Compliance

Group Promotion Structure

The ITOCHU Group has compliance officers in each organization within Headquarters and at all Group companies worldwide. These compliance officers are strengthening compliance by creating systems, conducting education and training, responding to individual cases, and any other necessary measures based on directives and support from their respective Division Companies, as well as consideration of local laws, business characteristics, and operational formats.
In addition, we conduct simultaneous companywide Monitor & Review surveys every six months. While checking the progress in implementing compliance measures at all ITOCHU Group companies through these surveys and other opportunities, the ITOCHU Group is making a concerted effort to find improvements that will enhance its well-developed systems for advancing compliance.

Compliance Structure

Major Compliance Measures in Fiscal 2011 and Tasks for the Future

During fiscal 2011, we compiled and distributed to all employees a Compliance Handbook summarizing rules that each employee is expected to strictly observe. In conjunction, we conducted a test to confirm understanding of handbook contents via an e-learning module.
Additionally, overseas and Group companies received visits and subsequent guidance designed to assess actual frontline conditions and identify risk, as we pursue activities that emphasize compliance system operations. Furthermore, we formulated and moved to steadily implement distinctive measures to enhance compliance at each Division Company,based on existing incident trends, Monitor & Review results, and other data. Along with further promotion of these measures, we will continue striving to strengthen compliance with an emphasis on overseas and Group companies.

Bolstering Measures to Fight Corruption

Over the years, ITOCHU has sought to fight corruption by drafting regulations that specifically ban bribes and payoffs, along with related guidelines, with the aim of supporting the broad prohibition of payoffs to public officials and others in comparable positions worldwide.
Anticipating more stringent regulations against bribery and corruption worldwide,including enforcement of a major anti-corruption law in the UK on July 1, 2011,ITOCHU in June revised its own aforementioned regulations and guidelines as a measure to enhance its own responsiveness in this area.
Going forward, we will work to circulate information regarding the aforementioned revisions within ITOCHU and to overseas blocs. At the same time, steps will be taken to conduct risk assessment and monitoring with respect to payoffs, bribery and similar impropriety.

Global Security Risk Management

To prevent the proliferation of weapons of mass destruction and conventional weapons, Japan maintains strict trade-security under the Foreign Exchange and Foreign Trade Act. To observe such laws and regulations, we have implemented our own internal trade-security control program. Further, to ensure that we do not take part in business transactions that threaten international peace and security, not only do we meticulously comply with existing government laws and regulations, but we are voluntarily taking extra measures to ensure that our stakeholders and corporate reputation are adequately safeguarded through our implementation of a comprehensive global security risk management program.
The potential intersection of corporate operations with global terrorism or the development and proliferation of weapons of mass destruction can give rise to reputational and financial risks for ITOCHU and other companies with extensive international business operations.
Accordingly ITOCHU recognizes that, as a responsible member of society and the global business community, we need to manage carefully the potential risks associated with business operations in certain locations. In response to the growing field of corporate governance termed global security risk, ITOCHU has developed and implemented corporate policies, procedures, and internal reporting structures to ensure that we perform rigorous, security-minded due diligence with respect to projects and transactions in which security issues are implicated.