Policy and Strategy
Basic Views
One of the items in the IINO Group Sustainability Policy states that "The IINO Group adheres to all laws and regulations in each country and region where it conducts business activities, and also establishes compliance with competition laws and anti-bribery measures to promote fair trade. Additionally, we will not be involved with any antisocial forces or groups that threaten the order and safety of society." And we have identified initiatives targeting "compliance including anti-corruption" as one of our materiality (key sustainability issues).
The IINO Group Sustainability Policy and Compliance Regulations form the basis of our compliance structure, and we work to draft and implement compliance-related policies through the Compliance Committee established in accordance with the Compliance Committee Regulations.
IINO Group Anti-Corruption Policy
The IINO Group, as a global company, recognizes that it is its social responsibility as a corporation to carry out fair corporate activities by ensuring that all officers and employees of the Company and its subsidiaries comply with laws, regulations, and internal rules and by encouraging ethical conduct. "The IINO Group Anti-Corruption Policy (the Policy)" has been established based on the Corporate Philosophy. This policy also expresses our basic stance on anti-corruption as advocated in the "Ten Principles of the United Nations Global Compact," and in order to be a company that continues to meet the expectations of our stakeholders, the Group hereby announces this policy and will further enforce it to realize our ideal state. Business Administration Department will review periodically for revisions of this policy, and all modifications will be disclosed to all officers and employees of the Company and its subsidiaries.
IINO Group Competition Law Compliance Policy
The IINO Group, as a global company, recognizes that it is our social responsibility as a corporation to conduct fair and honest corporate activities by ensuring that all officers and employees of IINO Kaiun Kaisha, Ltd. (IINO) and its subsidiaries comply with the competition laws of all countries and regions where we are conducting business, and has thereby established this "IINO Group Competition Law Compliance Policy" (hereinafter referred to as "this Policy") based on our Corporate Philosophy. This Policy also expresses the basic stance on competition laws of the IINO Group which aims to realize the robust development and expansion of business based on fair and honest competition, and the IINO Group will continue to exert efforts to fully enforce this Policy.
Structure
Compliance Structure
The IINO Group has established the Compliance Committee, which is chaired by the President Executive Officer and whose members include all executive directors, the representative directors of major Group companies, and some executive officers, as a body responsible for developing and strengthening the compliance structure. The Compliance Committee meets quarterly and as necessary, and under the Chief Compliance Officer appointed by the President Executive Officer in their capacity as committee chair, the committee conducts regular deliberations on compliance, including anti-corruption, and reports to the Board of Directors.
The Chief Compliance Officer also works with auditors and the Corporate Audit Office to fulfill reporting obligations regarding legal and regulatory violations, etc., in accordance with the Compliance Regulations and External Reporting System Operational Regulations.
Initiatives
Initiatives to Assess and Avoid Corruption Risk
The IINO Group specifies its commitment to prevent bribery, facilitation payments, illegal political contributions, money laundering, conflict of interest transactions, and prohibition of cheating in the Group Anti-corruption Policy and make the best effort to prevent corruption risks in its worldwide business operations along with selection of business partners. In addition, the Group investigates and collects information about unlawful practices that might occur, given its business activities. More specifically, we seek understanding from all business partners, including suppliers, to support this policy and carry out corruption checks using credit research agencies and other means. Contracts concluded by the Group also include regulations for the elimination of antisocial forces, clearly stating that the Group will cancel the contract if the other party is found to have ties with antisocial forces. When, as a result of such risk assessment, the risk of corruption is judged especially high, the Compliance Committee conducts an investigation based on the information received and judges whether to proceed with the business or new business partner, in cooperation with a lawyer or other outside expert where necessary.
Raising Awareness of Anti-Corruption
The IINO Group Anti-Corruption Policy represents the IINO Group's responsibility to prevent corrupt practices. The IINO Group Sustainability Policy clearly states that the Group will comply with all laws and regulations, and will promote fair trade by establishing system with competition laws and anti-bribery measures, and prohibit any and all involvement with bribery, insider trading, and antisocial forces.
