In the Compliance Manual, the Marubeni Management Policy calls for fair and upright corporate activities in accordance with the spirit of the Company Creed of ”Fairness, Innovation, and Harmony.” Accordingly, the Compliance Manual stipulates specific provisions under such headings as “Compliance with Antimonopoly Act and Related Laws and Regulations” and ”Prohibition of Unfair Competition.” Moreover, we will stand firm against anti-social organizations and threats to social order and public security, and will never form or foster relationships with any organization that poses such threats. To this end, the Compliance Manual provides detailed guidelines regarding the prohibition on conferring benefits on anti-social organizations, the prohibition on money laundering, and other related issues.
“When you are faced with a choice between integrity and proﬁt, choose integrity without hesitation.”
If we do not follow this direction and choose an easy option that results in our corporate brand being damaged, it will take a long time and a lot of energy to restore our brand. We shall not take short-cuts in the pursuit of a quick profit, rather we shall choose the right pathway even if it involves a detour, taking one step at a time.
Each and every one of you should re-assess your position to confirm that your pathway:
If you are ever in any doubt as to any of the above, please revisit this compliance manual.
(Excerpt from the Compliance Manual)
We, the directors and employees of the Marubeni Group, shall observe the laws, regulations and internal corporate rules, by observing the values of “Fairness”, “Innovation” and “Harmony” expressed in our Company Creed, the Marubeni Management Philosophy and the Marubeni Corporate Principles, and shall conduct our business activities in compliance with a high corporate ethical code.
While the term “compliance” is sometimes used to mean “upholding laws”, today the term is also used to mean “upholding corporate ethics”.
For the Marubeni Group, compliance means conducting our business activities while observing laws, regulations and internal company rules in accordance with the philosophy incorporated in the Company Creed, Marubeni Management Philosophy and Marubeni Corporate Principles, and also maintaining a high standard of ethics.
Compliance is a prerequisite for a company to endure. This is because, if profits are not realized through sound business practices based on upholding rules and ethics, the company will betray the expectations and demands of various stakeholders (i.e., interested parties) such as consumers, business partners, shareholders and employees, and sooner or later society will no longer tolerate the existence of that company.
The Term “Compliance” is the guiding principle for the actions of company workers.
Compliance within a corporation can only be achieved when every director and employee in the corporation understands the significance of compliance and takes appropriate steps to adhere to its principles, not only in business but also in their private lives.
The Compliance Committee, under the direct control of the President, serves as an organization to support and provide instruction to ensure compliance by the directors and employees of the Marubeni Group.
The Chief Compliance Officer (nominated by the President) is the person responsible for ensuring that the compliance system is observed throughout the whole of the Marubeni Group. The Chief Compliance Officer shall also be the Chairman of the Compliance Committee.
The Group and Branch Office Compliance Officers are responsible for ensuring compliance within their designated groups or branches.
If a person becomes aware of any conduct that is (or that he/she suspects may be) contrary to the compliance system, he/she should report it in accordance with the established lines of the staff organization. If the usual lines of reporting are not functioning properly for some reason, the following access points (collectively known as “Compliance Access Points”) are available:
The “Door of Courage” is the Compliance Access Point for general compliance matters. It is available to the directors and employees of Marubeni Group Companies. To make a report or seek a consultation using the “Door of Courage”, we should contact one of the following from the list below.
The “Marubeni Anti-Corruption Hotline” is the Compliance Access Point for concerns relating to bribery and other serious crimes. It is available to the directors and employees of our Group Companies and our business partners.
Rules on reporting to and consulting with a Compliance Access Point:
When compliance problems arise, the following procedure shall be followed.
This manual provides a framework for effective compliance within the Marubeni Group serving as a guideline to standards to be observed by all members of the Marubeni Group in the discharge of their daily operations. If you ever find yourself unsure about which course of action to follow from a compliance point of view, in the first instance you should refer to this manual. Having done so, if you are still unsure you should consult your manager or the relevant departments/sections in charge.
This manual shall be observed by directors and employees of the Marubeni Group as well as those who regularly work at the offices of the Marubeni Group, including part-time or temporary workers, and those working pursuant to outsourcing agreements. Each department shall be responsible for making all relevant workers aware of this Compliance Manual and for ensuring that they comply with its principles. The Marubeni Group referred to in this manual includes consolidated subsidiaries and other companies that are regarded as being “important affiliates” by Marubeni Corporation.
This manual is based on, and supersedes, the Marubeni Corporation Code of Conduct, which was published at the same time as the Marubeni Corporate Principles. This manual only applies to the operations conducted by the Marubeni Group Companies in Japan. Overseas offices are requested to prepare their own manuals based on the same principles but taking into account the laws, customs, and conventions of their countries and areas.
Furthermore, since the Marubeni Group deals in a broad range of goods, services and transaction formats, this manual has been drafted on the assumption that business groups or Marubeni Group Companies shall promptly compile their own detailed manuals in conformity with and complementary to this manual, if necessary.
If you become aware of a violation of this manual, if you are instructed by your superior to act in contravention of this manual, or if you find yourself inadvertently in contravention of this manual, you must not hesitate to report such contravention.
There are no particular corporate regulations to penalize for violation of this manual. Each contravention shall be judged and punished in accordance with the Employment Handbook and other applicable rules.
To respect human rights and not to discriminate or engage in any kind of Sexual Harassment or “Power Harassment”.
Not to engage in private monopoly, unreasonable restraint of trade (cartel) and other unfair trading practices.
Not to engage in unfair competition such as manufacturing and selling unlawful merchandise or unlawfully acquiring and using trade secrets.
To obtain licenses and permits necessary to carry out business activities and comply with various business laws and regulations.
To observe laws, regulations and international treaties relating to international trade and to follow appropriate procedures for import and export.
To observe strict security trade controls for maintenance of international peace and safety and not violate the law or enter into an inappropriate transaction as a global corporation.
To administer product safety properly in compliance with related laws and regulations in order to secure the safety of the products the company handles.
Not to infringe the intellectual property rights of others.
Not to provide, propose or promise an illicit benefit to public officials, their equivalents or relatives in Japan or overseas.
Not to aid or conspire with other business entities for any of the above acts.
Not to provide presents or client entertainment to a transaction partner that exceeds the accepted business and societal norms.
Not to engage in any activity for the benefit of any anti-social organization, and not to have a relationship with any such organization.
To be conscious of our responsibility as good corporate citizens and to use our best efforts to sustain a healthy environment and to act in harmony with the prosperity of the society.
Not to engage in an act which violates insider dealing regulations.
To carefully manage confidential information of both the company and others.
Not to improperly use or harm our IT systems.
To proceed with accounting, filing of tax returns and disclosure of company information properly.
To conduct the business of the company faithfully and to refrain from any acts which constitute conflicts of interest.