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Compliance

Approach to Compliance

MOL believes compliance means more than just strictly complying with legislation and internal rules (including voluntary Rules of Conduct). It also covers observing the Rules of Conduct in corporate activities and daily operations, including respecting human rights and refusing to permit discrimination and harassment, in accordance with social norms and corporate ethics. In order to instill a compliance mindset and strengthen the systems supporting this, MOL is conducting various activities worldwide. These include an e-learning program as well as legal affairs seminars for the MOL Head Office and Group companies, including those overseas. MOL will continue to strengthen its compliance systems with a view to Global Group management.

(*)MOL's Rules of Conduct, created with our diverse stakeholders in mind, are a set of behavioral guidelines for executives and employees. Click here for more details.

Organizations Responsible for Compliance

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.

Basic Policies for Compliance (Compliance Rules Article 3)

  • Strive to follow the MOL Corporate Principles and make them a reality.
  • Always recognize the public mission and social responsibilities of MOL's business, and maintain the trust of the company's stakeholders.
  • Strictly comply with laws, regulations, and so on, and conduct fair and transparent corporate activities in the context of social norms and corporate ethics.
  • Never yield to antisocial influence, and never be a party to antisocial acts.

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