Compliance
Basic approach
At the Idemitsu Group, compliance not only means complying with laws and regulations and internal rules and contracts, but also not engaging in any ethically or socially unacceptable conduct, even when it does not violate the law. In other words, it means acting with integrity, self-discipline and a humble attitude based on high ethical standards.
To instill a compliance mindset among all employees working around the world and to ensure that they act accordingly, we have established the Compliance Code of Conduct, which explains more specifically, simply and in an easy-to-understand way what compliance means.
Policy
In accordance with the "Integrity" set forth in Action Mindset, we have established the following specific compliance code of conduct for employees working around the world, both domestically and overseas. In addition, specific compliance-related standards of conduct are compiled in a Compliance Book, and their effectiveness is regularly reviewed and revised.
Compliance Code of Conduct
1. Compliance with laws and regulations, rules, and morals
We will comply with domestic and international laws and regulations, social ethics, internal rules and contracts, and act in good faith as a good corporate citizen.
2. Respect for human rights
We will not tolerate any human rights violations, accept diversity in race, nationality, gender, etc., and create a healthy and comfortable workplace free from harassment.
3. Safety, quality, and environmental protection
We will make every effort to ensure the appropriate quality of our products and services, to prevent accidents and reduce losses caused by disasters, and to act with full consideration for the preservation of the global environment.
4. Fair and free competition
We will conduct business based on fair and free competition.
5. Anti-corruption
In conducting our business activities, we will maintain sound and transparent relationships with public officials and the government, both in Japan and abroad.
6. Information disclosure and management
We will disclose information appropriately to society at large, ensure management transparency and soundness, and appropriately manage information held by the company.
Governance
Risk management
Responding to concerns about compliance violations
The Group regards reports from each business division and reports to various consultation desks as cases of compliance concern, and Risk Management and Compliance Committee provides support for dealing with these cases, issues instructions or requests for investigations, and discusses and confirms measures to prevent recurrence.
Number of serious compliance violations in fiscal 2023: 0
During the fiscal year under review, there were no significant compliance violations or violations of laws and regulations due to corruption or bribery, and no fines or surcharges were paid.
*Instances of violations disclosed as having a significant impact on group management
Establishment of a consultation desk
All cases received by the Compliance Consultation Desk, both in Japan and overseas, are reported to Risk Management and Compliance Committee. The Risk Management and Compliance Committee Secretariat will strictly maintain the confidentiality of those who make inquiries and will appoint a person (who will be involved in accordance with laws, regulations and rules) who will be able to investigate and take corrective measures in a fair manner, while ensuring that those who make inquiries do not suffer any disadvantage.
The secretariat will also determine the results of the investigation and any corrective measures, as well as the appropriateness of measures to prevent recurrence, and will provide feedback on the investigation results etc. to the person who made the complaint.
Domestic reporting desk
We have established in-house contact points that primarily accept consultations regarding compliance and harassment. We have also set up an external contact point where a third party can act as a point of contact, and telephone calls can be answered by consultants who are qualified as industrial counselors.
Each consultation desk is posted on the internal portal site and also on posters so that everyone knows its existence. In addition to maintaining the confidentiality of the content of consultations, we have set out regulations that prohibit disadvantageous treatment of those seeking advice for reporting or consulting, in an effort to protect those seeking advice.
Overseas reporting desk
We have established the Idemitsu Global Hotline (IGHL) to respond to reports from overseas Complex. It covers almost all of our overseas Complex, covering approximately 40 locations in China, Asia/Oceania, the Middle East, Europe, Russia, North America, and South America, and is available in all languages in the countries where our local subsidiaries are located.
