Pursuing Stronger Compliance

The Cosmo Energy Group Management Vision is, “In striving for harmony and symbiosis between our planet, man and society, the Cosmo Energy Group aims for sustainable growth towards a future of limitless possibilities.” As part of our efforts to achieve this vision, we recognize that it is imperative for the Group to comply with all relevant laws and regulations, internal rules, and social norms. Accordingly, the Cosmo Energy Group Code of Conduct requires all officers and employees to act in good faith with high ethical standards. Based on the Management Vision and Code of Conduct, the Group established the Compliance Policy to define its basic approach when operating our business with the emphasis on compliance.

Corporate Ethics Implementation Structure

In order to achieve “sustainable development” as set out in the Group Management Vision, we have established the Cosmo Energy Group Code of Conduct, which defines the actions that all officers and employees should take and the rules they must observe in their everyday work. With the objective of raising the ethical awareness of each and every employee, the Sustainability Strategy Committee works to improve systems and reduce non-compliance by developing various measures such as corporate ethics and human rights training, and establishing several consultation services where employees can anonymously consult about and report misconduct and ethical issues, including violations of laws, internal rules, and other ethical issues.

The Sustainability Strategy Committee and Sustainability Committee were established under the supervision of the Board of Directors to determine, promote, implement, and confirm basic policies regarding corporate ethics. These two bodies also promote, implement, and confirm efforts to respect human rights and prevent and eliminate all human rights violations both in Japan and overseas. To firmly embed the Cosmo Energy Group Code of Conduct, ensure that all employees comply with it, and to raise the ethical awareness of each and every employee, the committees plan, implement and evaluate various measures, including corporate ethics training and e-learning for all Group employees.

Corporate ethics implementation structure

Corporate ethics implementation structure

Additionally, in order to promote corporate ethics and human rights measures, the Company’s Sustainability Initiative Department implements measures to internally disseminate compliance with laws, regulations, and rules and specific actions to ensure thorough compliance, with important matters being reported to and decided by the Sustainability Strategy Committee.

If and when they arise, corporate ethics violations are promptly reported to the executive officer in charge of the Sustainability Initiative Department and the directors who are Audit and Supervisory Committee members. This is also followed by a report to the Sustainability Strategy Committee from the officer with responsibility on the status of compliance with corporate ethics and other matters discussed by the Sustainability Strategy Committee and Sustainability Committee, with more important incidents being reported to the Board of Directors.

The issues promoted, implemented, and confirmed by the Sustainability Strategy Committee and the Sustainability Committee are not restricted to violations of laws and regulations, but also consist of the following examples, including ESG factors.

  • Safety: Workplace environment, operational efficiency, and time management
  • Trust: Fair transactions and sustainable procurement
  • Human rights: Respect for basic human rights, prohibition of discrimination, work-life balance, prohibition of harassment, self-development
  • Ethics: Thorough enforcement of corporate ethics, prohibition of insider trading, prohibition of conflicts of interest, appropriate use of company property, respect for intellectual property of other companies, prohibition of unfair competition, fair transactions (Anti-Monopoly Act), prevention of corruption, restriction of entertainment and gifts (prohibition of bribery), avoiding any relationship with organized crime groups, and appropriate handling of information

Cosmo Energy Group Corporate Ethics Consultation Helpline

We have established contact points for the Cosmo Energy Group Corporate Ethics Consultation Helpline both in and outside the Group, allowing employees to anonymously discuss and report misconduct by their colleagues such as violations of laws and company rules (including harassment), as well as ethical issues.

Reporting covers all issues related to corporate ethics in corporate activities, such as violations of laws and regulations, violations of internal rules, human rights violations and harassment, bribery (anti-corruption) and bid-rigging. Consultations and reports are accepted not only from Cosmo Energy Group officers and employees, but also from all parties involved in the Group’s business activities, such as business partners.

Number of reports to Corporate Ethics Office (past five years)

Number of consultations

In addition, external helpline contact points accept consultations on sexual harassment, power harassment, and other concerns related to human relationships in the workplace. We work to prevent mental health problems and enable employees to resolve issues in the workplace environment by themselves at an early stage by offering counseling by outside experts. Employees can also meet with a psychiatrist if needed.

In fiscal 2022, the number of consultations totaled 35 (seven violations of company rules, 11 cases of harassment, and 17 consultations on other issues.)

In fiscal 2022, the Group recorded one serious compliance violation1 (improper product testing and inspection), and we have worked to strengthen quality management systems and taken thorough measures to prevent a recurrence.

The improper testing and inspection that were identified were immediately corrected, and investigations into the products that were shipped have confirmed that there are no quality problems. The incident was also reported in a Cosmo Energy Holdings press release.

