Guidance Documents for Aviation,
Space and Defence Organizations
Appendix-1- Compliance Education - April, 2014 Published- June, 2017 Revised(Added English translation for Examples)1

Table of contents
1.
2.
3.
4.

Objectives
Scope
Terms
Compliance education
4.1 Scope of the educational content
4.2 Educational methods
4.3 Essential points of education
4.4 Enhancing "perceptiveness"
4.5 Summary
5. Reference information
6. Examples
7. Reference documents
8. Editor’s Note2

1. Objectives
The objective of this document is to provide thepolicies and best practices regarding theperspectives that should be incorporated in theplanning of education and how to implement theeducation when providing education to the personnelof an organization to enable the organization toestablish and continuously maintain its compliancestructures.

3

2. Scope

All aspects of the Aviation, Space andDefence organizations
Note that these materials can be used in otherindustry as well.

43. Terms
Compliance:
This is generally understood to mean "compliance with laws andregulations" but this is a narrow definition. Naturally organizations mustcomply with laws and regulations.
Normally, the compliance required for the organizations is considered tocover not only laws and regulations but also compliance with in-houserules/manuals (procedures), business ethics, and social norms such as the
widely accepted views, good conscience, etc. of society
Socail norms
Business ethics
In-house rules and manuals
Laws andregulations

Note: there is no official definition of "compliance" so eachorganization uses its own definition.
5

4. Compliance education
4.1 Scope of the educational content (laws and regulations)
There is a full range of laws and regulations
related to the activities of organizations
including the Penal Code, the Act on theProtection of Personal Information, theProduct Liability Act (PL Act), the Labor
Standards Act, etc. and there is a limit to theextent that education can be provided
uniformly for all of them. Therefore, it isdesirable for organizations to grasp thecompliance matters that all of the employees
have to know for that organization and thecompliances matters the employees have toknow in their respective work duties, andcreate an education plan.

Prefecturalordinances

Ministerial
ordinancesand cabinet
ordersLaws

Organization(company)

Notifications

Guidelines

Refer to the following web site to search for domestic laws andregulations (Laws and regulations data provision system)
http://www.japaneselawtranslation.go.jp/?re=02
6

4. Compliance education
4.1 Scope of the educational content (laws and regulations) (continued)
The main laws and regulations with a deep relationship to the aerospace industry–

Aircraft Manufacturing Industry Act [Ministry of Economy, Trade and Industry] A law forbusiness permission for the manufacturing and repair of aircraft and equipment for aircraft–

Civil Aeronautics Act [Ministry of Land, Infrastructure, Transport and Tourism] A law for thesafety of aircraft navigation and for preventing damages arising from aircraft navigation–

High Pressure Gas Safety Act [Ministry of Economy, Trade and Industry]
A law for preventing accidents caused by high pressure gas. Related to manufacturing equipment,
facilities, etc. using high pressure gas–

Explosives Control Act [Ministry of Economy, Trade and Industry] A law for preventing accidents
with explosives. Related to articles processed with heat, etc. for aircraft.

–

Measurement Act [Ministry of Economy, Trade and Industry]
A law for ensuring the implementation of proper measurement. Related to the use of measurement units
based on the Imperial system in aircraft.

–

Radio Act [Ministry of Internal Affairs and Communications] A law to ensure the fair and efficientuse of radio. Related to equipment installed in aircraft.

–

Fire Service Act [Ministry of Internal Affairs and Communications] A law aimed at preventing
fires, reducing the harm caused by disasters such as fires, earthquakes, etc. and maintaining social order,and enhancing public welfare. Related to fueling facilities (storage tanks) for aircraft, etc. which are
categorized as dangerous facilities– The pollution prevention ordinances, etc. of prefectures [local governments]
In addition, the following international convention related to this area has been signed.
– Convention on International Civil Aviation [United Nations]74. Compliance education
4.1 Scope of the educational content (laws and regulations) (continued)

Relationships between the laws and regulations that have a
deep relationship to the aerospace industry (in relation to the
Civil Aeronautics Act)
Civil Aeronautics Act

Convention on
International Civil
Aviation

Ordinance for Enforcement of
the Civil Aeronautics Act

Ordinance for Enforcement of the Civil
Aeronautics Act Supplementary
Provisions

Circulars

Airworthiness inspection
guidelines

Published in the case that the
Civil Aviation Bureau clearlystates the more detailed
content of the Civil Aeronautics
Act and other related laws andregulations/the case of
publicizing the policies of the
Civil Aviation Bureau/the caseof publicizing general technicalmatters, etc.

