Guided by our sense of purpose and values representing our corporate philosophy, we view compliance as the cornerstone of management, based on two keywords in a list of shared values-respect and integrity. As a member of the international community, the JGC Group believes that compliance with the laws of Japan and overseas as well as fair and equitable business practices in accordance with corporate ethics, are essential to the pursuit of sustainable business development. Based on this belief, the Group has developed the JGC Group Code of Business Conduct. The code, which must be followed by all employees, contains key points to ensure that the JGC Group's corporate philosophy is implemented in practice.

Although the company formulated the Code of Business Conduct in 2002, since then the demands of society towards compliance efforts required of companies have become more diverse and in-depth. In April 2018, the JGC Group revised the previous Code of Business Conduct in response to these changes in social conditions , and established the new JGC Group Code of Business Conduct in order to make its contents more comprehensive and concrete.
This JGC Group Code of Business Conduct specifically indicates the standards for actions and decisions that we should follow, as we put our corporate philosophy, the JGC Way, into practice.

• The JGC Group Code of Business Conduct

The JGC Group has established a Group compliance system to ensure each company carries out its business based on high ethical standards. Compliance executives assigned to each main Group company work with compliance officers under their supervision to evaluate risks faced by the company and implement suitable measures.
The JGC Group has also established the Compliance Committee as a forum to share information and collaborate among Group companies. We are aiming to achieve a sense of unity to the entire Group through the Committee. The Compliance Unit at JGC Holdings Corporation is in charge of comprehensive measures, coordination, and other functions.

For prompt identification and prevention of compliance risks, the JGC Group has made available several ways to seek advice and report suspicions, mainly based on the "JGC Group Compliance Hotline" external contact point to facilitate anonymous consultation and reporting. In addition to accepting reports from employees, we have created a convenient system that also responds to consultations and accepts reports of violations. A system has also been developed that allows suppliers to submit reports via our homepage.

Number of Reports Received by Hotlines

The JGC Group follows a basic policy of complying with all anti-bribery rules and regulations, such as provisions in Japan's Unfair Competition Prevention Law prohibiting the bribing of foreign public officials, the US Foreign Corrupt Practices Act (FCPA), and the UK Bribery Act 2010. Group rules on preventing bribery, based on our corporate philosophy and Code of Business Conduct, are summarized in the following table.

Under these anti-corruption programs, business partners intending to do business with the JGC Group are screened to ensure compliance, and the results enable us to implement any necessary risk-based measures, such as stipulating strict anti-corruption clauses in contracts with business partners. Any gifts, entertainment, donations, or contributions must be approved in advance, so that we are aware of transactions that may be linked to corruption.
Compliance is also monitored to ensure implementation of anti-bribery programs at Group companies. Each year, members of the Compliance Unit of JGC Holdings visit several Group companies. Executives and employees are interviewed and records audited to identify issues and make improvements.

Awareness of compliance is enhanced through thematic and level-specific compliance training programs. Four types of level-based courses including beginner training to suit employees' positions are available for employees at group companies in Japan. Beyond compliance basics, the training features case studies and encourages each employee to view matters of compliance as personally relevant.
Some domestic and overseas Group companies also conduct their own training programs for anticipated risks, or covering a range of individual topics.

Courses and participation

Training courses in fiscal 2022