Compliance

Management information

Relevance to our business

As a member of the global community, the Fuji Oil Group believes in the importance of conducting fair and transparent business activities. To that end, we are engaged in various measures related to compliance throughout the Group.

Basic approach

The Fuji Oil Group believes it is important that we act with high ethical standards not only to comply with laws and regulations as well as internal policies and rules in daily business operations but also to meet the expectations and needs of society (stakeholders). This notion of compliance is embedded in the Fuji Oil Group Management Philosophy,* which we formulated in October 2015.
Furthermore, we defined the Fuji Oil Group Three Principles of the Code of Conduct to clarify specific behavior that all Group members are expected to display in order to ensure compliance.

Fuji Oil Group Three Principles of the Code of Conduct

  • Follow the rules.
    ・Observe the laws and regulations applicable in the respective countries and regions.
    ・Act according to the rules and procedures established by the company.
    ・Follow social norms and live up to society’s expectations and trust.
  • Act honestly.
    ・Act on one’s own conscience.
    ・Do not hide one’s mistakes or failures.
    ・Give reports and explanations which are properly based on the facts, and in a timely manner.
  • Act fairly.
    ・Engage in fair and proper transactions.
    ・Draw a line between public and private matters and do not commit any illegal conduct.
    ・Respect the human rights of the people involved in business activities and consider racial, gender, and religious sensitivities.
    ・Do not do anything that may lead to constraint, bribery, or any other form of corruption.
    ・Do not allow any antisocial forces to intervene and disrupt the workplace.

Management system

Under the supervision of the Chief Administrative Officer (CAO), the Legal Affairs Department of Fuji Oil Holdings Inc. plans various measures to increase compliance awareness and works to improve compliance issues throughout the Group. Moreover, the Fuji Oil Group has set compliance as a material ESG issue*1 from FY2021. We assess the compliance risks in our business operations and formulate measures against bribery, corruption, and other risks, while the ESG Committee,*2 which is an advisory body to the Board of Directors, confirms the progress and results of initiatives. The ESG Committee reports insights to the Board of Directors for review.

Next step

We recognize that to strengthen our compliance, we need to develop a compliance risk management system (including prevention of bribery and other corruption) for the entire Group. To address this issue, we set the following goals for FY2021.

  • Strengthen collaboration with the Legal Affairs Department of Fuji Oil Holdings Inc. by appointing staff responsible for legal affairs at the regional headquarters or their subsidiary Group companies
  • Have regional headquarters or their subsidiary Group companies conduct a self-assessment on compliance management, and have the Legal Affairs Department of Fuji Oil Holdings Inc. review the results
  • Conduct compliance training

Specific initiatives

Training

Business Ethics Guidelines

We established the Fuji Oil Group Business Ethics Guidelines. Based on the Fuji Oil Group Management Philosophy, these guidelines explain the importance of ethics and compliance using representative case studies encountered in daily duties. The guidelines comply with laws and regulations of the countries and regions in which we operate, and are available in nine languages spoken there. The guidelines are distributed to employees in booklet and PDF forms.

Compliance training

We have been conducting Groupwide e-learning training globally on key compliance issues, including anti-bribery, anti-corruption, and antitrust laws, as well as laws and regulations related to fair business transactions, with the aim of enhancing compliance sensitivity of all Fuji Oil Group employees. In FY2021, we plan to conduct the training in nine languages. In addition, the Legal Affairs Department collaborates with the Human Resources Department and other related departments to provide the necessary compliance education for the departments that need them through face to face trainings or e-learning.

Monitoring

We have been monitoring Group companies both in and outside Japan, in cooperation with Audit & Supervisory Board members and departments responsible for internal audits. Moreover, the Legal Affairs Department of Fuji Oil Holdings Inc. endeavors to identify compliance risks and verify the status of the compliance activities by reviewing the results of self-assessments and conducting interviews with each Group company.

Whistleblowing system

The Fuji Oil Group Whistleblower Hotline and a whistleblowing hotline outsourced to an outside law firm are in place at Group companies in Japan. As part of efforts to promote fair transactions, third-party partners in some limited areas are provided with access to the Fair Trade Helpline, which operates as a whistleblowing contact point.
The Fuji Oil Group’s Compliance Helpline is available for employees at Group companies outside Japan.
We created an environment that facilitates reporting both in and outside Japan by appointing an outside organization that ensures the confidentiality and anonymity of informants and accepts reports 24 hours a day, 365 days a year.
Fuji Oil Holdings Inc.’s whistleblowing regulations prohibit the dismissal and unfair treatment of an employee due to the whistleblowing. They also stipulate that those who have unfairly treated or harassed a whistleblower may be punished in accordance with the work regulations and other rules.
Over the last few years, the number of reports received annually throughout the entire Group has remained in the range of five to ten. Upon receipt of a whistleblowing report, we promptly investigate the details of the report, make necessary corrective measures, and provide feedback to the whistleblower. We also conduct a Groupwide yearly survey on the whistleblowing system to ensure that the whistleblowing system is well known and to improve its operation.

Corruption prevention

Preventing bribery and corruption is one of our key compliance issues related to fair transactions. We have established the basic regulations for preventing bribery that prohibit acts of bribery throughout the Group.
Moreover, to ensure that our business partners who conduct business on behalf of the Group strictly comply with the basic regulations for preventing bribery, we also perform proper due diligence prior to making transactions and take the necessary precautions, such as including anti-bribery and anti-corruption clauses in contracts with our business partners.
Furthermore, we plan to conduct bribery risk assessments at each Group company in FY2021.
To instill these anti-bribery policies and measures throughout the Group, we have also focused our efforts on education and raising awareness of bribery. The Fuji Oil Group Business Ethics Guidelines comprehensively cover bribery and corruption prevention along with case examples. We also provide e-learning and face to face trainings for employees.
In addition, employees can use the whistleblowing system described above to anonymously raise concerns and grievances related to bribery and corruption in the company.

Political donations

The Fuji Oil Group does not make political donations.

Compliance with laws and regulations

There were no serious violations of laws or regulations linked to the Fuji Oil Group’s business operations in FY2020.

Related documents