FAA Regulations
Consistency(FAR)

Ordinance for Enforcement of the Civil Aeronautics Act Supplementary Provisions: these stipulate the"technical standards for ensuring the safety of aircraft and equipment" and they are normally called the"airworthiness requirements."
Airworthiness inspection guidelines: guidelines for determining whether aircraft and equipment satisfy the
airworthiness requirements.
8(Consistency with the FAR Part 25, 27, 29 of the FAA is ensured.)4. Compliance education
4.1 Scope of the educational content (laws and regulations) (continued)
Particularly in the globalizing aerospace industry, it is necessary to be careful
about domestic laws and regulations related to exports and imports and also
overseas laws and regulations.
Some representative examples of related laws and regulations are shown
below.
Japan’s laws and regulations:
Foreign Exchange and Foreign Trade Act: Ministry of Finance
Export Trade Control Order: Ministry of Economy, Trade and Industry
Reference: refer to http://www.meti.go.jp/policy/anpo/englishpage.html
regarding the cargo export control parameters.
Examples of overseas laws and regulations:
Export Administration Regulations (EAR): U.S. Department of Commerce
Laws and regulations controlling the provision of dual use technologies
International Traffic in Arms Regulations (ITAR): U.S. Department of State
Laws and regulations to control the disclosure of technologies and materials
related to military items and services
94. Compliance education

4.1 Scope of the educational content (in-house rules and manuals)
It depends on the size of the organization, but there can be awide range of in-house rules and regulations, includingorganization-wide regulations such as the Articles ofIncorporation, the regulations for dividing duties among
employees, the employment regulations, etc., and manuals forindividual operations and work procedures, etc. used inindividual workplaces.
Therefore, just as with laws and regulations, it is desirable fororganizations to plan education that makes the distinction
between the rules that all of the employees have to know andthe rules the employees have to know in their respective workduties.
(Unlike laws and regulations, in-house rules are established by
the organizations themselves, so identifying the target of therules is easy.)10

4. Compliance education
4.1 Scope of the educational content (business ethics)
Business ethics generally refers to the standards thatorganizations should comply with when implementing theircorporate activities; they regulate corporate activities to ensurecompliance with laws and regulations and also with moral
perspectives such as nature and the social environment,
protection of human rights, etc. and include methods ofbuilding and managing mechanisms for controllingorganizations.
Normally they are established as the "company philosophy"and "guidelines for action" and are published in many cases.
Naturally, education is provided to all of the employees in orderto ensure they are informed about the matters which apply to allof the employees.
114. Compliance education
4.1 Scope of the educational content (social norms)
Social norms generally refer to the laws, morals, andcustoms that people must comply with when living insociety.
Therefore, they are broadly learned through education in
the home and school education but because incidents
contrary to social norms have become prominent, social
norms have become understood as one of the elements
included in business ethics and there are manyorganizations reflecting social norms in their "company
philosophy" and "guidelines for action."124. Compliance education
4.2 Educational methods
General methods used to educate employees about compliancecan be shown below(1) Learn by themselves using distributed compliance educational
package.
(2) e-learning(3) Hold training sessions (internal and/or external training)・Organization should select what method to adopt based on
the level (importance) of the educational content
・It is recommended to adopt method (3) because of following reason;- in case of (1): there is a high likelihood that the employees who
are given the educational materials will not do anything, so it isthought that this is the least effective form of compliance education- in case of (2): if the consideration is not taken sufficiently
for the method of application then there is a risk of the sameoutcome as case (1),13

4. Compliance education
4.2 Educational methods (continued)•There is a large
difference in
implementation rate
between companies
that thought effective
and companies that
didn’t think effective

Information
notification by the
Intranet, etc.

Laws and regulations
training, study
sessions

Case studies,case methods

Utilization ofvideos or DVDse-learning

Low effect group

Educational anddiscussion sessions
in the workplace

Training byexternal lecturers

High effect group

Training andexplanations byin-house lecturers

Distribution of inhouse code of
conduct,
handbooks, etc.

