The JT Group has established the ''JT Group Compliance Policy,'' which summarizes the JT Group's values and ethics that are common globally, to practice compliance. In addition, we have tailored the Codes of Conduct to the unique environments and characteristics of each corporate and business unit, which serve as the basis for our employees' daily actions. Our Reporting Concerns Mechanism allows employees and business partners to report concerns in a confidential manner. We take a zero-tolerance approach to bribery, corruption, and other financial crime, and we actively manage risks related to these areas.
We train employees on the codes, and there are communication channels for employees to report concerns about potential breaches or violations.
Our employees sign an acknowledgment form to show their commitment to following our Codes of Conduct. In the biannual performance appraisal of employees at JT, confirmation of compliance with our Codes of Conduct is integrated into the process.
Our Codes of Conduct are reviewed every few years and revised when necessary, considering the environments in which we operate. We revised and updated the Codes of Conduct in 2012, 2015, and 2018. In 2021, we reviewed the codes in their entirety and evaluated the need for revision. As a result, after consulting with relevant divisions, we determined they were sufficient at that time, and left them unchanged. In 2024, we established the ''JT Group Compliance Policy,'' which summarizes the JT Group's values and ethics that are common globally, to practice compliance. In addition, we have tailored the Codes of Conduct to the unique environments and characteristics of each corporate and business unit, which serve as the basis for our employees' daily actions. In the future, we will continue to review the codes periodically and revise them when necessary. In our tobacco business*, the JTI Code of Conduct has been digitalized into an accessible, easy-to-read document, including a decision-making guide to assist employees in making the right choices. It is available in 42 languages.
*Tobacco business excluding Japan market
Training and communication
We continued to provide training on the Codes of Conduct to our employees in 2023. We provide training programs to all employees, regardless of their employment status (e.g., directly or indirectly employed, full or part time).
In our Japanese operations, 99.2% of employees completed the online courses.
To ensure that the JTI Code of Conduct is communicated effectively throughout the entire tobacco business*, we run various communication campaigns, initiatives and training courses for all employees. We also use an interactive Code of Conduct video in multiple languages to guide our employees to make the right choices.
*Tobacco business excluding Japan market
Compliance survey in Japan
In order to better implement compliance in our workplaces, each department in our Japanese operations makes Compliance Action Plans. These action plans are rolled out on a yearly basis, which means they are based on the results of the compliance survey and the status of our initiatives in the previous year.
We conduct a compliance survey every year. In 2023, 96.7% of employees completed the survey. Survey results are analyzed by JT's Legal and Compliance Division, and reported to the head of each department while ensuring confidentiality. Next, JT's Legal and Compliance Division develops an Annual Compliance Action Plan based on the results of the analysis. The relevant departments then introduce remediation plans to address any issues raised, using quantitative targets to evaluate the effectiveness of the plan.
Based on the survey results and compliance-related matters in 2023, we set priority issues in 2024 which are deemed necessary for each division, such as preventing harassment*. We will provide training programs incorporating these issues during Compliance Promotion Month in June and strengthen and implement necessary measures with related departments.
* Harassment includes sexual harassment and bullying.
Reporting concerns
Across the JT Group, each of our operating companies has specially trained members who handle compliance matters. If an employee is concerned about a potential violation of our Codes of Conduct, they can contact their line manager, their HR lead, or a member of the compliance team. We also provide an external concern-reporting service, run by an independent provider and available 24/7. In addition, the Audit & Supervisory Board members in our Japanese operations have established a consultation and reporting contact independent of business operations. Every reported concern and investigation report is treated on a strictly confidential basis, and retaliation against anyone reporting a concern will not be tolerated. Employees can file a report anonymously if they prefer. Our approach is explicitly described in our internal policy and employee handbook so that our employees can be aware of their rights and free of fear.
* In our Japanese operations, we distribute a Reporting Concerns Booklet to all employees with detailed information about the process for reporting concerns.
We believe that everyone should be able to raise concerns and have their voice heard, even if they do not have access to a company computer and/or the company network. That's why we ensure secure access to the reporting system for all of our employees, at all times and from anywhere.
We offer multiple communication channels for employees, customers, and business partners to confidentially raise concerns about potential violations of our Codes of Conduct or policies. We review all concerns raised, launch investigations as needed, and take appropriate corrective actions.
Employees are informed of our Reporting Concerns Mechanism through various channels, including the JT Group intranet. In our Japanese operations, the mechanism is available in five languages (Japanese, English, Chinese, Vietnamese, and Nepalese) to meet the needs of our diverse workforce.
Any concerns are then dealt with by specially trained contact persons, who all follow a mandatory training course.
In our tobacco business*, we are committed to achieving and maintaining the highest standards of ethical behavior and acting responsibly in all we do. JTI Reporting Concerns Mechanism, called ''Your Voice'', helps meet these standards by allowing employees and business partners to confidentially report behavior related to our business, which they believe is in breach of the JTI Code of Conduct, JTI policies and procedures, or applicable laws.
We believe that everyone should be able to raise concerns in relation to our business and have their voice heard. We ensure secured access to the Your Voice for all of our employees and business partners, either via a portal run by an independent provider, accessible 24/7 in more than 70 countries and 50 languages with a computer or phone, or via a dedicated email address.
Every reported concern and investigation report is treated confidentially. All substantiated instances of misconduct are addressed appropriately, and retaliation against anyone reporting a concern is not tolerated.
Examples of the types of issues that can be reported through our Reporting Concerns Mechanism are: human rights concerns, fraud, theft, corruption, money laundering, illicit trade, discrimination, moral and sexual harassment, or other forms of inappropriate behavior.
In 2022, we received 631 reports across the JT Group. In a total of 361 cases, violations of our Codes of Conduct we discovered, and we implemented remedial action in the form of dismissal, verbal or written warnings, financial penalties, or other measures. For instance, we took remedial action in 169 cases concerning fraud and misuse of company assets and 88 cases concerning labor practices (excluding human rights). More specifically, we took remedial action in 2 cases concerning corruption, 1 case concerning data privacy violation, 8 cases concerning conflicts of interest, and 1 case concerning discrimination. Regarding money laundering and insider trading, there were no substantiated cases, thus no remedial action was taken.
