Compliance

Basic Policy

While meeting its corporate social responsibilities, the Company is engaged in various business activities, mainly in the energy distribution fi eld. Meeting the expectations of all its stakeholders, which include customers/consumers, business partners, suppliers,communities, shareholders, investors, employees and the environment, is an important management task. To this end, under the Corporate Philosophy, “The best partner for life and society,” the Company is striving to raise awareness of and promote social responsibility Group-wide by ensuring that all managers and employees correctly understand and thoroughly comply with the Code of Conduct and the Declaration of the Group Code of Conduct, which have been refi ned over many years.

Compliance Structure

The Company has taken steps to improve its compliance system. Those steps include appointing a CCO, establishing a department that oversees matters concerning compliance, developing a corporate social responsibility (CSR) and compliance program, appointing a CSR and compliance manager1 and personnel2 in each department, providing compliance education and training, compiling a legal and regulatory compliance manual, clarifying responses to compliance incidents and establishing a whistleblowing system. In addition, each Director, Executive Offi cer and employee is required to submit a written statement of intention to comply with the Code of Conduct.

1. CSR and compliance manager:
CSR and compliance managers of Itochu Enex are appointed by the CCO. One person from each division is appointed. Additionally, at Group companies for which Itochu Enex has over 50% ownership, in principle the president of the Group company serves as CSR and compliance manager, also supervising subsidiaries for which that Group company has over 50% ownership.

2. CSR and compliance personnel:
CSR and compliance personnel are appointed by CSR and compliance managers, promoting awareness regarding CSR and compliance, serving as the point of contact in the event of trouble, accidents, misconduct or complaints, and ensuring environmental preservation and soil contamination prevention.

*About the expression "CSR and compliance"
Itochu Enex places high importance on the legal compliance aspect of corporate social responsibility and uses the expression "CSR and compliance" to foster awareness of the importance of compliance throughout the Group.

Education and Training in CSR and Compliance

With the objective of maintaining and ensuring the universal recognition of CSR and compliance systems, the Company holds education and training in CSR and compliance for Group offi cers and employees on an annual basis. In particular, compliance training is held across Japan twice a year, once each fiscal half.

Promoting Awareness of Compliance

To promote awareness of compliance, the Company periodically prepares documents to be distributed within the Group and shared on the intranet.

Group Awareness Survey

In the present day, incidents relating to accounting misconduct, embezzlement, harassment, and labor issues at various companies, organizations, and bodies are on the rise. The Group conducts a compliance awareness survey for offi cers and employees at Group companies to ascertain the state of compliance awareness and help prevent misconduct. The results are drawn on to create new initiatives and improve compliance training, and are also used as a measure of engagement with the Corporate Philosophy.

Whistleblowing and Consulting Contact Points

The Group has established inside and outside whistleblowing contact points. These contact points offer a prompt response to employees with concerns that they may have violated or be about to violate the Declaration of the Group Code of Conduct or laws, or when they know of a violation committed by an offi cer or another employee and cannot point out the violation to that person, or when they have determined that a violation is likely to occur. Through regular CSR and compliance training, the Group ensures that all employees are aware of whistleblowing contact points and the protection given to whistleblowers, and a system is in place for responding appropriately to whistleblowing while maintaining transparency.
Additionally, the Group has made available an outside consulting contact point for any employee or family member associated with the Group. This consulting contact point can also respond to issues concerning harassment, mental health, physical health and living circumstances. A system for providing care for mental health and consultation on other issues is maintained through responses 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 the various parties that handle reports.These regulations prohibit unfavorable treatment, including termination of employment, as a consequence of whistleblowing, and mandate confidentiality.