Difference between the education implementation rate and the overall average

Question 3: In fiscal year 2009 what kinds of education about compliance did you implement for each subject?
(by educational effect)

High effect group = The group that answered “Question 5: Was the education
effective?” with “1. Definitely effective” or “2. Thought to be effective”
Low effect group = The group that answered “3. Thought to be ineffective”,“4. Not effective at all” or “5. I don’t know.”

From JMA Research Institute Inc.「コンプライアンス教育に関する調査報告書(2010）」

Training such as laws and regulations training, study sessions, etc.
and e-learning are highly effective

14

4. Compliance education
4.3 Essential points of education
Elements that influence the "educational effects" when providing education
include the following.
(i) Continuity
The longer organizations continue education, the better response they could
obtain. "Endurance makes you stronger.”(ii) Educational methods
It will result in better response from the attendees when the method which theattendees feel something familiar to their work, not general theory, is used fortraining such as;・Implementing in-house/ industry specific case studies
・Giving each individual employee opportunities to think,・Establishing opportunities to talk to the employees and managers in educationaland discussion sessions in the workplace(iii) Hours of education
The education will not necessarily be more effective even if the duration of study
is increased. Since organizations that are producing good results are working hardto provide high quality education within limited hours, and to introduce multiple
educational methods ,the difference in educational effects is not very closely
related to the number of hours of study.
From JMA Research Institute Inc.「コンプライアンス教育に関する調査報告書(2010）」

15

4. Compliance education
4.3 Essential points of education (continued)
Question 5: Was the education effective(improved
awareness of compliance among the employees,
reduction in dishonesty, accidents, etc.) through thecompliance education overall? (n = 313)
It is moretrue to say I
didn’t feel
an effectthan to say I
did feel aneffect5.4%

Question 5: Was the education effective(improved
awareness of compliance among the employees,
reduction in dishonesty, accidents, etc.) through thecompliance education overall? (by education staringyear)

I didn’t feel
an effect
0.3%
LegendIt is more true to say I
felt an effect than to say
I didn’t feel an effectI felt an effectI don’tknow
12.1%

Started by 1999
(n=40)
I felt aneffect34.8%

It is moretrue to say I
felt an effectthan to say I
didn’t feel
an effect
47.3%

Started between 2000
and 2002 (n=64)

Started between 2003
and 2005 (n=109)

Started in 2006 orlater (n=77)

I didn’t feel
an effect

It is more true to say I
didn’t feel an effectthan to say I did feel aneffectI don’t know

Theorganizations
start education
earlier = The
longerorganization
implement
education, thebettereducational
effect they
could
recognize.

From JMA Research Institute Inc.コンプライアンス教育に関する調査報告書』(2010）」

16

4. Compliance education
4.3 Essential points of education (continued)
Current

Question 3: In fiscal year 2009 what kinds of education
about compliance did you implement for each subject?
(n=310)FutureQuestion 7: Educational methods planned to be newly
added into compliance education in the current fiscal
year and next fiscal year (n=302)

Distribution of in-house code of conduct,
handbooks, etc.
Distribution of in-house code of conduct,
handbooks, etc.
Training and explanations by in-house
lecturers
Training by external lecturers
Educational and discussion sessions in theworkplacee-learning

Utilization of videos or DVDs

Training and explanations by in-house
lecturers
Training by external lecturers
Educational and discussion sessions in theworkplacee-learning
Utilization of videos or DVDs

Case studies, case methods

Case studies, case methods
Laws and regulations training, study
sessions
Laws and regulations training, study
sessions

Information notification by the Intranet, etc.

Information notification by the Intranet, etc.
OthersOthersI am not considering any additions

There are many organizations that are attempting training ande-learning using specific case studies
From JMA Research Institute Inc.コンプライアンス教育に関する調査報告書(2010）」

17

4. Compliance education
4.4 Enhancing "perceptiveness"
Even if education is provided, when employees become
busy in their daily work duties, they sometimes can't
recognize the abnormal condition as “abnormalities”
whether intentionally or not, due to “familiarity” and“assumption” such as “we have always done it this way inthe past", “about this much should be ok", “others arealso doing the same thing," etc.
Giving employees such "perceptiveness" to abnormalities
is getting much more important as a part of employees
awareness, together with education about the laws andregulations, in-house rules and business ethics.
18

4. Compliance education
4.4 Enhancing "perceptiveness"(continued)
How can we enhance employees "perceptiveness"?
 Create time (opportunities) for reviewing one’s own work duties
Are any actions different from the regulations being overlooked due
to"familiarity“?
Occasionally it is important to take a step back and objectively observe yourown behavior (work).

