Initiatives to Promote Compliance

The Compliance Implementation Guide, which contains the background of the Oiles Group Corporate Conduct Charter and keywords and explanations of compliance-related items, has been distributed to all employees to serve as a guide for their daily work. In addition, the Oiles Group Corporate Conduct Charter and Corporate Code of Conduct have been translated into English and Chinese to extend employees’ awareness about compliance on a global basis.

Moreover, we offer regular, employee-level-based Compliance Training programs, and each department conducts training on a topic-by-topic basis under the leadership of the department’s promotion leader. These efforts help deepen employees’ understanding of compliance.

The Oiles Group has established an “internal whistleblowing system” as a mechanism to identify compliance issues at an early stage and take countermeasures. Specifically, we have set up an internal reporting window at the Compliance Committee Secretariat (Legal Office of the Legal Department) and an outside reporting window at the law office to ensure thorough protection of whistleblowers during compliance-related consultations and reporting unfair practices. By improving the convenience of whistleblowers, we strive to identify and resolve problems at an early stage.

The Oiles Group requires its officers and employees to comply with the Antimonopoly Act, the Act Against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors (the Subcontract Act), and competition laws of various countries in light of the global trend of emphasizing fairness in business transactions, stricter laws and regulations, and the risk of damage to corporate value in the event of unfair practices. In accordance with the Group’s Antimonopoly Act Compliance Manual, its officers and employees are required to comply with the Antimonopoly Act during their daily business activities, including prohibiting any contact with competitors that may violate the act and reporting any such contact to their supervisors. Furthermore, to ensure compliance with the Subcontract Act, we are raising awareness and training employees to prevent violations of the act while also strengthening the managerial aspect.

The Oiles Group has built a sound relationship with politicians and other administrative bodies while prohibiting acts that could be misunderstood as providing profits or collusion. Moreover, we have established the Bribery Prevention Regulations, which prohibit bribery by officers and employees of the Group to public officials and prohibit the provision of excessive entertainment and gifts to private operators. When entertaining or gift-giving, we thoroughly follow the guidelines established in accordance with domestic and foreign laws and regulations.

The Oiles Group refuses all connections to antisocial forces or organizations that threaten the order or safety of society and steadfastly confronts them. We closely verify that our business partners are not a part of antisocial forces and include a clause on eliminating antisocial forces in our Basic Transaction Agreements to prevent any transactions with such groups. If any antisocial force or organization contacts us, we cooperate with the police, lawyers, and other external institutions, and the entire Group, including top management, works together to address this issue at the organizational level.