 

1. A violation or incident that falls within the crisis level that could have a significant adverse impact as defined in the company's internal rules

Corporate Ethics and Human Rights Training

The Cosmo Energy Group provides corporate ethics and human rights training as employee education aimed at ensuring appropriate conduct of business and ethically-aware actions and preventing and eliminating human rights violations with the objectives of implementing the Cosmo Energy Group Code of Conduct and creating a better workplace.

In accordance with the Cosmo Energy Group Code of Conduct, e-learning (online learning) in implementing sustainable management and the Code of Conduct and the importance of working on human rights and diversity measures is provided for all Group employees each year. In fiscal 2022, training was provided for all Group employees in October 2022, and 6,699 employees took part. We created our own teaching materials with the aim of deepening understanding about conducting business in good faith and maintaining a high level of ethical awareness.

Fiscal 2022 Corporate Ethics and Human Rights Training Program

1. Message from Hiroshi Kiriyama (then Group CEO, currently Group Chairman)
2. Implementing the Code of Conduct
3. Human rights and diversity
4. Knowledge of laws, regulations, and rules
5. Questions to check understanding
6. Questionnaire

Fiscal 2022 Corporate Ethics and Human Rights Training
Participants: 6,699
Participation rate: 100%

Fiscal 2022 Results of Training Incorporating Corporate Ethics and Human Rights Education

Training title Topics Number of participants
New recruit training Group Management Vision, Code of Conduct, human rights, sustainability, misconduct, harassment, and the Corporate Ethics Consultation Helpline

31 (key positions)

40 (technical experts)

Newly appointed line manager training Labor management, human rights (harassment), employment of people with disabilities, finance, implementation of the Code of Conduct and sustainable management, internal control, corporate governance, branding activities, etc. 39

Training title Topics Number of participants
New recruit training Understanding of the Group Management Vision and Code of Conduct, sustainability at the Cosmo Energy Group, misconduct and harassment and the Corporate Ethics Consultation Helpline (online training)

37 (key positions)

45 (technical experts)

 

Newly appointed line manager training Understanding of the Group Management Vision and Code of Conduct, Basic Concept of Sustainability, misconduct and harassment and the Corporate Ethics Consultation Helpline 39

Training title Topics Number of participants
New recruit training Understanding of the Group Management Vision and Code of Conduct, the Consolidated Medium-Term Sustainability Plan, misconduct and harassment and the Corporate Ethics Consultation Helpline (online training)

24 (key positions)

66 (technical experts)

Newly appointed line manager training Group Management Vision and Code of Conduct, Basic Concept of Sustainability, risk management, misconduct and harassment and the Corporate Ethics Consultation Helpline 35

We also shared information on correct accounting procedures when holding a presentation on consolidated financial results for employees.

Training title Topics Number of participants Training time
New recruit training Understanding of the Group Management Vision and Code of Conduct, CSR activities policy, misconduct and harassment and the Cosmo Energy Group Corporate Ethics Consultation Helpline (online training)

32 (key positions)

67 (technical experts)

60 minutes
Newly appointed line manager training Code of Conduct, Cosmo Energy Group’s CSR management, risk management, misconduct and harassment and the Corporate Ethics Consultation Helpline (e-learning and test) 28 30 minutes

Training title Topics Number of participants Training time
New recruit training Understanding of the management philosophy and Code of Conduct, CSR activities policy, and sharing of ethical awareness through group discussion

30 (key positions)

46 (technical experts)

50 minutes
Newly appointed line manager training Role of line managers in achieving goals in Code of Conduct and CSR activities policy 43 30 minutes

We also shared information on correct accounting procedures when holding a presentation on consolidated financial results for employees.

Conducting Employee Awareness Survey

In November 2022, we conducted the annual employee awareness survey of employees of the Cosmo Energy Group.

In fiscal 2022, there was a high response rate of 95%, with 7,469 responding out of the 7,864 potential survey subjects.

We conduct the survey each year in order to assess employees’ understanding of the Code of Conduct and their awareness of compliance and corporate ethics in promoting sustainability management. The results are used for various measures such as fulfilling sustainability management and creating a better workplace.

Question Categories

Compliance culture
Current status of compliance
(existence of violations, harassment, etc.)
Understanding of the Group Management Vision
Compliance system and its embeddedness
Fairness and future prospects
Customer and external orientation
Management behavior of supervisors
Mutual trust in the workplace
Fulfillment and pride in one’s work

Distributing Panda News


Panda News is an in-house e-mail magazine featuring a mouse character who raises problems concerning often-overlooked events or rules related to corporate ethics and a panda who makes the issue black and white. We have been distributing Panda News every other month since January 2014 with the aim of increasing the sensitivity of Group employees to pick up on hidden problems in their daily lives by continuing to raise their awareness on a regular basis.

