Code of Ethical Conduct

All of our executives and employees will act with high ethical standards based on the principles outlined in this Code of Ethical Conduct (Hereinafter, the Code), comply with all relevant domestic and international laws and regulations, and support and respect international norms *. In doing so, we will aim to fulfill our Guideline of Conduct, “I am One with Infinite Missions.” In implementing the Code, the ITOCHU Group will pursue a series of due diligence processes to identify, prevent and mitigate, and account for any negative impacts on the economy, environment and the public. The Board oversees this Code of Ethical Conduct and its implementation.

*"OECD Guidelines for Multinational Enterprises," "OECD Due Diligence Guidance for Responsible Business Conduct," "ILO Declaration on Fundamental Principles and Rights at Work," "UN Global Compact," "Universal Declaration of Human Rights," "UN Guiding Principles on Business and Human Rights," "Keidanren Charter of Corporate Behavior," etc.

1. Innovation for Sustainable Economic Growth

In order to contribute to the sustainable growth of the economy and provide solutions to social issues, we will develop useful and safe next-generation services, products and social infrastructure through the innovation of new technologies and approaches.

2. Respect and Consideration for Human Rights

We will not discriminate in employment or the workplace on such grounds as race, sex, religion, political opinion, national extraction, body, illness, age or other irrational grounds.

We will respect the human rights of stakeholders affected by corporate activities, and contribute to the effective abolition of child labor and the elimination of forced labor.

More specific policies on human rights can be found in the Human Rights Policy.

3. Development of a Rewarding Work Environment

Emphasizing work styles that respect diversity, each individual’s character, and individuality, we will create a comfortable work environment that is free from discrimination and harassment (sexual, power, maternity or any kinds of harassment) and that takes health and safety into consideration. We will raise labor productivity and corporate value through the creation of a challenging but rewarding workplace, strongly emphasizing an on-site approach, embodying the spirit of "Sampo-yoshi," and maximizing the opportunity for employees to demonstrate their abilities.

4. Environmental Conservation

We will comply with environmental treaties and laws, and strive to conserve the environment. In our corporate activities, we will consider energy conservation, resource recycling, prevention of environmental pollution, and conservation of water resources and biodiversity. We will also strive to reduce greenhouse gas emissions and actively promote projects that contribute to the mitigation of climate change.

5. Fair Business Practices

Compliance with Competition Law (Antitrust Law)

We will conduct business practices in compliance with competition laws (antitrust laws) and related laws and regulations in each country and region.

Prohibition of Bribery

In compliance with laws and regulations concerning bribery, no money, goods, services, facilities, or other benefits will be provided to public officials or persons in equivalent positions, or officers and employees of private business partners, regardless of whether they are in Japan or overseas, for the purpose of obtaining illicit profits.

Prohibition of Conflicts of Interest

Employees will not engage in activities that conflict with the interests of the company, such as dealing with the company for personal benefit or using the company's assets and expenses for personal purposes.

Export and Import Procedures

We will comply with export and import-related laws, regulations, and permitting procedures, and with regard to trade transactions legally governed by security trade controls, will not engage in inappropriate transactions, in compliance with the laws and regulations of Japan and other countries, UN Security Council resolutions and other international agreements.

Political Donations

Any political donations and donations to various organizations will be made in accordance with public information disclosure standards, be subject to appropriate internal approval, and the details of such donations will be reported to management.

Prohibition of Insider Trading

Employees will not engage in insider trading in violation of the laws and regulations, such as buying and selling shares of a company or business partner while holding important nonpublic information about the company or business partner.

Tax Responsibility

We will pay taxes appropriately in compliance with the tax system of each country.

6. Management and Provision of Information

Appropriate Handling of Information

Employees will undertake the proper handling, management, protection and maintenance of information in accordance with the Information Security Policy.

Protection of Personal Information

Employees will appropriately manage personal information obtained through business activities and use it only for the purpose of notifying the information provider himself/herself. In addition, unless permitted or enforced by law, this information will not be presented to a third party without the prior consent of the person concerned.

Protection of Intellectual Property

The company will appropriately protect and manage its own intellectual property rights and will not engage in business activities that infringe on intellectual property rights held by others.

Provision of Consumer Profit and Product Information

We will provide information necessary for voluntary and rational product selection by consumers in a timely and appropriate manner.

Timely and Accurate Information Disclosure

We will disclose accurate information on important matters related to corporate activities, business performance and financial conditions, and corporate governance in a timely manner.

7. Contribution to Society

As a good corporate citizen, we will contribute to the development of local economies through our business activities. We will develop mutual trust with stakeholders in local communities and the international community through social contribution activities in our business regions and around the world.

We will collaborate and cooperate with a wide range of stakeholders, including NPOs, NGOs, local communities, governments, and UN agencies, to contribute to the development of an affluent, livable, and sustainable society.

8. Crisis Prevention

We will refuse to make any easy compromises, monetary or otherwise, in response to wrongful demands from anti-social forces, and will have no relationship or business with anti-social forces or related organizations or individuals.

We will have no involvement whatsoever in terrorism, money laundering or other crimes. In addition, we will take sufficient caution to avoid being used indirectly in these crimes in the course of trade.

9. Reporting and Consultation

If employees discover or personally engage in conduct that violates or may violate the Code, they will immediately report to their superior. In addition, if this conduct constitutes or is likely to constitute a compliance case, it will be promptly reported in accordance with the ITOCHU Group Compliance Program.

In cases that fall or are likely to fall under compliance cases, and in cases where corrections are not taken despite immediate reporting to superiors, or in cases where reporting is difficult, whistle-blowing using a real name or anonymously is permitted, and disadvantageous treatment of the whistle-blower or investigation partner on the grounds of such cases is prohibited.

Fumihiko Kobayashi

Member of the Board
Executive Vice President
Chief Administrative Officer

Established in March 2020

Revised in May 2022