization.  If you wish to undergo a review. 2. Submit an annual “Regular Report” to describe the activities conducted during the year. Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Report to the relevant authorities, and explain and apologize to the general public regarding the inappropriate relationship with a partner company or organization. 2. Loss of social trust and credibility for the university. Incident at the university In an incident concerning a clinical trial funded by a donation from a pharmaceutical company, the media reported that a part of the clinical trial data (a graph) had been altered. The university investigated the situation, including the possibility of conflict of interest, and provided an explanation to the public at a press conference, etc.

◆ Divisions in Charge:  Conflict of Interest Management Office  Kyoto University Hospital Business Management Section ◆ Relevant university regulations and guidelines:  Kyoto University Regulations for Conflict of Interest Management  Kyoto University Operational Guidelines for Conflict of Interest Management ◆ Relevant laws:  Clinical Trials Act  Guidelines on the Management of Conflicts of Interest in the Ministry of Health, Labor and Welfare Scientific Research  Rules for the Management of Conflicts of Interest in Research Activities (AMED: Japan Agency for Medical Research and Development)  Report of the Conflict of Interest Working Group (Ministry of Education, Culture, Sports, Science and Technology, MEXT) ◆ Relevant manuals, booklets, and websites:  Website of the Conflict of Interest Management Office, Kyoto University (currently in Japanese only) http://www.rieki-souhan.kyoto-u.ac.jp/  Kyoto University Web Site: Home > Research & Collaborate > Research compliance & ethics > Conflict of interest management https://www.kyoto-u.ac.jp/en/research/research-compliance-ethics/conflict_of_interest

COMPLIANCE 19 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-13 Acts Causing Financial Damage to the University (Prohibition of Breach of Trust)

University faculty and staff members are obliged not to allow or cause the university unnecessary expenses in the course of their work. They must not falsely reduce research funds to be received by the university, nor wrongfully increase expenses and fees to be paid by the university. Such acts will cause financial damage to the university, and may be regarded as breach of trust, which is subject to criminal punishment. (Refer to Article 247 of the Penal Code.)

Compliance obligations 1. Contracts, including contracts for the receipt of external funds, contracts for the purchase of articles, and service contracts, must be concluded in compliance with relevant laws, internal regulations, and other rules. If there are unclear points or questions regarding any such contracts, consult with the relevant divisions in charge in advance, and be sure to conclude the contract appropriately in cooperation with the appropriate administrative staff. 2. Faculty members and researchers must not individually receive external research funds without completing the necessary internal procedures. Giving due consideration to the intended use and role of the fund in the research, they must complete the appropriate procedures to receive funds and conclude contracts in accordance with the university’s internal rules and regulations for contracted research, collaborative research, donations, etc. 3. Before concluding a contract, complete the necessary procedures as stipulated by the university’s accounting rules and regulations, and carefully determine whether the contact details and amount are appropriate and reasonable. 4. Before engaging in research as a concurrent business undertaking, carefully determine whether it is appropriate for you to engage in the work as concurrent business separate from your main duties (research) at the university, and in view of the research implementation system and the handling of research results, intellectual property, etc. If it is difficult to judge, consult with relevant divisions in charge in advance. 5. If engaging in research as concurrent business, do not use the university’s research funds, equipment, or human resources for work related to the concurrent business.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Statutory penalty for breach of trust (Article 247 of the Penal Code): Imprisonment for up to five years or a fine of up to 500,000 yen. 2. May be regarded as grounds for disciplinary action under the university’s employment regulations. 3. Depending on the circumstances, the university may require the perpetrator to pay damages or return any benefits received illegitimately if a financial loss was incurred by the university. 4. Depending on the circumstances, research may be negatively impacted and social trust may be damaged for both the perpetrator and the university.

Incident at another university The following incident occurred at another national university corporation. If faculty members at a university engage in collaborative research with an external institution as part of their work, and the external institution provides the research expenses, the faculty members are obliged to inform the university of this situation immediately in order to ensure that the university does not pay any unnecessary expenses. If the faculty member receives research expenses from an external institution and the university subsequently provides or has already provided such expenses, the faculty member must then compensate for or donate the equivalent amount to the university to eliminate the unnecessary expense burden. However, a faculty member neglected these obligations, and the university paid 15 million yen in total from its donation fund to pay for the research expenses, causing a financial loss to the university.

◆ Divisions in Charge:  Legal Affairs Office, General Affairs Department  Personnel Division, General Affairs Department  Accounting Regulatory Division, Department of Financial Affairs  Research Promotion Division, Research Promotion Department  Industry-Academia Collaboration Division, Research Promotion Department ◆ Relevant law:  Article 247 (Breach of Trust) of the Penal Code

COMPLIANCE 20 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-14 Maintaining Ethics and Safety in Life Sciences and Other Research

Researchers in life science fields must maintain a high sense of ethics and self-discipline, and observe research rules and regulations, laws, and university regulations. They must observe social and ethical responsibilities by complying with relevant laws and regulations regarding the handling of pathogens, recombinant DNA experiments, the acquisition of genetic resources from overseas, animal experiments, medical research involving human subjects, human genome and gene analysis research, specified clinical research, etc.

