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Compliance
- Approach/System
- Initiatives
- Compliance Risk Management
- Compliance Education/Personnel Evaluation
- Rules of Conduct
- Tax Transparency
Approach/System
The MOL Group has instituted compliance regulations to determine behavioral norms so that all our employees and executives are committed to making compliance a prerequisite of everyday business activities and to making the appropriate decisions. This thorough approach is supported by continuous compliance training.
Beyond complying with laws, regulations and Articles of Incorporation, our actions are guided by the Company’s values and Code of Conduct (MOL CHARTS), which includes the rule: "Always be cognizant of compliance and act in accordance with social norms and corporate ethics."
We set up the Compliance Committee to manage the development and reinforcement of compliance systems in the MOL Group. Chaired by the Chief Operating Officer (who also serves as the Representative Director and Executive Vice President) and vice-chaired by the Chief Compliance & Legal Officer, the committee meets every three months to monitor Group compliance. The Board of Directors receives regular reports from the Compliance Committee and is responsible for overseeing overall compliance efforts.
Compliance Committee
The Compliance Committee exists as a subordinate under the Executive Committee to study and deliberate compliance-related matters and to develop and enhance the company-wide compliance system.
Chief Compliance & Legal Officer
The Chief Compliance & Legal Officer manages compliance officers and takes responsibility for enhancing the compliance system, and is appointed by the Board of Directors.
Compliance Officer
The general manager, unit manager, branch manager, and 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.
Compliance Advisory and Reporting Service Desk
The MOL Group has established both internal and external compliance advisory service desks that MOL and MOL Group personnel (including full-time, contract and temporary staff) can consult for advice, or report any issues or violations, related to general compliance (such as monopolistic or corrupt practices, harassment and human rights issues). These 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 also possible, the confidentiality of those reporting or consulting is strictly maintained, and it is guaranteed that they will not be treated disadvantageously. 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.
We have established internal and external compliance advisory service desks for customers, business partners, and other external stakeholders as described above, and also an external advisory service desk (operated by the Japan Center for Engagement and Remedy on Business and Human Rights (JaCER)) to receive a wide range of complaints and reports related to human rights, in compliance with the UN Guiding Principles on Business and Human Rights. For more information on advisory service desks and initiatives on human rights, please click here.
List of Advisory and Report Service Desks
| Target | Advisory and Report Service Desks | Details of Consultations/ Reports Received |
|---|---|---|
| For group executives and employees (including temporary and contract employees) | Compliance Officer (internal) |
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| Compliance advisory service desk (internal/external) | ||
| Harassment advisory service desk (internal/external) |
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| For external stakeholders such as customers and business partners | Compliance advisory service desk (internal/external) * Click here to contact us. |
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| Human rights advisory service desk (external) * Click here to contact us. |
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Post-report follow-up process
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. The Corporate Audit Division, which is independent of the corporate employment structure, is responsible for the internal compliance advisory service desk. 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.
Process for Reporting and Corrective Actions for Violations in MOL Group Companies
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.
Compliance Enhancement Month
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 71 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.
Building Awareness among Executives and Employees
MOL proactively builds awareness of the reporting system (compliance advisory service desk) among all MOL executives and employees and its group companies through regular training programs and the company intranet. In addition, the intranet discloses cases of compliance violations and the number of cases to ensure the reliability of the reporting system and prevent the occurrence of compliance incidents.
Initiatives
Initiatives on Compliance with the Antitrust Act
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. Having accepted this fact in good faith, the Group is pushing ahead with initiatives aimed at ensuring full anti-trust compliance all the time.
The group has established the "Antimonopoly Act Compliance Action Guidelines" to prevent violations of the Act by officers and employees and follows procedures such as prior notification, etc. to the Chief Compliance and Legal Officer or Compliance Officer in its contacts with competitors. In addition, we regularly conduct e-learning and training sessions to ensure compliance with the Antimonopoly Act. The group’s annual engagement survey includes compliance-related questions, and the results are visualized and shared throughout the organization, while being used for organizational development, including the prevention of compliance violations. For more details on this survey, please visit "Engagement Survey".
Initiatives on Anti-corruption
Anti-Corruption Policy
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 Group executives and employees are striving to eliminate bribery and corruption in our business operations through this policy, and we expect all our business partners to support the policy. In addition, we ask our business partners for their cooperation in implementing the "MOL Group Supplier Procurement Guidelines," which covers the prevention of corruption. For details, please visit "Responsible Procurement"
Note also that the policy was approved at our Executive Committee in 2022. The Board of Directors is also responsible for overseeing this policy.
MOL Group Anti-Corruption Policy[111KB]
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
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".
Compliance Risk Management
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.
Compliance Education/Personnel Evaluation
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.
Rules of Conduct
Tax Transparency
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.