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
We have established the following specific compliance code of conduct for employees working around the world, both in Japan and overseas. Specific compliance-related standards of conduct are compiled 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
Reports from each business unit and notifications to various consultation channels are treated as compliance concerns. Risk Management and Compliance Committee provides support for these cases, directs and requests investigations, and deliberates and confirms measures to prevent recurrence, ensuring appropriate responses and thorough prevention of future occurrences.
There were no serious compliance violations in fiscal year 2025.
Number of serious compliance violations in fiscal year 2025: 0
*Instances of violations disclosed as having a significant impact on group management
Anti-bribery and corruption
Our "Compliance Code of Conduct" includes anti-corruption measures as one of its items, and stipulates that we must maintain sound and transparent relationships with public officials and administrative bodies, both domestically and internationally, when conducting our business activities.
Specifically, the "Regulations for the Prevention of Bribery" and the "Guidelines for the Prevention of Bribery Against Domestic Public Officials, etc."
It is equipped.
Number of anti-corruption and bribery cases in fiscal year 2025: 0
Number of disciplinary actions taken against employees for corruption and bribery in fiscal year 2025: 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.
Establishment of a consultation desk
All cases received through compliance consultation desks, both domestically and internationally, are reported to Risk Management and Compliance Committee. The Committee Secretariat appoints an officer capable of conducting investigations and implementing corrective measures in an impartial manner. The committee assesses the investigation results, corrective measures, and measures to prevent recurrence, and provides feedback to the person who made the inquiry. In fiscal year 2025, there were a total of 96 cases, with the largest proportion being related to the work environment, including harassment. Our group has established workplace harassment prevention guidelines and conducts various education and training programs, including harassment prevention.
Domestic reporting desk
We have established internal contact points primarily for compliance and harassment-related consultations. We also have an external contact point where a third party handles inquiries, and telephone support is available from counselors who are certified industrial counselors.
Each consultation service is listed on the company's internal portal site and also displayed on posters so that everyone is aware of its existence. In addition to ensuring the confidentiality of all consultations, regulations prohibit any adverse treatment of those who report or consult, thus protecting those who seek consultation.
Starting in fiscal year 2026, we changed our external third-party compliance contact point to a law firm and conducted lectures for group employees on how to use the contact point, delivered by lawyers.
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.
● Number of consultations received at the consultation desk
| Classification at reception | FY2024 | FY2025 |
|---|---|---|
| Working environment (harassment, labor relations, etc.) | 41 | 51 |
| Leakage and loss of assets and information | 0 | 2 |
| accounting fraud | 1 | 0 |
| Violation of laws and regulations | 18 | 34 |
| Others | 7 | 9 |
| Total | 67 | 96 |
Our Customer Center accepts any external complaints or inquiries, and works with the Compliance Consultation Desk to respond appropriately.
Initiatives
Compliance promotion activities
In accordance with our compliance code of conduct, we provide continuous education and training to ensure that each and every employee of our group acts with high ethical standards, integrity, and fairness.
Compliance book
In 2020, we published a compliance booklet outlining specific behavioral standards related to compliance, including the prevention of corruption and conflicts of interest, and the prohibition of insider trading. This booklet is regularly revised and used by all group employees as a tool to confirm specific behavioral norms. In addition to the Japanese version, the compliance booklet is also published in English and Chinese, and efforts are made to ensure thorough dissemination to group employees both domestically and internationally.
Compliance education
In addition to the annual Compliance e-learning program, the Idemitsu Group provides various education and training programs, including those related to harassment prevention, such as strengthening awareness of Human Rights Policy and formulating a harassment prevention guide.
● Internal education and training achievements related to compliance (FY2025)
| Education/Training Name | Implementation period | Target audience | Number of participants | Attendance rate |
|---|---|---|---|---|
| Compliance e-learning | February-March 2026 | Employees of our company and 48 domestic affiliates | 13,438 people | Approximately 99% |
| Face-to-face compliance training | August to October 2025 | Employees of 14 domestic affiliated companies | Approximately 1,700 people | Approximately 49% * |
| Compliance training session | March 2026 | Our employees | 1,108 people | 22% * |
| Compliance training for new employees * Conducted as part of new employee training. |
April 2025 | New employees for fiscal year 2025 | 150 people | 100% |
| Compliance training for newly appointed managers * Conducted as part of training for newly appointed managers |
June 2025 | Newly appointed officers for fiscal year 2025 | 106 people | 100% |
| Harassment prevention seminar for all employees | November 2025 | Our employees | 1,077 people | 18% * |
| Harassment prevention seminar for managers and executives | December 2025 | Company executives | 687 people | 46% * |
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Only live participants on the day will be counted (recorded viewers will not be included).
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.