Compliance obligations Before undertaking research, confirm the relevant laws and the university rules and regulations (including departmental regulations) in advance. Observe the applicable laws and regulations, and take the necessary procedures to provide notifications to and obtain permissions from internal or external administrative authorities, etc. ● Pathogens:  Notification of possession of specified pathogens, change of possession status, or non-possession.  Application for permission to possess domestic animal infectious disease pathogens.  Notification of possession of notifiable infectious disease pathogens, etc. ● Recombinant DNA experiments:  Application for recombinant DNA experiments.  Application for transfer or acceptance of genetically modified organisms, etc. ● Acquisition of genetic resources from overseas:  Compliance with laws and regulations in the provider’s country.  Advance agreement with the government of the provider’s country, etc. ● Animal experiments:  Submission of an animal experiment plan.  Application for permission to establish facilities to keep and manage animals, etc. ● Medical research involving human subjects, human genome and gene analysis research, and specified clinical research:  Screening by the Ethics Committee, etc.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. The university may be required to report the issue to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 2. The university may be required to implement preventive measures (including improvement of the administrative system, review and improvement of the regulations and manuals, education and training, etc.). 3. The perpetrator and their supervisor may be required to take responsibility for the noncompliance. 4. Incidents may result in the suspension of research projects, rejection of funding applications, and rejection of submitted academic papers.

Incident at the university Prior to transferring genetically-modified organisms to another organization, a researcher did not provide the required information via printed documents or e-mail. As a result, the university received a strict warning from the Ministry of Education, Culture, Sports, Science and Technology (MEXT).

COMPLIANCE 21 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

◆ Divisions in Charge:  Research Ethics and Safety Promotion Office, Research Promotion Department  Environment, Safety and Health Division, Facilities Department  Department of Ethics Support, Kyoto University Hospital ◆ Relevant university regulations and guidelines:  Regulations for Maintaining Ethics and Safety in the Life Sciences and Other Research Fields at Kyoto University  Kyoto University Regulations for the Management of Pathogens, etc. (currently in Japanese only)  Domestic Animal Infectious Diseases Control Regulations at Kyoto University  Kyoto University Regulations for Safety Management in Recombinant DNA Experiments (currently in Japanese only)  Regulations on Animal Experimentation at Kyoto University ◆ Relevant laws:  Act on the Prevention of Infectious Diseases and Medical Care for Patients with Infectious Diseases  Act on Domestic Animal Infectious Diseases Control  Act on the Conservation and Sustainable Use of Biological Diversity through Regulations on the Use of Living Modified Organisms  Guidelines for Access to Genetic Resources and the Fair and Equitable Sharing of Benefits Arising from their Utilization  Act on the Welfare and Management of Animals  Fundamental Guidelines for Proper Conduct in Animal Experiments and Related Activities in Academic Research Institutions  Ethical Guidelines for Medical and Health Research involving Human Subjects  Ethical Guidelines for Human Genome/Gene Analysis Research  Guidelines for Gene Therapy Clinical Research  Act on the Safety of Regenerative Medicine  Clinical Trials Act ◆ Relevant manuals, booklets, and websites:  Kyoto University Website (Japanese): Home > Research/Industry-Government-Academia Collaboration > Research Ethics/ Bioethics (currently in Japanese only) http://www.kyoto-u.ac.jp/ja/research/ethic/  Website of Kyoto University’s Research Ethics and Safety Promotion Office (Life science section), Research Promotion Department (currently in Japanese only) http://respo.rp.kyoto-u.ac.jp/  Website of Kyoto University’s Agency for Health, Safety and Environment (currently in Japanese only) http://www.esho.kyoto-u.ac.jp/?p=266  Website of Kyoto University Graduate School and Faculty of Medicine, Kyoto University Hospital Ethics Committee (currently in Japanese only) http://www.ec.med.kyoto-u.ac.jp/

COMPLIANCE 22 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-15 Security Export Control

Security Export Control is a system to prevent weapons, dual-use items (equipment, specimens, etc.) and technologies that could potentially be used for military purposes from reaching countries developing weapons of mass destruction, terrorists, and other groups or persons of concern in order to maintain peace and security in Japan and around the world. University activities that are subject to security export control include: shipping items overseas, carrying items outside the country on international business trips, hosting international students and researchers, concluding academic exchange agreements, implementing international research collaboration, and presenting research findings at international conferences.

Compliance obligations 1. When carrying items outside the country, providing technologies to non-Japanese nationals (who are non- resident in Japan), or hosting international students or researchers, confirm that no restrictions apply to the item, technology, research subject, partner organization, or intended use. 2. If List Control or Catch-All Control restrictions apply, it is necessary to obtain permission from the Minister of Economy, Trade and Industry. 3. The relevant faculty and staff members are required to take an e-learning course on security export control to ensure that they understand the laws and regulations.

Impacts and damage caused by compliance violations, misconduct, and malpractice Persons who export or provide restricted items or technology without obtaining prior permission from the Minister of Economy, Trade and Industry may be punished by the law. 1. A criminal penalty of imprisonment for up to ten years may be imposed. 2. Fines of up to thirty million yen may be imposed on individuals, or up to one billion yen on corporate entities. 3. Administrative penalty: ban on exporting items or transferring technology may be imposed for up to three years. 4. An official warning may be issued to the perpetrating organization by the Ministry of Economy, Trade and Industry, and an official announcement of the violation may be made. 5. In cases that violate the Foreign Exchange and Foreign Trade Act, the incident may be reported by the mass media, resulting in a negative social impact for the perpetrator and the university.

