Compliance

Policy and Basic Concept

  • All officers and employees are to conduct themselves in accordance with the ITOCHU Group Corporate Mission and the ITOCHU Group Guideline of Conduct based on high ethical values.
  • ITOCHU is to designate a representative director as the Chief Officer for Compliance (Member of the Board・CAO) responsible for supervising compliance and also establish the Compliance Committee and a department that oversees all compliance matters. In addition, the "ITOCHU Group Compliance Program" Is to be created to further enhance our compliance system.

Targets and Action Plan

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Risks Opportunities
  • Occurrence of business continuity risk or unexpected loss resulting from the malfunction of corporate governance or internal control.
  • Improvement of transparency in decision-making, appropriate response to changes and establishment of a stable basis of growth enabled by the establishment of a firm governance system.

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Materiality SDGs Targets Impact Classification Issues to address Business area Commitment Specific approach Performance indicators Degree of Progress
Maintain Rigorous Governance Structures
Governance Ensuring compliance Compliance We will make employees more aware that ensuring compliance at any time is our contribution to the company and society. Recognizing attitude of employees identifying issues and ensuring action plans to tackle the issues through periodic compliance attitude survey and direct communications. Continuous direct communication with employees through face-to-face training programs whose contents shall be updated along with monitoring the measures according to risks, expectations from society and issues on site which will change with the time.
  • In the period of April-May 2023, we conducted “Monitor and Review” of the ITOCHU Group’s compliance system of for FYE 2023, which covered a total of 433 organizations, including all organizations at the headquarter, all domestic branches, overseas blocks, and ITOCHU Corporation’s Group companies, and their sub-subsidiaries. The purpose is to understand and promote the status of the compliance system in each organization.
  • In the period of Aug-Sept 2023, we conducted a compliance awareness survey of approximately 56,000 executives and employees (including contract employees and temporary employees) of ITOCHU Corporation and 242 ITOCHU Group companies in Japan and overseas (with approximately 55,000 respondents) in order to improve the compliance system of the ITOCHU Group and prevent the occurrence of compliance incidents.
  • In the period of Dec 2023-Feb 2024, we identified compliance-related cases occurred in ITOCHU Group companies, for which recurrence prevention measures were formulated in FYE 2023 and monitoring was thought to be highly necessary. As a result of the monitoring on the implementation status of the formulated measures, we confirmed that they were properly implemented.
  • In the period of Jan-Feb 2024, we provided e-learning on the “Anti-Monopoly Act” and “Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors” for ITOCHU Corporation employees, seconded employees and employees temporarily assigned to us. (Number of the participants: 4,271)
  • The status of our periodical on-site compliance training seminars in FYE 2024 is as follows:
    • For ITOCHU Corporation: 3,291 employees (who all watched the training video)
    • Group companies: 75 companies, 15,964 persons

Structures and Systems

ITOCHU Group’s Compliance System

Internal Reporting System (Hotlines)

Initiatives

Implementation of Compliance Training

Bolstering Measures to Fight Corruption

Measures to Fight Collusive Bidding and Cartels

Tax

Measures for Intellectural Property

Basic Policy on Product Safety

Measures for Comprehensive Import and Export Control

Basic Policy and Efforts against Antisocial Forces

Insider Trading Regulations

Perspectives on Information Management

Response to Compliance Incidents (Violations)