To disseminate information about prohibited conduct specified in the Compliance Regulations and thoroughly ensure compliance with domestic and overseas anti-corruption laws based on section 6 (Education and Training) of the IINO Group Anti-Corruption Policy, we prescribe that all officers and employees undergo training. Reflecting our support for the United Nations Global Compact, this training for all officers and employees, including contractors such as temporary employees, includes insider trading, as well as compliance training designed to comprehensively prevent corruption public officer ethics violations, conduct involving cozy relationships with business partners, bribery, and other corrupt behavior. We have also posted compliance training videos that are available for viewing at any time on the Group's intranet. We alert each department and Group company, including local overseas subsidiaries and overseas representative offices, to strengthen the prevention of unfair competition through the thorough enforcement of information management and anti-bribery efforts.
Moreover, in addition to conducting a briefing on the IINO Group's corporate philosophy, management policies and code of conduct to coincide with the formulation of the new corporate philosophy system, we have also introduced the philosophy system in the Group's internal newsletter in an effort to instill it within the organization.
Business Entertainment and Gifts
We prohibit the provision or receipt of business entertainment, monetary gifts, and other goods that are inappropriate according to laws, regulations, or social norms and have prepared specific handling guidelines that are disseminated among Group officers and employees.
Excerpt from the handling guidelines
- Arrange gifts in advance to ensure they fall within the bounds of social custom
- When providing business entertainment, do so in a dignified manner to take care to avoid extravagance
- Do not give or receive money
Corruption-related Penalty Charges, Surcharges, or Settlement Money
In FY2023, there were no major violations of laws and regulations due to the non-observance of anti-bribery regulations, and the Group incurred no penalty charges, surcharges, or settlement money related to corruption.
Data List (Corruption-related Penalty Charges, Surcharges, or Settlement Money)
External Whistleblower System
To enhance compliance management in line with the Group's policies (such as IINO Group Anti-Corruption Policy and IINO Group Competition Law Compliance Policy), we've established a reporting desk. This desk is available not only to Group officers and employees of the Group (including board members, permanent employees, contract workers, contract employees, temporary employees, seconded employees and part-timers, and retirees) but also to business partner of the Group. They can seek guidance and report any violations of laws, regulations, human rights, or instances of harassment. Reports can be made in Japanese, English, and other languages, with strict confidentiality maintained for the reporter or consultee. While anonymous reporting or consultation is possible, it may limit our ability to verify facts or take corrective measures and may affect the reporting of outcomes.
The "External Reporting System Operational Regulations" stipulate that an external lawyer appointed by the Company will serve as the reporting contact. The reported content will be conveyed by the external lawyer to the Chief Compliance Officer. Additionally, the Company explicitly states that it must not treat whistleblowers or cooperating individuals unfavorably due to their reporting or cooperation with investigations.
Prevention of Harassment
We have established regulations concerning the prevention of sexual harassment and power harassment in order to prevent harassment in the workplace and maintain a favorable working environment. Employees and other workers who have experienced harassment or have become aware of such behavior may consult with the counseling office established by the company. Upon receiving reports from the counseling office, the company may establish an investigation committee as a body to investigate and deliberate on the confirmation of facts, the necessity and methods of redress for victims, and measures to prevent recurrence, when deemed necessary.
Internal workshops for the Group's officers and employees are held every year led by an IINO attorney for the purpose of raising their awareness of the importance of preventing harassment. These workshops have changed the way employees think and educated employees about harassment.
Basic Views on Elimination of Antisocial Forces and Status of Maintenance
The IINO Group Sustainability Policy includes the statement: "we will not be involved with any antisocial forces or groups that threaten the order and safety of society," having instituted the Anti-Social Forces Regulations that cover the entire Group. The Group is committed to the total rejection of any kind of links with groups or individuals that threaten the social order or public safety. Any invitations to engage with anti-social forces or related monetary inducements shall be rejected resolutely through organizational responses and close cooperation with external bodies with relevant professional expertise.