Incident at another university The following incident occurred at another national university corporation. The university hosted an international student from an Iranian institution suspected of engaging in nuclear development (Iran was listed as a country of concern at that time, and as of 2018 is still listed as such). The international student engaged in research on “the collection of rare metal from the waste water of spent nuclear fuel.” Ultimately, there was not deemed to have been any violation of the Foreign Exchange and Foreign Trade Act, but it was widely covered by mass media and the university was investigated by the Ministry of Economics, Trade and Industry. Since then, the university has been enhancing its internal control systems and implementing very strict security export control.

◆ Division in Charge: Research Ethics and Safety Promotion Office, Research Promotion Department ◆ Relevant university regulations and guidelines:  Security Export Control Regulations of Kyoto University  Security Export Control Rules of Kyoto University ◆ Relevant laws:  Foreign Exchange and Foreign Trade Act  Export Trade Control Order  Foreign Exchange Order ◆ Relevant manuals, booklets, and websites:  Brochure: Preventing the Use of Research for Military Purposes̶The Basics of Security Export Control (currently in Japanese only)  Kyoto University Website: Home > Research & Collaborate > Research compliance & ethics > Security Export Control https://www.kyoto-u.ac.jp/en/research/research-compliance-ethics/security-export-control.html  Website of the Ministry of Economy, Trade and Industry http://www.meti.go.jp/policy/anpo//englishpage.html  Website of the Center for Information on Security Trade Control (CISTEC) http://www.cistec.or.jp/english/index.html

COMPLIANCE 23 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-16 Fire Prevention and Control

To prevent fires, Kyoto University makes efforts to raise awareness of fire safety and maintain an effective fire prevention and control system in compliance with laws and regulations. The university has established a fire prevention system to minimize damage caused by fires, explosions, hazardous material leakages, and other disasters or accidents, and to enable a quick response to such incidents should they occur on any campus or in any department. Faculty and staff members are required to take appropriate action to respond to fire outbreaks in accordance with the procedures for each campus and department.

Compliance obligations 1. Understand the laws relating to fire prevention, internal regulations, fire defense plans, and other rules and regulations, always be conscious of fire prevention, handle fire appropriately, and proactively participate in training to ensure fire prevention and control. 2. Manage and handle hazardous materials appropriately in compliance with the relevant laws and regulations. 3. Maintain and manage firefighting equipment appropriately. 4. In the event of a fire or other disaster, take appropriate action to respond quickly, including raising an alarm and notifying people, making efforts to extinguish fires as soon as they start, assisting with evacuation, and emergency aid and rescue.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Increased damage caused by fires or other disasters can have a serious impact, not only on the continuation or resumption of university operations, but also on the surrounding area. 2. The university may be required to report the issue to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 3. The university may be required to undergo on-site inspections by supervisory authorities, and suspend the use of facilities. 4. Preventive and safety measures may be implemented (including the renovation of facilities, improvement of the administrative system, education and training, etc.) 5. In the case of a violation of the fire service act or a major incident, the perpetrator, their supervisor and their organization may be required to take criminal, civil, and administrative responsibility.

Incident at the university A fire occurred at a facility using radioisotopes (RI) that damaged twenty-nine square meters of an RI laboratory. The fire resulted in a serious loss of public trust in the university. Because the fire occurred at an RI laboratory, the university had to respond to and provide information immediately to various parties, including reporting to the Secretariat of the Nuclear Regulation Authority, holding a press conference and providing an explanation to the media, providing information to the general public and responding to their inquiries, and providing an explanation and apology to local residents. The university was also subject to on-site inspections by the Labor Standards Inspection Office, the Nuclear Regulation Authority, and the local fire department, and was strongly requested to enhance its procedures to prevent the recurrence of such an incident.

◆ Divisions in charge:  Property Management Division, Facilities Department  Environment, Safety and Health Division, Facilities Department ◆ Relevant university regulations and guidelines:  Kyoto University Fire Prevention Regulations  Guidelines for Fire and Disaster Prevention and the Maintenance of the Fire and Disaster Prevention Systems (currently in Japanese only)  Fire Defense Plan (currently in Japanese only) ◆ Relevant laws:  Fire Service Act  Fire Service Act Enforcement Ordinance  Fire Service Act Enforcement Regulations  Cabinet Order concerning the Control of Hazardous Materials  Rules concerning the Control of Hazardous Materials ◆ Relevant manuals, booklets, and websites:  Firefighting Manual (currently in Japanese only): Portal site for faculty and staff / Facilities Department / Property Management Division / Campus Safety Section

COMPLIANCE 24 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-17 What to Do in the Event of an Earthquake

Kyoto University’s basic policy for responding to earthquake disaster is as follows: The university shall prioritize protecting the life and safety of students, patients, faculty, staff, and visitors, and ensuring the continued operation of the Kyoto University Hospital. After an earthquake, the university shall endeavor to continue or resume education, research, and medical care as soon as possible, and contribute to the restoration and reconstruction of local communities. To achieve these goals, it is necessary to implement disaster preparedness and response measures at the university to ensure that every person can take appropriate initial actions in the event of an earthquake, and that all faculty and staff members can quickly and effectively take appropriate action after an earthquake has occurred, including safety confirmation procedures and the emergency repair of facilities and equipment.

