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 address 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 March - May 2025, Monitor and Review of the ITOCHU Group’s compliance system for the FY2024 was conducted. This survey covered a total of 447 organizations, including all organizations at the headquarter, all domestic branches, overseas blocks, and ITOCHU Group companies, and their sub-subsidiaries. The purpose of the survey is to understand and promote each organization’s compliance system.
  • In the period of July - September 2025, in order to strengthen the compliance framework and prevent compliance incidents within the ITOCHU Group, we conducted a compliance awareness survey targeting 61,317 officers and employees (including contract and temporary staff) at ITOCHU Corporation and 269 domestic and overseas group companies. A total of 60,839 individuals responded to the survey.
  • In the period of November 2025 - February 2026, the Legal Department conducted monitoring for the compliance-related incidents where the necessity to confirm the implementation status of their recurrence prevention measures, formulated in the FY2024, was high. This monitoring was in addition to the comprehensive monitoring already conducted on the organizations where compliance-related incidents occurred. It is confirmed that these recurrence prevention measures for these cases were generally implemented appropriately.
  • In the period of February - March 2026, e-learning regarding the “Antimonopoly Act”, “Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors”, and periodical on-site compliance training seminars was simultaneously conducted for all ITOCHU Corporation employees, temporary staffs, and secondees.
    Number of the participants: 4,336
  • The status of our periodical on-site compliance training seminars conducted for domestic group companies including their subsidiaries and affiliates in FY2025 is as follows: 89 companies with 26,317 participants.

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)