Basic Approach to Compliance
Companies must not concern themselves with the pursuit of profit alone; rather, they are expected to develop their businesses while conducting themselves in accordance with social norms and contributing to society. Sojitz believes that thorough compliance is essential to meeting these expectations. We focus on instilling and establishing a compliance mindset among employees while making a Company-wide effort to enable cooperation and teamwork through daily communication among employees. However, there are no shortcuts to establishing corporate compliance.
Initiatives for Thorough Compliance
Publicizing and Establishing the Compliance Mindset
The Sojitz Group’s Corporate Statement is honored through the Sojitz Group Code of Conduct and Ethics—a set of decision-making standards established to act as the foundation for all of Sojitz Group’s business activities around the world. The Sojitz Group includes many operating bases outside Japan, and therefore actively works to enhance understanding and practice of compliance not only in Japan, but at the global level. The Code of Conduct and Ethics has been translated into 23 languages, including Japanese and English to enable all Group employees in Japan and overseas to acquire a shared compliance mindset.
The Sojitz Group conducts a variety of compliance training
programs, such as e-learning to help Group employees deepen their understanding
of the Sojitz Group Code of Conduct and Sojitz Group Compliance Program,
as well as training seminars which focus on specific case studies.
The Sojitz Group Compliance Program will be reviewed on an annual basis, while the Sojitz Group Code of Conduct and Ethics will be revised at least once every five years. The latest revision of the Sojitz Group Code of Conduct and Ethics occured in April 2016.
＜Sojitz Group Code of Conduct and Ethics＞
Constructing a Compliance Framework
The Compliance Committee, chaired by the Chief Compliance Officer (CCO), is at the core of activities to ensure adherence to laws, regulations and corporate ethics, in cooperation with the head office, consolidated Group companies, overseas sites and other parts of the Group. Compliance supervisors and assistants have been assigned to Sojitz’s domestic and overseas operating bases and consolidated Group companies in order to install a framework for compliance response at each office and promote educational activities and training programs, including those for locally-hired employees.
Sojitz has also set up compliance committees in each of the four regions, which run committee meetings and carry out local compliance activities overseas. In addition to these initiatives, Sojitz promotes a shared awareness of compliance and regularly exchanges views on future policies through various channels, such as meetings between the CCO and the presidents of each division and consolidated Group companies and conferences among the compliance officers of domestic consolidated Group companies.
To help prevent and detect compliance violations early on, all Sojitz Group employees are made well aware of the Company hotline (reporting system) that provides access to the CCO and outside legal counsel; a consultation desk where Compliance Committee Secretariat members can be contacted; and the multi-lingual Sojitz Ethics Hotline, which is available 24 hours a day, 365 days a year.
Furthermore, we have a department specifically for conducting
investigations into compliance violations and taking steps to ensure
they do not happen again. We are strict in our response to compliance
infractions, including punishment based on the nature of the violation.
Cases of legal violations across the Sojitz Group worldwide in FY2016
Incidents involving the law in Japan
・Cease and desist order from the Japan Fair Trade Commission and other related government organizations ０
・Suspension of business or operations due to a scandal ０
・Criminal charges resulting from a compliance-related incident or accident ０
Legal violations outside of Japan
・Participation in a price cartel ０
・Other legal violations ０
The number of cases involving violations of the Sojitz Group Code of Conduct and Ethics in Japan and overseas for FY2017 are listed below.
・Number of cases involving violations: 49
However, there were no cases that had a major impact on business at the Sojitz Group.
The Sojitz Group Compliance Hotlines
Sojitz has set up the compliance hotline below for parties both inside and outside the organization to report any known or suspected violations of law or the Sojitz Group Code of Conduct and Ethics by Group companies or individual Group employees.
In FY2017, 47 cases were called in through Sojitz’s compliance hotlines.
Enhancement of Anticorruption Measures
In recent years, the United States and other countries have tightened regulations against corrupt practices such as bribing or improperly giving gifts to foreign public officials, and the level of standards demanded for prevention of corruption is increasing globally.
Sojitz formulated anticorruption rules in December 2012
and set out methods for preventing corruption in April 2013. Since
then, the Company has implemented full-scale initiatives starting
with the head office, where it began conducting e-learning focusing
solely on the prevention of corruption, employee training regarding
enforcement of its anticorruption rules, and other initiatives in
May 2013. At the same time, the Company began screening gifts, entertainment
and engagement of agents and other third parties, etc. that pose a
high risk of corruption. Sojitz plans to expand these initiatives
to all Group companies in Japan and overseas to quickly ensure a high
level of anticorruption measures throughout the Group.
Sojitz Corporation is member of TRACE International, the world's leading anti-bribery standard setting organization. We initially completed a TRACEcertification due diligence review in November 2015 and received the TRACE Certificate, underscoring Sojitz Corporation’s commitment to transparency and integrity in international commercial transactions. The membership and TraceCertification is updated annually.
Sojitz Corporation is member of TRACE International, the world's leading anti-bribery standard setting organization. We initially received TRACEcertification (TRACEcertification ID: TC3151-4085) in November 2015. The membership and TraceCertification is updated annually.
Information pertaining to legal violations in Japan and overseas for FY2017 is listed below.
・Number of cases of discovered bribery: 0
・Amount of fines imposed for violation of anti-corruption laws: ￥0
Reporting to the Board of Directors
A report is made each year to the board of directors on compliance measures (including anti-bribery initiatives), any instances of compliance violations, and compliance policy for the applicable fiscal year.