Compliance obligations 1. When an earthquake occurs (or when an earthquake early warning is issued), protect your own life and safety by taking appropriate initial actions (cease working, ensure and confirm the safety of those around you, prevent fires, etc.). 2. Assist with providing first-aid to the injured and assist with the evacuation of the people in the building. 3. Assist each department in the work of performing necessary actions (such as reporting, initial firefighting, rescue work, and entry restriction) to reduce damages and prevent secondary disasters caused by fire, damaged buildings, etc. 4. Assist with departmental efforts to confirm those who are injured or missing, and with conducting follow-up checks. 5. Register your safety information on the university’s Safety Confirmation System. 6. Assist with departmental efforts to carry out emergency repairs of facilities and equipment.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Increased damage caused by fires or hazardous material leakage have a serious impact, not only on the continuation or resumption of university operations, but also on surrounding areas. 2. Failure to implement the necessary safety and prevention measures (aseismic reinforcement of buildings and facilities, maintaining the safety of evacuation routes, education and training, etc.) or ineffective initial responses (firefighting, evacuation, rescue, first-aid activities, etc.) may increase casualties and damage to property, and may hamper emergency operations by disaster response organizations. 3. The university may be required to implement preventive measures (including the renovation of facilities, improvement of the administrative system, review and improvement of the relevant regulations and manuals, education and training, etc.). 4. The persons concerned, as well as their supervisors and organization may be required to take criminal and civil responsibility.

Incident at the university In the aftermath of Kumamoto earthquake in 2016, three of the university’s facilities had been damaged. The university therefore implemented “Level 2 Crisis” emergency response: a disaster response office was established, the safety and damage status of students, faculty and staff members was confirmed, the damage to facilities was assessed and repaired, and support was provided to students. However, there was a slight delay in the initial gathering of information and the establishment of the disaster response office.

COMPLIANCE 25 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

◆ Division in charge: Risk Management Division, General Affairs Department ◆ Relevant university regulations and guidelines:  Kyoto University Risk Management Regulations  Detailed Regulations for the Enforcement of the Kyoto University Risk Management Regulations (currently in Japanese only)  Business Continuity Plan (BCP) in the Event of Major Earthquake (currently in Japanese only)  Kyoto University Basic Plan for Risk Management (currently in Japanese only)  Kyoto University Risk Management Plan (for Earthquakes) (currently in Japanese only)  Departmental Risk Management Plan (for Earthquakes) (currently in Japanese only)  Fire Defense Plan (currently in Japanese only) ◆ Relevant laws:  Disaster Countermeasures Basic Act  Fire Service Act ◆ Relevant manuals, booklets, and websites:  Earthquake Response Manual for Faculty and Staff: Portal site for faculty and staff / General Affairs Department / 01-0 General Affairs Division / 01 General Affairs Division’s Documents / 4. Risk-related  Earthquake Safety Manual for Students: Kyoto University Website (Japanese): Home > Education and Student Support > Campus Life Support > Points to note about student life > Response in the event of earthquakes http://www.kyoto-u.ac.jp/ja/education-campus/campuslife/notice2  Firefighting Manual (currently in Japanese only): Portal site for faculty and staff / Facilities Department / Property Management Division / Campus Safety Section

COMPLIANCE 26 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-18 Handling of Chemical Materials (poisonous and deleterious substances, etc.)

It is important to choose the safest and most eco-friendly chemical materials from among those that meet the requirements for the intended use, and limit the usage to the minimum necessary. When handling special materials, such as specified poisonous substances, stimulant drugs, and psychotropic drugs, which must be handled by qualified persons, in a specified facility, or which must be reported to the authorities prior to use, be sure to follow the regulations for use, maintain strict control of the substances, and do not fail to make the necessary reports to the relevant authorities. When such substances are being used, it is also necessary to observe all applicable laws and regulations, including the rules for safety confirmation, storage, and labeling. Users are also responsible for appropriately disposing of waste in compliance with the applicable laws and regulations.

Compliance obligations 1. Before starting your research, confirm the applicable laws, internal regulations, and other rules (including departmental rules), receive all required education and training, and prepare and submit all required applications and reports. 2. Take care when storing chemical materials, including reagent, and regularly check the materials to avoid any loss or damage. 3. Confirm any risks entailed before using or disposing of chemical materials to prevent health hazards or environmental contamination. 4. If a problem occurs, report it immediately to the administrator of the department and the administrative staff in charge.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Incidents may harm the health of those using the materials and others, and may cause pollution of the surrounding environment. 2. The university and the perpetrator may be required to issue an apology or pay compensation for the damage. 3. The university may be required to report the issue to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 4. The university may be required to implement preventive measures (including improvement of the administrative system, review and improvement of the regulations and manuals, education and training, etc.) 5. The perpetrator and their supervisor may be required to take responsibility for the noncompliance.