 Create a workplace atmosphere (culture) in which employees can talk toand consult with the people around them if they feel doubts even slightly
Do you ever feel doubts but brush off them by saying “it will be all right, let it
be...” because it is too bothering to deal with? If there is no atmosphere(culture) in which doubts can be easily identified /said , then anawareness/perceptiveness will not take root.

 Focus on change
Change always accompanied by risk. Understand change points asopportunities for “perception."194. Compliance education
4.5 Summary Educational content• It should include not only laws and regulations but also in-houserules and manuals, business ethics and social norms, and it should bedesigned based on the size and circumstances of each organization.
 Educational methods• The main methods include (1) distribution of educational materials,(2) e-learning, (3) holding of training sessions, etc. but it isrecommended to continuously implement training that gives
individual employees opportunities to think, such as the adoption of
specific case studies, discussion formats, etc.
• Should establish opportunities not only for training but also forenhancing daily "perceptiveness".

20

5. Reference information(The relationship between work and laws/regulations)

Work (contracts) and laws/regulations are closely connected21

5. Reference information(The relationship between work and laws /regulations)

For commercial aircraft• Manufacture prototypes and carry out tests to confirm that the design issafe. (TC: Type Certificate)• Safe aircrafts are built by manufacturing them in accordance with theconfirmed design.
• In order to ensure that when 100 aircrafts are made 100 identical aircrafts
are made, it is required to define regulations / procedures, document them,and manufacture the aircrafts in accordance with them.
(PC: Production Certificate)⇒ I.e. it is necessary for all employees to recognize the importance ofperforming their work (job) in accordance with regulations/ procedures.
22

6. Examples
Example of lists of related laws and regulations
Job and work place related laws
Act

Note

Penalties
Antitrust related laws

Sexual Harassment

Power Harassment

Act

Penalties (example)○ Private Monopolization“Private Monopolization” means ……
(Ref. Antitrust Law Article 3, 2-5)

- Individual imprisonment 3years
or Individual’s fine ¥5,000,000- Company’s fine ¥500,000,000- Representative imprisonment 3years
or representative fine ¥5,000,000○ Unfair restraint of trade“Unfair restraint of trade” means ……
(Ref. Antitrust Law Article 3, 2-6)

- Individual imprisonment 3years
or Individual’s fine ¥5,000,000- Company’s fine ¥500,000,000- Representative imprisonment 3years
or representative fine ¥5,000,000○Unfair Trade“unfair trade” means ………
（Ref. unfair trade law Article 2-9, 19)○Unfair Trade- abatement order(article 20)- injunction demand (article 24)- indemnity (article 25)

Secret Leak

Falsity Registration
Copy right
Infringement
TrademarkInfringement

From Principle Consulting Inc. 「仕事と職場のコンプライアンス

関連法令の概要」

23

6. Examples
Example of Compliance Training (i) The essential points of the training(i) The objectives of compliance education are to aim to build
organizations with good communication through discussions withinorganizations (workplaces, groups, teams, etc.), and to firmly establish
improvement of the compliance awareness of each and every employee.
(ii) Case studies that use “incidents that could happen” or “actually did
happen” at organizations, such as “falsification of data, taking out data(including PCs) from the workplace without permission, illegaltransactions, etc.” to hold discussions among the members are effective
for obeying laws and social rules and giving employees "perceptiveness.”(iii) Depending on the number of people, the duration for the discussions
should be about one hour.
(If the discusion takes place for a long time, there is a risk that theconversation will go in a different direction and it will be difficult to returnto the main topic.)24

6. Examples
Example of Compliance Training (i) (continued)
 Preparation prior to Training
The managers or leaders should prepare "case studies and questions"
beforehand and distribute them to the participating members in advance(several days in advance) to get individual employees to think about
their views on the issues. Prepare "case studies and questions" with
contents like the following.
•For the case studies, use “incidents that have occurred" and “incidents that could
occur".
•The questions include “Where do you think the responsibility lies? Does it lie with anindividual? Does it lie with the company? Or somewhere else? "“What do you think your superior should have done?"“What actions do you think should have been taken by your colleague who noticed the
problem?"“What do you think about the response of the company? Do you think there was anythinglacking in the response?
“What would you do to take a corrective action for this problem?" etc.
25

