We make every effort to ensure that all of our business operations are carried out in an appropriate way, and that we focus on compliance risk management to maintain our stakeholders' trust.
In our Japanese market in the tobacco, pharmaceutical, and processed food businesses, every division is required to assess their compliance risks and submit action plans to address any risks identified. A compliance survey is conducted every year and each organization incorporates the results into their action plan.
With operations spanning the world, some of our businesses are conducted in jurisdictions with a high prevalence of bribery and corruption. Our Codes of Conduct clearly prohibit bribery and forbid corrupt practices in any form. Taking into account legislation such as the Unfair Competition Prevention Act of Japan, U.S. Foreign Corrupt Practices Act, U.K. Bribery Act, and anti-bribery laws in China, we have introduced the JT Group Anti-Bribery Policy.
We take a zero-tolerance approach to bribery, corruption, and other financial crime, and actively manage risks related to these areas.
In Japan, we run an e-learning course on anti-bribery and corruption periodically. Through this program, we aim to gain a better understanding of corruption with a view to preventing it at the JT Group and reducing the risk of becoming involved in corruption cases. The course focuses on business dealings with government bodies, etc. that use agents and where the risk is particularly high. The participation rate for the e-learning course in 2023 was 99.2%.
In our tobacco business**, we take a zero-tolerance approach to bribery, corruption, and other financial crime, and we actively manage risks related to these areas.
In 2022, as part of our annual focus on training, we provided training through Introduction to Compliance to 2,072 new employees, and anti-bribery and corruption training to 5,866 employees (new employees hired in 2022 and re-enrolled employees from previous years).
To mitigate the risks of bribery and corruption, we have also updated several corporate compliance procedures, including Employee Disclosure and Declarations, Know Your Business Partner, and Preventing Financial Crime.
We do not encourage the exchange of gifts, hospitality, or entertainment (GHE), but we recognize that occasional GHE is a common business practice. We must always be transparent when exchanging GHE, as such action could otherwise be interpreted as a bribe or conflict of interest.
To mitigate and prevent such risks, we have established internal GHE policies and procedures. These help to prevent bribery and conflicts of interest. They also help to ensure an appropriate level of GHE exchange, which must be transparent and reasonable, and must respect local regulations. Where our standards are stricter than local laws, we require our local offices to comply with our standards.
We provide regular training and run communication campaigns to ensure that compliance is well embedded within our organization.
Compliance with competition laws is covered by our Codes of Conduct, which require employees to compete fairly in all markets.
In our tobacco business*, we have a policy with detailed guidelines in place to ensure that our business is conducted fairly and in compliance with competition laws at all times. The policy requires our employees to conduct business in an ethical manner and in compliance with competition laws. For example, all personnel are required to determine JTI's commercial strategies and make decisions independently from our competitors and in the interest of JTI alone, without consultation, influence by, or access to competitors' competitively sensitive information.
In addition, we do not enter into agreements with competitors or third parties operating at different levels within the supply chain (e.g., trade customers, such as distributors or retailers) that have as their aim or effect the prevention, restriction or distortion of competition. Our customers must be free to make their own business decisions concerning their customers and how they compete in the market.
We have developed extensive training materials. Our employees are required to attend regular training sessions on compliance with competition laws and our policy.
We do not tolerate any form of financial crime. We perform policy controls and provide training programs to our employees. We also publish communications on the subject regularly. Our global policy sets out principles and guidelines to prevent employees from being involved in any form of financial crime, including money laundering, tax evasion, and facilitating tax evasion.
The JT Group Tax Policy outlines our approach to tax compliance, tax risk management, the utilization of external tax advisors, and our relationship with tax authorities. Read more on tax practices.