Incidents at the university I. After receiving a delivery of ethyl acetate (a deleterious substance) from a supplier, a researcher failed to put it in a storage cabinet and lost it. The director of the researcher’s department held a press conference, and the department was instructed to take corrective measures by Kyoto Prefecture’s Pharmaceutical Administration Division. The department complied with the instructions, which included the submission of a report to the Pharmaceutical Administration Division. II. After it was discovered that a researcher possessed specified poisonous substances without the necessary license, the department was investigated and received instructions from a public health center. III. A faculty member who possessed stimulants' raw materials for their research, neglected to take the required procedures before transferring to a different institution, and left the materials as they were. As soon as they were discovered, the department reported it to Kyoto Prefecture, and the incident was determined to be a legal violation (illegal possession of stimulants' raw materials). The faculty member was required to submit a written statement, and to be on-site while the investigation and collection of the materials were conducted by drug control officers.

COMPLIANCE 27 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

◆ Division in charge: Environment, Safety and Health Division, Facilities Department ◆ Relevant university regulations and guidelines:  Kyoto University Regulations for the Management of Chemical Materials (currently in Japanese only)  Guidance for the Implementation of the Kyoto University Regulations for Management of Chemical Materials (currently in Japanese only)  Kyoto University Regulations for Hazard Prevention in High Pressure Gas Production Facilities (currently in Japanese only) ◆ Relevant laws:  Stimulants Control Act  Narcotics and Psychotropics Control Act  Poisonous and Deleterious Substances Control Act  Law on Securing the Quality, Efficacy and Safety of Products, Including Pharmaceuticals and Medical Devices (PMD Act: Pharmaceutical and Medical Device Act)  High Pressure Gas Safety Act  Industry Safety and Health Act  Fire Service Act  Rules for Restricting Hazardous Materials  Explosives Control Act ◆ Relevant manuals, booklets, and websites:  Website of the Kyoto University Chemicals Registration System (KUCRS) (currently in Japanese only) https://kucrs.esho.kyoto-u.ac.jp/cris_v2_0/login.aspx

COMPLIANCE 28 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-19 Use of Radioactive Materials (radioisotopes, X-ray devices, nuclear materials, etc.)

When handling radioactive materials (radioisotopes, X-ray devices, nuclear materials, etc.), users must observe the applicable laws, internal regulations, and other rules, prevent radiation hazard, and ensure safety in and outside the university. Nuclear materials must be used solely for peaceful purposes and managed using appropriate control systems, including material accounting. Safety must be assured.

Compliance obligations 1. Prior to using radioactive materials, changing the approved use conditions (such as form of usage or quantity), or altering or decommissioning facilities, the relevant applications or reports must be submitted, and approval must be granted by the relevant authorities. 2. Those who use radioactive materials are required to be registered as radiation workers, receive the necessary education and training, and have the required medical checkups. 3. Radioactive materials must be used within the controlled area. No radiation must be allowed to leak outside the controlled area. 4. Radioactive materials must be appropriately managed in compliance with the relevant laws and internal regulations to reduce the risk of radiation exposure. 5. If an abnormality is found, it must be reported immediately to the radiation protection supervisor, X-ray operation chief, and person in charge of material accounting.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Incidents may result in health hazards due to radiation exposure, environmental damage due to radiation leakage, and concern by local residents about radiation exposure and leakage. 2. The university may be required to report incidents to the relevant authorities, provide an explanation about the hazards and damage entailed to the general public at a press conference, issue an apology, and pay for damage. 3. The university may be required to implement preventive measures (including an investigation into the cause of the problem, the implementation of countermeasures, improvement of the administrative system, education and training, etc.) 4. Incidents may result in increased concern about the possibility that radioactive materials may be used for nuclear weapon development or terrorist attacks due to inappropriate management.

Incidents at the university I. Old equipment for handling nuclear materials was disposed of, and a replacement was installed, without first obtaining approval in compliance with the relevant laws. The university received a written warning from the Nuclear Regulation Authority, and was required to enhance measures to prevent the recurrence of such incident. II. A fire occurred at a facility using radioisotopes. Although there was no radiation leakage, the university was required to do the following: ● Report the matter to the Secretariat of the Nuclear Regulation Authority ● Provide an explanation and issue an apology at a press conference. ● Respond to requests for information disclosure and inquiries from residents, and provide them with an explanation and apology ● Submit a detailed report to the Nuclear Regulation Authority ● Undergo several on-site inspections by supervisory authorities ● Implement a system to prevent recurrence of such incidents. III. The university installed and utilized new X-ray equipment without submitting the necessary application until after the fact (the application must be submitted to the Labor Standards Inspection Office thirty days prior to the installation). The university received a warning from the Labor Standards Inspection Office and was requested to ensure that there is no recurrence of such an incident.

COMPLIANCE 29 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

◆ Division in charge: Environment, Safety and Health Division, Facilities Department ◆ Relevant university regulations and guidelines:  Regulations for Prevention of Radiation Hazards at Kyoto University  Agreement Concerning Radiation Apparatus  Agreement on Radioisotopes (RIs) not Subject to Regulation and Radioisotopes Less Regulated  Kyoto University Regulations for the Accountancy and Management of Nuclear Materials (currently in Japanese only) ◆ Relevant laws:  Law concerning the Prevention of Radiation Hazards due to Radioisotopes, etc.  Ordinance on the Prevention of Ionizing Radiation Hazards  Atomic Energy Basic Act  Act on the Regulation of Nuclear Source Materials, Nuclear Fuel Materials, and Reactors ◆ Relevant manuals, booklets, and websites:  Website of Division of Radiation Management and the Radioisotope Research Center (Agency for Health, Safety and Environment, Kyoto University) (currently in Japanese only) http://www.rirc.kyoto-u.ac.jp/  Kyoto University’s Management System for Radiation Users (KRUMS) https://krums.esho.kyoto-u.ac.jp/msru/sessions

COMPLIANCE 30 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-20 Occupational Safety and Health

To prevent occupational accidents and fires in the workplace, and facilitate the smooth performance of work, all faculty and staff members must observe the relevant rules and regulations. Faculty members must instruct their students about the appropriate safety measures to be taken during their research and when conducting experiments.