6. Examples
Example of Compliance Training (i) (continued)
 How to proceed with the discussion• It should not be the managers (leaders) speaking all of the time; actively
encourage the members to speak.
• The managers (leaders) focus on being moderators for the discusssion and do
not reject the statements of the members.
• If there are members who do not speak, the managers (leaders) interjectquestions to them such as “What do you think?"• The most important aim of the education is to get everyone to think, speak, andarrive at the correct answer, so that the “perceptiveness" of all of the members is
improved.
• If the conclusion is mistaken, guide the members to the correct answer by saying
things such as “How about putting it this way?" (Of course, the managers(leaders) should prepare the correct answer in advance.)• The education will be even more effective if each of the members is encouraged
to speak about their awareness, etc. after the discussion, regarding the issues thatwere discussed.
26

6. Examples
Example of Compliance Training (i) (continued)
 Follow-up after training
The managers (leaders) endeavor to confirm in daily communication
whether or not the content that was discussed is being utilized in daily
work duties.

 Other points of attention
It is necessary to be careful regarding the risk that discussion about“incidents that occurred in the workplace" will result in personal
attacks on individuals.

27

6. Examples
Example of Compliance Training (ii) Training in a discussion format based on casestudies(Improving “awareness” not “knowledge”)
 Make all employees fully aware of the fact that“compliance violations are never legitimate no
matter what the motivation or backgroundcircumstances, or what pressure you may beunder”
 Top executives themselves should make a"compliance declaration" and then the training will
start

28

6. Examples
Example of Compliance Training (ii) (continued)(1) Overview of the training(i) Required time: about one hour(ii) Theme: select the content matched to the workplace.
“Subcontracting transactions”, “harassment”, “accounting processes”, “theenvironment”, “labor management”, or “corporate secrets”, etc.

(iii) Participants: all employees (including temporary employees and partners)(2) Implementation of the training(i) Superiors gather together their subordinates, and explain the improvement ofawareness of behaving correctly by holding discussions with them. (Not simply present
the correct answers to questions)(ii) Encourage discussions involving questions such as “What would you do?" and “Whydo you think this situation arose?" etc.
(iii) Also present cases in which employees were punished. Explain that they are required

to act in accordance with the “perspective of society”. (CSR)
29

6. Examples
Example of Compliance Training (ii) (continued)30

7. Reference documents
 JMA Research Institute Inc.
「コンプライアンス教育に関する調査報告書」（2010）(Japanese only)
http://jmar-im.com/keiei/keiei_1_page210.html
 Principle Consulting Inc.
「仕事と職場のコンプライアンス(Japanese only)

関連法令の概要」資料

http://www.principleconsulting.co.jp/tools/Shigototo_Shokubano_Compliance_120301.pdf

31

8. Editor’s Note









These materials were written mainly for the people in organizations who plan and implement
compliance education.
Organizations involved in the aerospace industry, which requires high levels of safety andtrustworthiness, are required to diligently engage in their operations with the conviction that"quality and safety have priority over everything else" at all times. We think it is necessary for
employees to be sufficiently aware that “compliance is a major precondition” for the execution of
their work duties and that "compliance is the foundation of everything."
However, the difficulty of compliance education is that it is difficult to perceive its direct
relationship to one’s own work duties in the daily operations. It is too late once a problem has
already occurred, but for some aspects understanding deepens when a problem related to one’s
own work duties has occurred close at hand, so it appears that for the people in charge ofplanning education, a major worry is how to provide effective education that has an emotional
impact on employees. In other words, the burden (pressure) on the people in charge of planningeducation is that large, but when the organization as a whole is aiming to provide effective
compliance education, then of course we think it is essential for the top executives themselves
to take initiatives to get their employees to perceive the importance of compliance education.
Generally it seems that even if students understand the content of education while they arereceiving it, they often forget everything after the education has finished. The objective ofeducation is not to provide education; it is to utilize the knowledge and experience obtained
through the education in one’s own work duties. It is not easy to ensure that each and every
employee continues to have awareness of this fact; furthermore there is no magic bullet forachieving this. Just as in the saying that “That's life. Every day is a new adventure in learning.“
it is desirable to continue making steady efforts believing that true strength comes fromcontinuation.
We hope that in terms of the above perspectives, these materials will be a useful reference forpeople who plan and implement compliance education.
32