Compliance
Basic approach
Compliance at the Idemitsu Group means not only ``compliance with laws and regulations'' and ``compliance with internal regulations and contracts,'' but also refraining from engaging in acts that are ethically and socially unacceptable even if they do not violate laws and regulations.In other words, maintaining high ethical standards. This means to discipline ourselves with humility and act with integrity.
In order to spread the compliance mindset that each and every employee should have and to practice actions based on it, we aim to provide more concrete and simple explanations of what kind of behavior compliance refers to, targeting employees working all over the world. We have established the Compliance Code of Conduct to provide easy-to-understand information.
Policy
In line with the "Integrity" stated in Action Mindset, we have established the following specific compliance code of conduct for employees working around the world, including both overseas and domestically. In addition, we have compiled specific standards of conduct related to compliance in a compliance book, which is regularly reviewed for effectiveness 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 treats reports from each business division and various consultation centers as cases of compliance concerns, and the Risk Management and Compliance Committee provides response support, instructs and requests for investigations, and deliberates and confirms measures to prevent recurrence. I am.
Number of serious compliance violations in FY2022: 2 cases
(Inappropriate acts related to product testing at TOA Oil Co. and Showa Yokkaichi Sekiyu Co.)
*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 domestically and overseas are reported to the Risk Management and Compliance Committee. The Risk Management and Compliance Committee thoroughly protects the confidentiality of those who consult and prevents any disadvantage, and if necessary, appoints an investigator to investigate the facts, and then considers countermeasures and disciplinary measures. In addition to providing feedback to those seeking advice, we are working to prevent recurrence in accordance with our compliance promotion system.
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 approximately 40 bases in China, Asia/Oceania, the Middle East, Europe, Russia, North America, and South America, covering almost all overseas Complex, and supports all languages of the countries where local subsidiaries are located.
| Domestic /abroad inside the company /external |
Counter name | Reception | Target audience | Consultation case Target range |
Consultation method | 2022 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 |
22 items |
| Harassment consultation counter |
Human resources department | Sexual harassment, power harassment, and other types of harassment | In principle, real name consultation email, letter |
22 items | ||
| Domestic /External |
External third party contact point "Workplace Helpline" |
Third party (Industrial Counselor) |
Compliance in general, harassment in general | Anonymous consultation possible email, phone |
6 | |
| 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 | 7 items |
Anti-bribery and corruption
Our Group's Compliance Code of Conduct stipulates that we will prevent all forms of corruption both domestically and internationally. Furthermore, we have established basic matters to be observed and necessary systems for preventing bribery, and are working to prevent violations of the OECD Convention, FCPA (Foreign Corrupt Practices Act), unfair competition prevention, and other laws and regulations of each country that prohibit bribery. For this purpose, we have established and are implementing the Anti-Bribery Regulations. We position anti-corruption as key challenges, especially at overseas bases, and will educate the importance of specific preventive measures. Additionally, in our Compliance Book, we include information on the prohibition of bribery (prohibition of bribing public officials) and restrictions on gifts and entertainment to educate employees.
Number of corruption/bribery incidents in FY2022: 0 cases
Number of employee disciplinary actions related to corruption and bribery in FY2022: 0 cases
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
Compliance e-learning is held regularly once a year. In November 2022, 18,418 employees of our company and 58 domestic group companies participated in the training, with the aim of gaining mutual understanding about power harassment in the workplace, as well as acquiring knowledge about the revised Whistleblower Protection Act and the whistleblowing system. I took the course (attendance rate 100%). 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
Since June 2022, we have been conducting awareness raising using posters and distributing them to Refinery, Complex, research institutes, and group companies. At our head office, we also use digital signage to disseminate information.