Compliance obligations 1. Observe the relevant laws, the university’s Safety and Health Control Regulations, Safety and Health Control Guidelines, and other departmental regulations, and proactively cooperate with the university’s efforts to prevent occupational accidents. 2. Prior to beginning tasks, receive appropriate safety and health education in accordance with the Safety and Health Control Guidelines. 3. Persons in charge (immediate superiors) in laboratories, etc., must provide safety and health education to faculty, staff, and students. 4. Be sure to undergo health and stress checkups by the specified date or within the specified period. 5. If an occupational accident or fire occurs, report it to your superior and the director of your department immediately.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. Incidents may result in the suspension of research, education, or other activities. 2. The university may be required to submit a report to the relevant authorities, and provide an explanation and apology to the general public at a press conference, etc. 3. The university may be required to implement preventive measures (including improvement of the administrative system, review and improvement of the regulations and manuals, education and training, etc.) 4. In the case of a legal violation, a penalty or fine and/or imprisonment may be imposed on the university and the perpetrator (including the person in charge of the laboratory).

Incidents at the university I. During an on-site inspection by the Labor Standards Inspection Office, it was discovered that there was no caution or classification details posted in a laboratory where an organic solvent was being used, despite the fact that the posting of such a notice is required by law. The university received corrective order from the Labor Standards Inspection Office. II. A work-related accident occurred, which was caused by a damage grinder. The university received a corrective order from the Labor Standards Inspection Office regarding the management of equipment subject to the Industrial Safety and Health Act, the provision of special education, and the appointment of an administrator. III. Due to extremely noisy working environments, the university received a corrective order from the Labor Standards Inspection Office regarding noise prevention, the wearing of protective equipment, and the implementation of noise measurement.

◆ Division in charge: Environment, Safety and Health Division, Facilities Department ◆ Relevant university regulations and guidelines:  Kyoto University Safety and Health Control Regulations  Safety and Health Control Guidelines ◆ Relevant laws:  Industrial Safety and Health Act  School Health and Safety Act ◆ Relevant manuals, booklets, and websites:  Website of Kyoto University’s Agency for Health, Safety and Environment: Document management system page (currently in Japanese only) http://www.esho.kyoto-u.ac.jp/document/

COMPLIANCE 31 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

12-21 Management and Disposal Regulated by Environmental Laws (effluent, waste, etc.)

The university has established internal regulations for the appropriate management of effluent and waste, which are subject to regulation by law. Effluent and waste (including general waste) generated in the course of experiments must be properly managed and disposed of in compliance with the relevant laws, internal regulations, and other rules and regulations to avoid environmental pollution.

Compliance obligations 1. Do not discharge waste liquid that is generated in the course of experiments and does not meet the effluent standards described in Article 12-2 of the Sewerage Act or Article 3 of the Water Pollution Prevention Act into the sewage system. Such waste liquid must be stored. 2. Regarding the water used to wash instruments used for experiments, do not discharge wastewater from primary, secondary, or tertiary cleaning into the sewage system. As a general rule, such wastewater must be stored in containers according to its specific properties. Regarding the water used for cleaning subsequent to tertiary cleaning, it must be discharged into an experimental wastewater treatment system, but not into a domestic wastewater treatment system. 3. Segregate, manage, and dispose of waste in accordance with the relevant laws and regulations. Follow the necessary procedures for the management of specially controlled industrial waste when disposing of waste containing asbestos, polychlorinated biphenyl (PCB), mercury, etc.

Impacts and damage caused by compliance violations, misconduct, and malpractice 1. In the case of a legal violation, a report must be made and an explanation must be provided to the relevant authorities. Such violations may be subject to criminal punishment, including imprisonment or fines. 2. The university may be required to identify the cause of the problem and partially suspend education, research, and other operations until effective measures are taken to prevent a recurrence of such incidents. 3. The university may be required to implement preventive measures (including an improvement of the administrative system, review and improvement of the regulations and manuals, etc.) 4. Incidents that cause environmental pollution may result in a loss of social trust in the university.

Incidents at the university I. Wastewater generated during experiments, which exceeded the allowable water quality standards set by law, was drained to outside of the campus. Until the university identified the cause of the problem and implemented measures to prevent the recurrence of such an incident, no applications (required by the Sewerage Act) for the installation of specified facilities (including laboratory sinks) were approved. This negatively impacted not only the department responsible for the incident, but also other departments. It also affected the schedule for the construction of a new building. II. Plastics and recyclable paper were not properly separated from general business waste as required by law. As a result, the university underwent on-site inspections by Kyoto City and other supervisory authorities, and was issued with warnings and guidance.

