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 all other countries where the Group operates, 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

Compliance executives assigned to each main Group company work with compliance officers under their super-vision to evaluate risks faced by the company and implement suitable measures. The JGC Group has established a Group compliance system to ensure each company carries out its business based on high ethical standards. 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 Team at JGC Holdings Corporation is in charge of comprehensive measures, coordination, and other functions to promote Group-wide compliance.

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, the agents, consultants, vendors, subcontractors, joint ventures, and others who intend to do business with the JGC Group are screened to ensure compliance. 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 Team 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 levelspecific compliance training programs. Beginning, intermediate, or advanced training is given for all JGC group employees when they are promoted. Beyond compliance basics, the training features case studies and encourages each employee to view matters of compliance as personally relevant. Since fiscal 2021, a compliance training for general manager on responsibilities and preparedness as a compliance leader in their division was newly started.
Training is also conducted on specific topics, such as preventing corruption, dealing with harassment, or complying with subcontracting laws. For those involved in projects, other training addresses local compliance risks. In addition to these training programs organized by the head office, some domestic and overseas Group companies also conduct their own training programs for anticipated risks.

Courses and participation

Training courses in fiscal 2021

For prompt identification and prevention of compliance risks, the JGC Group Compliance Hotline was established as a resource that employees can use without hesitation to seek advice or report any concerns about actual or potential violations. Calls are answered by a third-party organization, which also enables anonymous consultation and reporting. The hotline is supplemented by internal lines at the two main operating companies, JGC Corporation and JGC Japan, to provide direct lines for consultation and reporting, which enables faster investigation and response. Offering several ways to seek advice and report suspicions provides a more convenient environment for employees to receive assistance. In addition to accepting reports from employees, we also accept reports of violation of corporate ethics from all suppliers working with Group companies.

Number of Reports Received by Hotlines