| Domestic /abroad inside the company /external |
Counter name | Reception | Target audience | Consultation case Target range |
Consultation method | 2023 year reception number |
|---|---|---|---|---|---|---|
| Domestic /Internal |
Compliance consultation desk | General affairs department | Officers and employees of the Company and its affiliated companies (including part-time workers, part-time employees, seconded employees, and temporary employees), and those who have retired within one year of retirement. | Fraud, scandals, and other general compliance matters | In principle, real name consultation email, letter |
18 Results |
| Harassment consultation counter |
Human resources department | Sexual harassment, power harassment, and other types of harassment | In principle, real name consultation email, letter |
37 Results | ||
| Domestic /External |
External third party contact point "Workplace Helpline" |
Third party (Industrial Counselor) |
Compliance in general, harassment in general | Anonymous consultation possible email, phone |
19 Results | |
| Abroad /Internal |
Idemitsu Global Hotline (IGHL) | General affairs department | Employees of our Group's overseas Complex (including national staff and employees seconded from our company) | Fraud, harassment, illegal acts related to occupational safety, safe environment, and quality assurance, human rights issues | 8 Results | |
| Total | 82 Results | |||||
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Our Customer Center accepts any external complaints or inquiries, and works with the Compliance Consultation Desk to respond appropriately.
Anti-bribery and corruption
In our Compliance Code of Conduct, we have set out our commitment to preventing all forms of corruption, both domestic and international. Furthermore, we have established and are implementing our Anti-Bribery Regulations to set out basic matters to be observed and the necessary systems for preventing bribery, and to prevent violations of the OECD Convention, the Foreign Corrupt Practices Act (FCPA), the prevention of unfair competition, and other national laws and regulations prohibiting bribery. We consider corruption prevention to be key challenges, especially at our overseas bases, and we raise awareness of the importance of specific preventive measures. In addition, we have published the prohibition of bribery (prohibition of bribery of public officials) and restrictions on gifts and entertainment in our Compliance Book to raise awareness among employees.
Number of corruption and bribery cases in fiscal 2023: 0
Number of disciplinary actions against employees regarding corruption and bribery in fiscal 2023: 0
Rules of conduct for preventing bribery and corruption (excerpt from compliance book)
We will not improperly provide, offer, or promise economic benefits such as money or goods to public officials or similar persons, whether domestic or overseas. We maintain healthy and transparent relationships with politicians and government. We will take a firm stance against unreasonable financial demands.
Prevention of anti-competitive behavior
Our Group's Antimonopoly Law Compliance Regulations stipulate the basic matters to be observed and necessary systems regarding the Act on Prohibition of Private Monopoly and Ensuring Fair Trade, competition laws of each country, and other related laws and regulations. The President and Representative Director is responsible for ensuring the proper implementation of these regulations and the prevention of prohibited acts, and the company's department heads and presidents of group companies are responsible for ensuring that the company's business content, organizational structure, national situation, antitrust laws, etc. We carefully consider risks and other factors and take appropriate self-management measures to embody these regulations.
Initiatives
Compliance promotion activities
In accordance with the Compliance Code of Conduct, we provide ongoing education and training to ensure that each Group employee acts honestly and fairly based on high ethical standards.
Compliance book
In 2020, we published a compliance book that describes specific standards of conduct related to compliance, such as preventing corruption and conflicts of interest, and prohibiting insider trading. It is revised regularly and is used by all Group employees as a tool to confirm the specific code of conduct. The Compliance Book is published not only in Japanese, but also in English, in an effort to ensure that all group employees in Japan and overseas are fully aware of it.
Compliance education
We conduct "Compliance e-learning" regularly once a year. In November 2023, we conducted a compliance e-learning course for employees of our company and 48 domestic affiliates with the aim of acquiring knowledge about the difference between power harassment and guidance and strengthening awareness of the Idemitsu Group Human Rights Policy. 16,557 employees took the course (100% participation rate). We also conduct training for new employees and newly appointed managers.
Compliance room
We have set up a ''Compliance Room'' page on our internal portal site with the aim of raising compliance awareness.We post examples of violations and four-panel comics, introduce the latest examples of external violations, and disseminate information widely within the group. Masu.
Other information dissemination
Starting in June 2022, we will be distributing posters to Refinery, Complex, research laboratories, and Group companies. In addition, at the head office, we are posting information on digital signage to disseminate information.