◆ Division in charge: Environment, Safety and Health Division, Facilities Department ◆ Relevant university regulations and guidelines:  Kyoto University Effluent/Waste Management Regulations  Requirements regarding the Management and Disposal of Experimental Effluent and Waste ◆ Relevant laws:  Water Pollution Prevention Act  Sewerage Act  Waste Management and Public Cleaning Act ◆ Relevant manuals, booklets, and websites:  Website of the Kyoto University Agency for Health, Safety and Environment: Environmental Initiatives (currently in Japanese only) http://www.esho.kyoto-u.ac.jp/?p=144

COMPLIANCE 32 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

13 University Regulations and Guidelines Relating to Compliance

Response Guidelines for Eliminating Discrimination against Disabled Persons at General Affairs Division, General ★ Kyoto University Affairs Department ★ Kyoto University Compliance Regulations ★ Kyoto University Information Disclosure System Regulations Legal Affairs Office, General ★ Kyoto University Regulations for the Protection of Personal Information Affairs Department Kyoto University Regulations for the Protection of Individual Numbers and ★ Specific Personal Information

Basic Policy for Public Relations Public Relations Division, Guidelines for Public Relations Ethics General Affairs Department ★ Kyoto University Work Rules for Faculty and Staff ★ Kyoto University Special Work Rules for Faculty Member ★ Kyoto University Work Rules for Limited-term Faculty and Staff ★ Kyoto University Work Rules for Part-Time Faculty and Staff ★ Kyoto University Ethical Regulations for Faculty and Staff Kyoto University Regulations regarding Disciplinary Action against Faculty and ★ Staff Personnel Division, General Affairs Department ★ Kyoto University Regulations Regarding the Prevention of Harassment, etc. Kyoto University Guidelines regarding Demotion, Decrease of Service Grade, ★ and Decrease of Pay Step of Faculty of Staff Kyoto University Regulations regarding Restrictions on Re-employment of ★ Executives and Employees, etc. Guidelines concerning Additional Positions Held by Faculty and Staff Members Employed by Kyoto University ★ Kyoto University Risk Management Regulations Detailed Regulations for the Enforcement of the Kyoto University Risk ★ Management Regulations Business Continuity Plan (BCP) in the Event of Major Earthquake Risk Management Division, General Affairs Department Kyoto University Basic Plan for Risk Management Kyoto University Risk Management Plan (for Earthquakes) Departmental Risk Management Plan (for Earthquakes) Kyoto University Basic Policy for Information Security ★ Kyoto University Regulations for Information Security Programs Information Promotion Division, Kyoto University Information Security Program Standards Planning and Information Management Department Kyoto University Rules for Information Asset Use Standards for Rating Information Security at Kyoto University ★ Kyoto University Fire Prevention Regulations Guidelines for Fire and Disaster Prevention and the Maintenance of the Fire Property Management Division, and Disaster Prevention System Facilities Department Fire Defense Plan

COMPLIANCE 33 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

★ Kyoto University Regulations for the Management of Chemical Materials Guidance for the Implementation of the Kyoto University Regulations for Management of Chemical Materials Kyoto University Regulations for Hazard Prevention in High Pressure Gas ★ Production Facilities ★ Regulations for Prevention of Radiation Hazards at Kyoto University Kyoto University Regulations for the Accountancy and Management of Nuclear ★ Materials Agreement Concerning Radiation Apparatus Environment, Safety and Health Agreement on Radioisotopes (RIs) not Subject to Regulation and Radioisotopes Division, Facilities Department Less Regulated The Kyoto University Regulations for Safety Management in Recombinant DNA ★ Experiments ★ The Kyoto University Regulations for the Management of Pathogens, etc. Safety and Health Control Guidelines ★ Kyoto University Safety and Health Control Regulations ★ Kyoto University Effluent/Waste Management Regulations Requirements regarding the Management and Disposal of Waste Liquid and ★ Waste ★ Promoting Research Integrity Regulations of Kyoto University Matters ruled for the Preservation and Disclosure of Research Data as defined ★ in Article 7- 2 of the Regulations regarding Promoting Research Integrity of Kyoto University ★ University Guidelines for the Investigation of Misconduct in Research Activities Action Plan for the Promotion of Research Integrity at Kyoto University Regulations on the Proper Management of Competitive Funds at Kyoto ★ University Basic Policy as Defined in Article 4-2 of Regulations on the Proper Management ★ of Competitive Funds at Kyoto University Research Ethics and Safety Rules for Specifying Scope of Competitive Research Funds under Article 3.1 of Promotion Office, Research ★ the Regulations Concerning the Proper Management of Competitive Research Promotion Department Funds at National University Corporation Kyoto University ★ Guidelines for Investigation into Misconduct relating to Competitive Funds, etc. Guidelines on the Use of Funds Regulations for Maintaining Ethics and Safety in the Life Sciences and Other ★ Research Fields at Kyoto University ★ Domestic Animal Infectious Diseases Control Regulations at Kyoto University ★ Regulations on Animal Experimentation at Kyoto University ★ Security Export Control Regulations of Kyoto University Security Export Control Rules of Kyoto University

★ Kyoto University Regulations for Conflict of Interest Management Conflict of Interest Management Kyoto University Operation Guidelines for Conflict of Interest Management Office ★ Kyoto University Regulations for the Protection of Whistleblowers Audit Administration Office ★ Kyoto University Regulations for Internal Audits

The regulations and guidelines marked with ★ in the table above are available online through the following website: http://www.kyoto-u.ac.jp/uni_int/kitei/reiki_menu.html (currently only in Japanese). For the details of other regulations, please contact the division in charge.

