Ethics
Chapter 1. General provisions
1-1. Purpose
These guidelines set out what to decide by when staff face judgement calls at work, how that standard is put into practice, and what happens when it is not met.
1-2. Scope
- The guidelines apply to all employees, at home and abroad alike.
1-3. Definitions
Gifts: includes promising or offering to provide.
Cash, securities, real estate, goods, lodging, memberships and tickets.
Meals, entertainment, transport and lodging.
Debt relief, job placement, granted privileges and other benefits with no physical form but a measurable value
Payments disguised as donations or sponsorship.
Reporter: an employee obliged to report a prohibited benefit.
Whistle-blower: a person who informs the company of conduct harmful to it, whether or not they are an employee and whether or not they are still with the company.
Stakeholder: any counterpart other than clients and employees whose business judgement we affect or are affected by, including partners, media owners and other trading counterparts.
Public official: officials of the state and local government, employees of public institutions and state-run bodies, and anyone carrying out public duties entrusted by law; abroad, the scope set by local law and practice is weighed as well.
Manager: an employee holding a team-lead or higher post, who carries the same duty while acting in that post.
* Examples of who counts as a public official abroad.
1. Central and local government officials.
2. Employees of state-owned enterprises.
3. Officers of public international organisations.
4. Political parties, their officers and candidates.
1-4. How to decide
- When in doubt, ask a superior and the audit function before deciding, and record the answer and the grounds for the decision.
1-5. Duties of employees
- Put client interests first and follow the law and internal rules; where the two differ, follow the stricter one.
- Judge by the whole company’s interest rather than a local one, and record the grounds for that judgement.
- Report a risk found at work as soon as it is found, without hiding or deferring it.
- Stay out of transactions that may conflict; where involvement is unavoidable, disclose it in advance and obtain approval.
- Learn the principles and guidelines in advance and apply them at work, checking what has changed after each revision.
- Ignorance is no excuse; borrowing a family member’s or acquaintance’s name, or reaching the same result through a third party, counts as a breach and is treated as if done directly.
1-6. Duties of managers
- Brief team members regularly so they understand and keep the guidelines, and walk newcomers through the judgement calls that come up most often in their work.
- Keep decisions and the reasoning behind them visible to the team, and lead by example.
- Managers share responsibility for violations and never penalise reporters.
1-7. Rewards and sanctions
- Employees and outside partners who help meet the purpose of these guidelines may be commended; the audit function sets and publishes who qualifies each year.
- Employees who breach the code go through the internal disciplinary process.
1-8. How to report
- Internal report — tell the audit function.
- Reports are handled anonymously and the reporter protected.
- Self-report — voluntary disclosure is taken into account.
- Managers must pass self-reports on without delay.
- Unwanted gifts are returned without delay; where return is impossible, how they arrived and how they were handled is documented and passed to the audit function.
- ※ Good faith is protected; the facts are still verified.
- External report — clients and partners may use the same channel as employees, and the intake point is published both inside and outside the company.
- External reporters and their reports get the same protection as internal ones, and no trading term or contract is changed to their disadvantage because of a report.
- Each report is assigned an owner and its progress logged by stage.
- Once facts are confirmed, remedy and prevention plans are set together.
- Reporting statistics are compiled annually for management.
1-9. Interpretation
Matters not covered here are interpreted by the audit function, and where interpretations differ the executive responsible for ethics decides.
Customary limits are read as follows.
Meals — within customary amounts for work or courtesy.
Gifts — within customary amounts for courtesy.
※Vouchers and other securities are excluded from gifts whatever the amount; on discovering one has been received it is returned at once and the head of the unit is told how it happened.
Condolence money — customary amounts only.
※Abroad, local law and custom apply.
Requests beyond the limits are politely declined and the circumstances recorded; where declining is not possible, a superior is told first, the handling is agreed together before acting, and the outcome is reported back.
Recurring questions are published internally as worked examples, reviewed yearly and folded into revisions; changes are announced on the intranet and in regular training so every employee sees them.
1-10. Overseas operations
- Local anti-bribery law applies alongside these rules.
1-11. Effective dates
- Effective 1 January 2020.
- Effective 28 June 2021.
- Effective 17 September 2021.
- Effective 30 August 2024.