MOL compliance structure

• Compliance Committee
  The Compliance Committee exists as a subordinate committee of the Executive Committee and aims to reinforce and thoroughly apply the company-wide compliance system, and determines disciplinary measures for violations. The Compliance Committee has a chairperson and one or two deputy chairpersons, who are Directors or Executive Officers stipulated by the Executive Committee, which will also appoint other Directors and Executive Officers to serve as Compliance Committee members. The Compliance Committee Officer is the General Manager of the Corporate Planning Division.
  
  
• Compliance Officer
  Each division or office General Manager serves as a Compliance Officer. The role of the Compliance Officer is to ensure that all employees of the division, office and affiliates he or she is responsible for adhere to all applicable laws, internal business regulations and relevant standard working procedures. When a breach of compliance is discovered, or when the Compliance Officer receives a report from an employee in his or her division, he or she is responsible for making the initial report to the Compliance Committee Secretariat, and then taking quick corrective action, maintaining the confidentiality of the person reporting the alleged breach.
  
  
• Compliance Advisory Service Desk
  MOL established the Internal Compliance Advisory Service Desk and the External Compliance Advisory Service Desk to handle situations in which a company and its group companies' individual has difficulty reporting the breach or suspected breach to the Compliance Officer.
  These Compliance Advisory Service Desks are open not only to company personnel but also MOL Group company personnel, temporary employees stationed at the company in and outside Japan.
  
  The General Manager of the Internal Audit Office is responsible for the Internal Compliance Advisory Service Desk and the lawyer appointed by the company is responsible for the External Compliance Advisory Service Desk.
  
  Reports or consultations with these Compliance Advisory Service Desks shall be conducted by e-mail, letter or telephone after the name of the person reporting or consulting about a breach or suspected breach (the whistleblower) is clearly stated. However, the External Compliance Advisory Service Desk may protect the whistleblower’s identity, if the whistleblower so wishes, and report or consult on the whistleblower’s behalf with the Compliance Committee, the Compliance Committee Officer or another related internal office.
  
  Both of the compliance advisory desk shall strictly protect the confidentiality of the whistleblower, so as to ensure there is no retribution and will ensure they are not subject to retribution and shall not be treated unfavorably.
  
  
• Breaches of compliance in MOL Group companies
  MOL Group companies establish their own compliance structures to match the type and scale of their business operations. In case a breach of compliance occurs in a Group company, the relevant company follows its own internal rules and regulations to take immediate steps to prevent the breach of compliance from recurring. At the same time, MOL's Compliance Officer in charge of the relevant MOL Group company reports the breach to the Compliance Committee Secretariat without delay. It must also be reported to the Compliance Committee if it may affect MOL Group management. In addition, employees of MOL Group companies who discover a breach of compliance in an MOL Group company can also consult with MOL's Compliance Advisory Service Desk.

Rules of Conduct

All company personnel must act within the following Rules of Conduct when carrying out their duties.

1. Observe laws and regulations while at all times exercising due caution as a good administrator.
   • Observe the laws and regulations and the like of Japan and all other nations, and act in accordance with social standards and corporate ethics while at all times exercising due caution as a good administrator.
     
     
2. Respect human rights and refuse to permit discrimination and harassment.
   • Respect every individual’s basic human rights; and do not discriminate based on ethnicity, faith, religion, nationality, age, sex, class, disability, and the like.
   • Understand, appreciate, and value the diversity of cultures, customs, and so on, in every area and nation, and work to achieve harmony between them.
   • Do not subject anyone to sexual harassment or make offensive sexual remarks and do not act or speak in a way that might be misunderstood as sexual harassment.
   • Do not cause mental or physical suffering to anyone or act in a way that negatively affects the working environment by ignoring a person’s human rights or speaking or acting in a way that does not respect an individual’s human rights by using your position or authority in the workplace or exceeding the appropriate scope of your delegated authority.
     
     
3. Protect confidential information and respect intellectual property rights.
   • Do not reveal confidential company information to a third party without permission and do not use such information improperly.
   • Handle confidential information from third parties such as clients and contractors in the same way as you would handle the company’s confidential information.
   • Do not buy or sell shares of the company or outside companies based on knowledge of important internal information of the company or other companies obtained in the course of carrying out duties until that information is officially announced, observing internal business regulations regarding the prevention of insider trading (Insider trading is prohibited).
   • Do not use or obtain confidential information from third parties unjustly.
   • Do not violate the intellectual property rights of third parties, for example, by copying or using computer software without authorization.
     
     
4. Clearly separate official and personal conduct, avoid conflicts of interest.
   • Do not act against the company’s interests.
   • Do not use company property or funds for any activities against the company’s interests.
     
     
5. Stand firm against antisocial forces.
   • Take a stern and uncompromising attitude against antisocial forces and groups that may threaten public order and safety, and never take part in antisocial acts.
     
     
6. Act with awareness of social responsibilities.
   • Endeavor to make a positive contribution towards realization of a better society as a good corporate citizen in international society and communities.
   • Recognize the importance of transparency in management and properly disclose corporate information to promote understanding and trust among various stakeholders, remaining aware that the company is a member of society.
     
     
7. Actively work to ensure safe operations and protect the environment.
   • Voluntarily and rigorously work to protect the marine and global environment, by fully enforcing safe operations of vessels, respecting environmental laws and regulations, and observing the MOL Group Environmental Policy Statement.
     
     
8. Build good relationships based on trust with clients and contractors.
   • Strive to build strong, trusting business relationships and partnerships with honesty, fairness and transparency.
   • Respect various laws and regulations in Japan, including antitrust laws and the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors, as well as similar laws and regulations outside Japan, and observe the company’s Rules of Conduct Related to Antitrust Laws in order to maintain and promote free and fair competition.
   • Do not give or accept money, expensive gifts, business entertainment, or economic benefits of an inappropriate value when dealing with representatives of contractors or other parties.
   • Do not give, offer or promise bribes or illegal benefits in any relationship with public servants in Japan or overseas.
     
     
9. Provide guidance and supervision of these Rules of Conduct by individuals in management positions.
   • Directors, executive officers and employees in management positions shall provide guidance and supervision to company personnel so that the Rules of Conduct are followed faithfully, and request observance of the Rules of Conduct to outsourcing companies which dispatch their employees to MOL Group Companies.
     
     
10. Report and consult on discovering suspected breaches.
    • A company individual should report or consult with the Compliance Officer, Compliance Committee Officer, Internal Compliance Advisory Service Desk stipulated in Article 12, or External Compliance Advisory Service Desk stipulated in Article 13 without delay, if he or she learns of a breach or suspected breach of compliance; and not tacitly approve or cover up breaches by company personnel.
    • Company personnel shall cooperate with investigations related to any alleged breach.
    • The company strictly maintains the confidentiality of company personnel who report or consult about a breach and cooperate in related investigations and will ensure they are not subject to retribution and shall not be treated unfavorably.