COMPLIANCE 34 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

14 University Guidebooks and Other Materials Relating to Compliance

General Affairs Division, General Affairs Thinking about Human Rights Department

Preventing and Coping with Harassment at Kyoto University

Service Discipline Handbook -For the observance of service discipline Personnel Division, General Affairs Department Ethics Handbook: -Regulations governing relationships with interested parties in the course of duties-

Examples of Disciplinary Punishment Cases

Information Infrastructure Division, Planning and Information Security Quick Guide Information Management Department

Institute for Information Management and Safe Use of E-mail: Tips on Using E-mail Safely and Securely Communication

International Affairs Division, Planning and Handbook for International Researchers Information Management Department

Handbook for the Management of Chemical Materials

Implementing Experiments Safely Environment, Safety and Health Division, Facilities Department Safety and Health Control Guidelines (Standard/General Edition)

Radiation Management Division, Agency for Health, Kyoto University Guide for Radiation Safety Management Safety and Environment

Research Ethics and Safety Promotion Office, Research Promotion Department Handbook on Research Fund Use Accounting Regulatory Division, Department of Financial Affairs

Responsible Academic Research

Preventing the Use of Research for Military Purposes Research Ethics and Safety Promotion Office, ̶The Basics of Security Export Control Research Promotion Department Research Data Preservation for Responsible Research at Kyoto University

Guidelines for Conflict of Interest Management Conflict of Interest Management Office

For more details, please contact the division in charge.

COMPLIANCE 35 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

15 Organizational Chart: Compliance at Kyoto University

President

Compliance PromoƟŽn Oĸce

Director (Vice-Persident for Legal Aīairs and Compliance)

Vice-Director

Oĸcial Members

䞉 ExecuƟve Vice-Presidents 䞉 Other members appointed by the Director

Compliance PromoƟŽn Oĸce MeeƟng [InformaƟon-sharing/Decisions on acƟon to be taken]

Compliance PromoƟŽn Oĸce PracƟcal MeeƟng [InformaƟon-sharing, including reports on the progress of measures taken]

Report InstrucƟon/Advice

ExecuƟve Vice-President in Charge

Report InstrucƟon/Advice Central AdministraƟŽn

Report InstrucƟon/Advice InstrucƟon/Advice Report

Deans and Directors ConsuůƚĂƟŽn Services

InformaƟon/ConsultaƟon/Report InformaƟon/ConsultaƟon/Report Faculty and SƚĂī Members

COMPLIANCE 36 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

16 Consultation about Compliance and Where to Report Compliance Related Matters at Kyoto University

If you wish to discuss or report a compliance-related issue or problem, please contact the appropriate staff member or department as detailed below.

Consulting with your supervisor or other staff member. Always be sure to consult about or report compliance-related issues in a timely manner. If you encounter a compliance-related issue, or if you have any doubts or questions, do not ignore it or forget about it̶be sure to consult with your supervisor or other appropriate staff member.

Inquiries about whistleblowing Reports and inquiries about whistleblowing can be made internally within the university or externally to a legal firm employed by the university. For more details, please see the Whistleblowing Inquiries page of the university website: http://www.kyoto-u.ac.jp/ja/about/foundation/ktsuho/liaison/ (Currently in Japanese only)

Consultation about harassment Consultation about harassment can be provided either within individual departments, or by the General Student Support Center and the Personnel Division of the General Affairs Department, which provide harassment consultation for all faculty, staff, and students. For more details about where you can receive consultation about harassment, or for general information about the prevention of harassment and action that can be taken if it occurs, please access the relevant university webpages:

The Counselling Office, Kyoto University General Student Support Center https://www.gssc.kyoto-u.ac.jp/counsel/english.html

Harassment Policy at Kyoto University https://www.kyoto-u.ac.jp/en/about/human_rights/harassment-policy-at-kyoto-university.html

Consultation about misconduct in research activities and reporting cases of misconduct The central administration and departmental administrative offices provide consultation about misconduct in research activities and receive reports about misconduct. For more details, please access “Consultation about misconduct in research activities and reporting cases of misconduct” on the Kyoto University website: http://www.kyoto-u.ac.jp/ja/research/ethic/research_guide/madoguchi/ (Currently in Japanese only)

COMPLIANCE 37 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２

Consultation about false accounting in the use of competitive funds, etc. and reporting accounting violations For details of where to receive consultation about false accounting in the use of competitive funds managed by the university and where to report accounting violations, please access “Consultation about false accounting in the use of competitive funds, etc. and reporting accounting violations” on the university website: http://www.kyoto-u.ac.jp/ja/research/public/competitive/tsuho.html (Currently in Japanese only)

Whistleblower protection Kyoto University has a system to ensure that whistleblowers are protected from unfair dismissal or other prejudicial treatment.

COMPLIANCE 38 GUIDEBOOK KYOTO UNIVERSITY 京都大学 根拠資料３－２－Ｂ－２ 京都大学 根拠資料３－２－Ｂ－２ 京都大学 根拠資料３－２－Ｂ－２

Issued by: Kyoto University, May 2018 Contact: Legal Affairs Office General Affairs Department Kyoto University TEL: 075-753-2190 Compliance Guidebook