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

Within our Group, each company conducts business activities based on a high ethical standard, and in order to ensure these activities are carried out responsibly, we not only ensure strict compliance with anti-bribery laws in Japan, the United States, the United Kingdom, and other relevant jurisdictions but also assess reputational risks to ensure that our business partners are free from illegal activities and not tarnished by negative information, with our fundamental policy being only to engage with trustworthy business partners.

Under these policies, business partners intending to do business with the JGC Group are screened in advance to prevent illegal transactions or those that could result in sanctions. Based on the results, we implement any necessary risk-based measures, such as stipulating strict anti-corruption clauses in contracts with business partners, or any other clauses deemed appropriate. In addition, under the Group’s purpose and our Code of Conduct, we have developed bribery prevention rules and regulations as shown in the table above, and implemented bribery prevention programs. Any gifts, entertainment, donations, or contributions must be approved in advance and monitored, so that we are aware of transactions that may be linked to corruption or reputational risk.

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.
Furthermore, a top message (Tone at the top) connecting all Group companies has been crafted, with senior management emphasizing compliance directly to employees in order to instill a sense of compliance in all of our Group executives and employees.

Courses and participation

Training courses in fiscal 2023

• *Expanding it to both domestic and overseas Group companies as of 2024