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

Please scroll sideways.

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.

Please scroll sideways.

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 2022, we conducted “Monitor and Review” of the ITOCHU Group's compliance system for FYE 2022, which covered 452 organizations, including ITOCHU Corporation's all divisions in head quarter, all domestic branches, overseas blocks, and ITOCHU Group companies and their subsidiaries. The purpose is to understand and promote the status of the compliance system in each organization.
  • In the period of September-November 2022, we conducted the monitoring survey on compliance with “the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade” and “the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors” in ITOCHU Corporation and 63 ITOCHU Group companies in Japan. In the course of such survey, we performed individual hearings and fact-finding investigations based on answers to questionnaire in certain prescribed format, as a result of which we found no serious concern on that.
  • In the period of Dec/2022-Feb/2023, we identified compliance-related cases occurred in ITOCHU Group companies, for which recurrence prevention measures were formulated in FYE 2022 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.
  • The status of our periodical on-site compliance training seminars in FYE 2023 is as follows:
    For ITOCHU Corporation: 3,263 employees (who all watched the training video);
    For ITOCHU Group companies in Japan: 14,872 employees in total, of which (i) the webinar sessions and/or on-site sessions were provided for 49 companies in 86 occasions with 7,108 attendees; and (ii) the training video were provided to 7,764 viewers of 28 companies (including companies that participated in webinar courses as well).

Structures and Systems

ITOCHU Group’s Compliance System

The ITOCHU Group is developing a system for compliance by having the Compliance Department of the Legal Division plan and suggest policies and measures to encourage compliance throughout the entire Group and appointing compliance officers in each organization within ITOCHU Corporation, overseas offices and major Group companies worldwide (including consolidated subsidiaries and some equity method associated companies; hereafter referred to as the “companies subject to compliance management”).

The Compliance Committee is chaired by the CAO and consists of two external members and heads of relevant administrative divisions and sales divisions as internal members. It deliberates on matters related to compliance as a permanent organization on business operations and is held two times a year in principle. The most recent Compliance Committee meeting was held on March 1st, 2023.

The ITOCHU Group Compliance Program shows policy for developing compliance promotion system so that each organization within ITOCHU Corporation, its overseas offices, and companies subject to compliance management can ensure compliance by taking into account business characteristics, operational formats and local laws. At the same time, the Compliance Committee reviews the effectiveness and validity of the program every fiscal year based on laws/ordinances and social trends. The committee then revises and approves this program as appropriate.

The ITOCHU Chief Officer for Compliance (CAO) and the compliance officers of each organization, overseas offices and companies subject to compliance management report the situation of compliance system operation and the results of the Monitor & Review surveys in accordance with the ITOCHU Group Compliance Program to the respective board of directors and top management (e.g., presidents, compliance officers and management councils) once a year in principle.

The Internal Audit Division of ITOCHU confirms the compliance system operation in the relevant organizations and overseas blocs as appropriate. It does this in compliance audits to verify that the compliance system in the ITOCHU Group is functioning appropriately and regular audits on organizations (including supervising group companies) and overseas blocs in ITOCHU.

Moreover, the directors of ITOCHU and our group companies are obliged to report any serious compliance incidents with laws/ordinances and our Articles of Incorporation to the Audit & Supervisory Board members of the respective companies.

Across the Group, we conduct Monitor & Review surveys once a year to check the status of compliance systems and operations of each organization. In addition, as for key organizations such as overseas offices and companies subject to compliance management, we are implementing activities with a focus on the constant improvement and enhancement of our compliance structure. For example, we have been utilizing the Internet to provide on-site training using compliance incidences that have actually occurred as the teaching materials even during the COVID-19 pandemic. Furthermore, based on trends in former compliance incidents and the findings of the Monitor & Review surveys, we are formulating individual compliance reinforcement measures for each organization, and these measures are steadily being implemented.

In addition, to ensure compliance throughout the Group, at individual performance evaluations every fiscal year, we confirm all employees have complied/will comply with laws, regulations, and other rules in writing.

