ITOCHU ENEX CO.,LTD.

Compliance

Basic policy on compliance

To enhance corporate value, efforts to build a trust-based relationship with society are necessary. The prerequisite for building trust-based relationships is compliance. We believe compliance practices are an important issue for the enhancement of our corporate value. To embody this, each employee will increase their compliance awareness and work to build a compliance promotion system so that we can stay focused on our work in compliance with Code of Conduct and Declaration of the Group Code of Conduct.

Compliance Structure

The Company has taken steps to enhance its compliance structure. Those steps include the appointment of a Chief Compliance Officer (CCO), the establishment of a department overseeing compliance-related matters, the development of a compliance program, the appointment of compliance manager and personnel in each department and Group company, the provision of compliance training, the creation of a legal and regulatory compliance manual and the development of methods for handling compliance incidents and a whistleblowing system. In addition, all Directors, Executive Officers and employees are required to submit a written statement of intention to comply with the Code of Conduct.

Compliance Training and Communication

The Company provides regular training to maintain its compliance promotion structure and keep its employees informed of it. The Company formulates and implements plans top provide training sessions to increase the Enex Group's awareness of compliance and to comply with the rules that are a necessary part of its businesses (including laws, regulations, and internal rules) in its efforts to prevent compliance incidents.

Group Awareness Survey

Scandals such as accounting fraud, embezzlement, harassment, and labor issues occur at many companies, organizations and groups. In response, the Enex Group conducts a compliance awareness survey of officers and employees of Group companies to find facts about compliance awareness and penetration of the Corporate Philosophy in the Group and prevent the occurrence of misconducts and compliance incidents in the Group.
Based on results of this survey, the Group provides compliance training and takes other new measures.

Whistleblowing and Consulting Contact Points

The Group has established internal and external whistleblowing contact points to enable the prompt reporting of violations of laws, regulations or internal rules and inappropriate behaviors that have occurred or could occur.
The Group informs employees of the system of whistleblowing contact points and the protection given to whistleblowers via internal compliance training. Thus, a system is in place for responding appropriately to whistleblowing while maintaining transparency.
Additionally, the Group has made available an external consulting contact point for any employee or family member associated with the Group.
This consulting contact point also provides consultations concerning harassment, mental health, physical health and livelihood.
A system for providing care for mental health problems and consultation on other issues is maintained, with services provided by specialists such as clinical psychologists, health nurses, and consumer affairs advisors.
The Group ensures the effectiveness of the whistleblowing system through regulations that clearly define the responsibilities of various parties that handle reports. These regulations prohibit termination of employment and other unfavorable treatments as a consequence of whistleblowing and mandate confidentiality of information related to whistleblowing.

Bolstering measures to fight corruption and briber

The ITOCHU ENEX Group established its policy with the goals of maintaining healthy relationships with civil servants and business partners, ensuring the fairness and equitability of transactions and preventing corruption and bribery in compliance with our Code of Conduct, “Be Ethical (Reliability and sincerity, creativity and ingenuity, transparency and integrity),” and Declaration of the Group Code of Conduct.

1. ITOCHU ENEX Group Anti-Corruption1 Policy
• The ITOCHU ENEX Group established regulations and guidelines regarding the prohibition of illegal profit sharing, for the purpose of obeying applicable laws and preventing acts of corruption or bribery. The Group also defined and rigorously enforces rules regarding application, approval and reporting procedures in terms of the types of act that may easily be used in corruption or bribery.
• The ITOCHU ENEX Group has an office for the reception of reports from whistleblowers to make it possible for anyone, upon learning about a violation of an applicable law or an in-house rule or about any act that goes against socially accepted ideas, to promptly report the matter to the office and seek advice regarding it.
 
[ITOCHU ENEX Group Anti-Corruption Policy]
  No money, entertainment, gifts, or anything of value shall be given to any public or quasi-public official inside or outside of Japan, to obtain illicit gains.
 No money, entertainment, gifts, or anything of value shall be given to any director, officer or employee of any private entity, to obtain illicit gains.

2. Requests for All Partners
In order for the ITOCHU ENEX Group to implement the above anti-corruption policies, the ITOCHU ENEX Group requires the cooperation of all of its business partners. When necessary, we may request that our partners sign written agreements that include anti-bribery clauses. On behalf of the ITOCHU ENEX Group we thank you for your understanding and cooperation.

1 Corruption: Making use of a position of power or authority for personal profit, including acts such as embezzlement, fraud, and money laundering. 

ENEX Group Tax Policy

ITOCHU ENEX Corporation and the ENEX group companies (collectively, “the ENEX Group”) have established a Basic Policy: To comply with all applicable tax laws, rules, regulations, and tax treaties (collectively, “Tax Rules”) of each country and region where the ENEX Group conducts business.
The ENEX Group is committed to respecting the interests of all stakeholders, including all of the countries and regions where the ENEX Group conducts business, as well as the ENEX Group’s shareholders, creditors, business partners, and employees.

Basic Policy - Compliance with Tax Rules

The ENEX Group is committed to managing its business operations in full compliance with all applicable Tax Rules and not engaging in transactions that are intended to evade or avoid taxes.

Tax Cost Management

In accordance with the Basic Policy, the ENEX Group strives to achieve effective tax cost management by eliminating double taxation and utilizing the favorable Tax Rules of each country or region.

Maintaining Relationships of Mutual Trust with Tax Authorities

The ENEX Group strives to maintain a relationship of mutual trust with all tax authorities by engaging in constructive discussions and preparing documents in an accurate, timely and appropriate manner to ensure overall transparency of the ENEX Group’s tax matters.