In fiscal 2016, we added a new bat character who displays problematic behaviors to remind readers even more of the importance of acting in good faith by putting themselves in the position of the characters.

In fiscal 2022, while continuing to focus on the practice of the Code of Conduct, we have included topics that incorporate internal case studies, picking up common compliance and rule violations and near-miss moments.

Panda News

Topics (Fiscal 2022)

COVID-19-related harassment May 25, 2022
Being aware of incomplete records on entertainment and gifts July 25, 2022
Difference between power harassment and leadership August 25, 2022
Being aware of risks related to social media posts September 27, 2022
Being aware of psychologically abusive remarks at work-related functions involving alcohol November 28, 2022
Being aware of Road Traffic Act violations January 25, 2023
Being aware of data falsification and compliance violations March 23, 2023

Let’s take proper measures to control COVID-19 May 25, 2021
Unpaid overtime is a compliance violation July 26, 2021
Improper giving or receiving of money and other benefits September 27, 2021
Rules on smoking during working hours November 25, 2021
Coercing participation in out-of-work socializing January 18, 2022
Online harassment March 25, 2022

Differences in instruction systems for temporary staff and subcontract workers May 25, 2020
Telework harassment July 27, 2020
Compliance with the rules September 25, 2020
Entertainment and gifts November 25, 2020
Cyber attacks January 25, 2021
Scope of compliance March 25, 2021

Password management for electronic files: Handling confidential information carefully May 24, 2019
The need for labor management: Observing the rules for working hour applications August 1, 2019
The difference between power harassment and guidance September 25, 2019
Too much alcohol will be your downfall November 29, 2019
Do you comply with laws, regulations, and internal rules? January 24, 2020
Appropriate receipt and inspection procedures March 31, 2020

Infringements of work rules: Morals as a working adult May 25, 2018
Drink driving: Do you have a sense of responsibility as a member of a motorized society? August 3, 2018
Power harassment and sexual harassment at internal social events: Even once is unacceptable September 25, 2018
Occupational accidents: Let’s prevent them by making small changes in each and every employee’s awareness November 26, 2018
Reporting in a crisis: Report promptly without deciding on things alone! January 25, 2019
Improper accounting procedures: Let’s learn the right knowledge! March 25, 2019

Avoiding Any Relationship with Organized Crime Groups

The Cosmo Energy Group avoids any relationship with organized crime groups, stipulating in the Code of Conduct, “We have absolutely no relationship with organized criminal elements or groups who may threaten social order or safety, and we do not compromise with them or grant them any benefit whatsoever. We also do not involve ourselves in money laundering.”

We also verify that our business partners do not have any relationship with organized crime groups by including a clause on the exclusion of organized crime groups in contracts with them.

Restricting Entertainment and Gifts (Prohibiting Bribery and Preventing Corruption)

The Cosmo Energy Group places great importance on honest transactions and states the following restrictions on entertainment and gifts, prohibition of bribery, and prevention of corruption in the Cosmo Energy Group Code of Conduct. The Group not only refrains from engaging in corrupt practices itself, but also requires business partners, including agents, to comply with its guidelines.

6-3-6 Restricting entertainment and gifts
We do not give or receive entertainment or gifts that deviate from social norms or internationally accepted conventions. Moreover, we do not give or receive inappropriate entertainment or gifts for the purpose of providing personal or other improper benefits.

6-3-7 Maintaining healthy relationships with government and administrative agencies
Be it in or outside Japan, we do not entertain or exchange gifts with civil servants or equivalent persons (including former civil servants). We also do not make improper monetary donations, payoffs or benefits to politicians (including political candidates and former politicians) or political organizations.

6-3-8 Prohibiting bribery
We do not engage in bribery, or promise or request bribes.

Details of Fiscal 2022 Activities Related to Preventing Corruption

As part of the fiscal 2022 corporate ethics and human rights training, topics included “Prohibiting Bribery,” and the top management message from Hiroshi Kiriyama (then Group CEO, currently Group Chairman) informed employees about compliance with laws and regulations. Cosmo Energy Holdings has made it clear to business partners in its Sustainable Procurement Policy that one of its conditions for engaging in business transactions with a company is that it does not engage in corrupt practices, such as corruption and bribery. We also encourage our business partners to take these measures related to preventing corrupt practices.

In fiscal 2022, there were zero cases of entertainment and gifts that  violate laws and regulations, etc. (corruption), and zero employees were disciplined for bribery.