- Home
- Sustainability
- Governance
- Compliance
Compliance
● Basic policy
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.
● Structures and Systems
・ 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.
・ Whistleblowing 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.
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.
● Initiatives Within the Group
・ 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.
・ 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.
ITOCHU ENEX Group Anti-Corruption Policy
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.
・ Tax Policy
The Itochu Enex Group has established the "Itochu Enex Group Tax Policy," which outlines its fundamental approach and code of conduct regarding tax matters. By adhering to this policy, the group strives to maintain and enhance tax compliance.
ENEX Group Tax Policy
1.Basic Policy - Compliance with Tax Rules
The ENEX Group is committed to manage its business operations fully complying with and following the significance and spirit of all applicable Tax Rules, not to engage in transactions that are intended to evade taxes, and to make appropriate tax payments based on income earned from its business activities.
2.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.
3.Establishing and Maintaining Relationships of Mutual Trust and Fairness with Tax Authorities
The ENEX Group strives to disclose information in an accurate, timely and appropriate manner to ensure overall transparency of the Enex Group’s tax matters and to establish and maintain a relationship of mutual trust and fairness with all tax authorities by making sincere response and engaging in constructive discussions, to ensure proper and fair taxation.
・ Insider Trading Regulations
Itochu Enex has established and enforces the "Regulations on Insider Trading, etc." to ensure the thorough prevention of internal transactions (commonly known as "insider trading"), information communication acts, and trade recommendation acts that violate the Financial Instruments and Exchange Act and related administrative orders by officers and employees. Additionally, regular training sessions are conducted to reinforce compliance.
・ Response to Compliance Issues
In the event of an accident or incident within Itochu Enex or its group companies, compliance officers and personnel take necessary actions in accordance with the "Accident and Complaint Reporting Standards." In cases where an incident involves violations of laws or internal regulations, the need for disciplinary action and its justification are clearly established. Opinions from external experts such as lawyers are sought as necessary, and appropriate disciplinary measures are taken in accordance with the standards and other criteria set forth in internal regulations.