On March 18, 2014, the Japan Fair Trade Commission (JFTC) found that the MOL Group had violated Article 3 of the Japanese Antimonopoly Act in certain car carrier shipping trades. The MOL Group has taken measures to reinforce its compliance efforts, including reform of its corporate culture to ensure that the importance of compliance - as the major premise of all corporate activities - is etched deeply into the minds of all executives and employees.
The Compliance Committee, chaired by the Chief Operating Officer, who will serve as the Representative Director/Executive Vice President, and vice-chaired by the Chief Compliance & Legal Officer, meets every three months to monitor our compliance.
The Board of Directors receives regular reports from the Compliance Committee and is responsible for overseeing compliance efforts.
The Compliance Committee exists as a subordinate committee of the Executive Committee to study and deliberate compliance-related matters and to develop and enhance the company-wide compliance system.
The Chief Compliance & Legal Officer manages compliance officers and takes responsibility for enhancing the compliance system, and is appointed by the Board of Directors.
The general manager, unit manager, branch manager, sales manager, or corporate function manager, and for "group companies belonging to the head office organization," the general manager of the sales division in charge or the director in charge is appointed as the person in charge of compliance (compliance officer). The compliance officers shall ensure that their respective division, office, or group company complies in charge with all laws, regulations, and rules relating to its operations, and that it acts with the due care of a good manager in accordance with social norms and corporate ethics. When a violation or an act suspected to be a violation has been discovered and a compliance officer receives such report or consultation, he/she reports it to the Compliance Committee administrative office, and necessary corrective steps are taken without delay. The confidentiality of the reporter or consulter is strictly maintained.
The MOL Group has established both internal and external compliance advisory service desks that MOL and MOL Group full-time personnel, temporary employees, and external stakeholders can consult and report on general compliance issues (including Antitrust Act-related, corrupt practices in general, human rights issues such as harassment, and so on). Compliance advisory service desks are available 24 hours a day, 7 days a week, and accept reports and consultations in Japanese or English by means of email, letter, or telephone. Anonymous reporting is allowed at any of these points of contact, and the confidentiality of the person reporting or consulting is strictly observed. The group also guarantees that those who report or consult on violations and those who cooperate in investigations will not be treated disadvantageously or face retaliation.
In the case of a consultation or report, we will conduct an appropriate investigation after consulting with the parties concerned, and if a violation is found, the cause and its details, including measures to prevent recurrence, will be discussed at the Compliance Committee, and we will instruct the responsible person to make improvements as required.
Unless there are special circumstances, we will promptly interview the person who reported or consulted to confirm the details of the report. As a result, further investigations are carried out if deemed necessary. In addition, the external lawyer representing the person who reports to or consults with the external consultation service will act as an intermediary between the company and the person in charge of the investigation.
Employees and executives of MOL and its group companies are made aware of these internal reporting systems (compliance advisory service desks) through regular training programs and the company intranet. In addition, our intranet discloses cases of compliance violations and the number of cases to ensure the reliability of the "whistle-blowing system" and "prevent the occurrence of compliance incidents."
Inquiries from external stakeholders, including domestic and overseas business partners, are accepted from here.
In an effort to further raise awareness of compliance, and to complement compliance advisory service desks, the Compliance Enhancement Month is held for executives and employees of our company and Group companies. In order to identify potential problems and signs of problems as early as possible, and to take preventive measures, it is conducted every year from 2017, and it receives a wide range of information that shows signs of non-compliance for about 1 month. To date, our company and its group companies have received 60 consultations and reports, and in some cases were able to cope with problems before they developed into major problems.
Anonymous reporting is also possible, and the confidentiality of consultation and reporting persons is strictly observed, and disadvantageous treatment is guaranteed.
Each MOL Group company has established processes and disciplinary standards for reporting the occurrence of compliance violations, giving remedial instructions and taking corrective actions for violations, and taking disciplinary action in accordance with its own internal compliance rules and regulations. In addition, the Compliance Committee disseminates information on the company intranet within the Group to prevent the occurrence of new violations and their recurrence.
While investigating the cause of the Antitrust Act violations, it became apparent that we needed to revamp the MOL Group's corporate culture.
To analyze the group's current corporate culture, we conduct a questionnaire survey "Corporate Culture Assessment" of the employees. As a result of the survey, we developed a program under which the division GMs will foster a corporate culture aimed at eliminating compliance violations. The program includes planning and executing improvement measures such as building awareness of compliance within the divisions under their management and monitoring achievements.
For details, please visit "Engagement Survey".
The MOL Group has established a policy on the prevention of corrupt practices in general, including bribery, conflict of interest, facilitation payments, and money laundering, to further promote management in accordance with our values and code of conduct regarding compliance. All executives and employees of our group will strive to eliminate bribery and corruption through this policy, striving to improve business operation.
We also expect all business partners to support this policy. In addition, we ask our business partners for their cooperation in the "MOL Group Supplier Procurement Guidelines", which covers the prevention of corruption. For details, please visit "Responsible Procurement".
The policy was established in 2022 and approved at our Executive Committee. The Board of Directors is also responsible for overseeing this policy.
In addition, we established an internal rule called the "Anti-Corruption Policy" in October 2015 to eliminate bribery and excessive business entertaining of public servants as well as those outside the government. This policy ensures that we "build good relationships based on trust with customers and business partners," as stated in the Compliance Policy.
This policy and rule are communicated to executives and employees through workshops and e-learning to encourage compliance.
Political contributions are made in compliance with the Political Funds Control Act and in accordance with appropriate internal procedures.
For actual results of political contributions, please refer to "Sustainability Data".
The MOL Group conducts a risk assessment of its group companies every year, and among them, we also check for the existence of risks related to overall compliance, such as "bribery," "Antitrust Act violations," "various business laws," "violations of internal rules," "embezzlement," and "various types of harassment." Based on the survey results, we conduct internal audits with priority on companies and divisions that are deemed to have high risk. The audit results are passed through the Executive Committee, which instructs the auditee to take corrective action to remedy the problem. In addition, improvements are monitored and reported quarterly to the Executive Committee.
The MOL Group conducts education to foster and establish compliance awareness in executives and employees. Training programs on antitrust act and anti-corruption are held annually on an ongoing basis, as well as compliance-related e-learning. For actual E-learning participation rates, please refer to "Sustainability Data".
In addition, the MOL Group includes compliance-related items in personnel evaluations and compensation decisions for executives and employees. The MOL Group sets goals for strengthening and fostering the compliance awareness of each individual and for training and guiding subordinates to achieve these goals and conducts annual performance evaluations on the status of achievement of these goals. Through these personnel evaluations, we strive to raise the compliance awareness of each executive and employee.
As a company that operates globally, the MOL Group believes that tax transparency and payment of taxes are fundamental and important social responsibilities that a company should fulfill. We comply with the spirit of the applicable tax laws and regulations of all countries in which we do business and pay our fair share of taxes.
In addition, we understand that using tax havens without business purposes or actual conditions to enjoy excessive tax benefits will impede the proper payment of taxes in each country and hinder the development of those countries and regions, and we will not use tax havens for the purpose of tax avoidance.