Response to Compliance Incidents (Violations)

The compliance officers in the relevant organizations make reports to the Chief Officer for Compliance (CAO) according to the prescribed standards and procedures if violations of laws/ordinances and internal rules – including those on the prevention of corruption – are uncovered or if it is determined there is a risk of a violation occurring in the organizations of ITOCHU, overseas offices and companies subject to compliance management. At the same time, the compliance officers in the relevant organizations play a central role in reporting results when dealing with such concerns (e.g., internal investigations, cause investigations and recurrence prevention measures) to CAO.
We set up an investigation committee as necessary under the direction of CAO for serious compliance incidents requiring consideration from a company-wide perspective. That committee reports the results of the investigation and the recurrence prevention measures to the Board of Directors.
Furthermore, ITOCHU then takes the appropriate action as necessary upon considering whether it is necessary to respond, report and make announcements to external organizations.

We verify whether it is necessary to impose internal punishments on officers and employees involved in violations of laws/ordinances, including those concerning bribery, with reference to the internal regulations (e.g. work regulations) of each company. If necessary, we impose appropriate punishments such as pay or remuneration cuts according to the standards and procedures stipulated in the internal regulations upon consulting and cooperating with the relevant departments and experts inside and outside the company.

We take the appropriate action as necessary upon considering whether it is necessary to respond, report and make announcements to external organizations.
There was no serious compliance incident (including any breach of customer privacy) which shall require public disclosure.


The ITOCHU Group Compliance System


Internal Reporting System (Hotlines)

ITOCHU Corporation has formulated Internal Reporting Regulations and instructed the installment of similar rules at companies subject to compliance management as well. In addition to protecting whistleblowers through these arrangements, we have defined mechanisms for proper disposal of cases. This initiative is reinforcing compliance management by supporting the prompt discovery and rectification of any incidents of corruption, including bribery. The Internal Reporting System operation situation is reported to the Compliance Committee periodically.
ITOCHU Corporation has established multiple whistleblowing contacts both in Japan and overseas (including external whistleblowing contacts that utilize specialized company and external lawyers). We accept reports from employees who have an employment relationship with ITOCHU, those who have been dispatched to ITOCHU under a worker dispatch contract from a company that has entered into that contract with ITOCHU (temporary employees), and employees of group companies. It prohibits the unfavorable treatment (e.g., retaliation) of whistleblowers and allows whistleblowers to provide information anonymously. The following table shows the report numbers for the past three years through ITOCHU Corporation's whistleblowing hotlines.

FYE 2021 FYE 2022 FYE 2023
Report Numbers




Flow When Received a Report by the Japanese External Report Reception Desk (Integrex Inc.)


Consultation Desk for the General Public (including Stakeholders)

ITOCHU Corporation has established a system to accept opinions, proposals, and grievances and to accept inquiries from the general public and all our stakeholders, as described below.



Implementation of Compliance Training

ITOCHU provides ongoing education and training on compliance. The aim is for each one of our officers and employees to understand the purpose of laws/ordinances and social norms and to then comply with these based on high ethical values.

On-Site Compliance Training

Compliance Awareness Surveys

Bolstering Measures to Fight Corruption

In FYE 2023, there was no bribery or corruption case and no fine or penalty case.

Measures to Fight Collusive Bidding and Cartels

ITOCHU established the Basic Regulations on the Compliance with the Antimonopoly Act., etc. and the specific operational guidelines titled the Standard on Prevention of Cartels and Collusive Bidding in November 2017. The purpose of this is to prevent involvement in collusion, cartels and other violations of the Antimonopoly Act. In addition, we thoroughly inform our employees about compliance with the Antimonopoly Act. We do this by preparing the Antimonopoly Act Compliance Manual, various monitor reviews, and education and training. We passed instructions at a meeting of the Board of Directors according to four exclusion measure orders we received from the Fair Trade Commission from FYE 2018 to FYE 2019. We have notified and thoroughly informed all our employees of the content of these resolutions.


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

Monitor & Review Surveys on Personal Information Management