- Corporate Ethics Compliance Initiatives
- Corporate Ethics and Human Rights Training
- Conducting Employee Awareness Survey
- Distributing the In-House E-Mail Magazine “Panda News”
- Avoiding Any Relationship with Organized Crime Groups
- Restricting Entertainment and Gifts (Prohibiting Bribery and Preventing Corruption)
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 of the Group to act in good faith, according to 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 Compliance Initiatives
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, we distribute the Cosmo Energy Group Code of Conduct booklet for all Group employees and provide corporate ethics and human rights training. We also have established internal and external consultation services, our Corporate Ethics Consultation Helpline, where employees can anonymously consult about and report misconduct and ethical issues, including violations of laws, internal rules, and other ethical issues. Through these initiatives, we are working to establish and strengthen our compliance promotion systems and prevent violations before they occur.
Under the supervision of the Board of Directors, Cosmo Energy Holdings formulates and operates basic policies on corporate ethics. It also promotes and verifies efforts to respect human rights and prevent and eliminate all human rights violations, both in Japan and overseas. The status of these initiatives is reported to the Sustainability Strategy Council.
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. In addition, matters such as compliance with corporate ethics and the operation of the consultation helpline system are regularly reported to the Sustainability Strategy Council, the Executive Officers’ Committee, and the Board of Directors.
Scope of Corporate Ethics Violations
We define corporate ethics violations as violations of matters stipulated in the Cosmo Energy Group Code of Conduct and other guidelines.
The main examples are as follows:
- Safety: Matters related to occupational health and safety, the workplace environment, and accidents and disasters
- Trust: Promotion of fair transactions based on laws and contracts and prohibition of inappropriate conduct concerning quality and services
- Human rights: Respect for basic human rights, prohibition of discrimination, and prohibition of harassment
- 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 others, prohibition of unfair competition, ensuring fair transactions (compliance with Japan’s Anti-Monopoly Act and other applicable laws), prevention of corruption, compliance with rules concerning entertainment and gifts (prohibition of bribery), avoiding any relationship with organized criminal groups, and appropriate management and 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.
Our consultation and reporting system covers all issues related to corporate ethics in corporate activities, such as violations of laws and regulations, violations of internal rules, and conduct that may be considered to violate the Group Code of Conduct. Consultations and reports are accepted from all parties involved in the Group’s business activities, including Cosmo Energy Group officers and employees (including former officers and employees) and business partners.
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 support the early resolution of issues in the workplace environment by offering counseling by outside experts. Employees can also utilize the counseling services of a psychiatrist if needed.
In fiscal 2025, the number of consultations totaled 54 (20 violations of company rules, etc., 29 cases of harassment, and 5 consultations on other issues.)
In fiscal 2025, the Group recorded zero serious compliance violation※.
※ 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 works to create even better workplaces by ensuring the implementation of its Group Code of Conduct. As part of these efforts, we provide corporate ethics and human rights training as employee education to ensure the appropriate conduct of business and actions based on high ethical standards as well as to prevent and eliminate human rights violations.
This training is conducted annually in an e-learning format for all Group employees. In addition to the Cosmo Energy Group Code of Conduct, the training materials incorporate content reflecting social topics related to corporate ethics and human rights, as well as changes in laws and regulations and the social environment during the relevant fiscal year. The training is designed to enable employees to respond appropriately to changes in the business environment.
Furthermore, to ensure that the training goes beyond simply acquiring knowledge or passively listening to the content, we have enhanced the training by incorporating questions and case studies that encourage each employee to think independently and deepen their understanding.
In fiscal 2025, the training was conducted in September, with approximately 6,900 employees across the Group participating. Going forward, we will continue to promote initiatives to raise employees’ awareness of corporate ethics and human rights and foster and maintain high ethical standards.
Fiscal 2025 Corporate Ethics and Human Rights Training Program
1. Message from Shigeru Yamada (Group CEO)
2. Implementing the Code of Conduct
3.Human rights and diversity
4. Knowledge of laws, regulations, rules
Fiscal 2025 Corporate Ethics and Human Rights Training
Participants: 6,900
Participation rate: 100%
Fiscal 2025 Incorporating content related to corporate ethics and Human rights into various training programs
| 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 | 41 (key positions) 48 (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. | 22 |
| 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 | 37 (key positions) 46 (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. | 23 |
| 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 | 48 (key positions) 34 (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. | 23 |
| 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 |
Conducting Employee Awareness Survey
The Group also conducts an employee awareness survey annually to assess the extent to which the Code of Conduct has been embraced and employees’ awareness of compliance and corporate ethics. The findings are used when considering and implementing various initiatives to promote sustainable management and improve the workplace environment.
In fiscal 2025, the survey was conducted in November among Group employees. Of the 8,013 employees surveyed, 7,814 responded, resulting in a response rate of 97.5%.
The survey results are used to develop and promote initiatives aimed at further embedding the Code of Conduct, raising awareness of compliance, and improving the workplace environment.
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 the In-House E-Mail Magazine “Panda News”
Panda News is an in-house e-mail magazine featuring animal characters who illustrate in an easy-to-understand manner often-overlooked cases or rules related to corporate ethics and compliance. In the magazine, a mouse raises familiar issues, while a panda makes each issue black and white by clarifying the appropriate course of action. Through this format, Panda News provides employees with an opportunity to think about corporate ethics and compliance.
We have been distributing Panda News every other month since January 2014. Through these ongoing awareness-raising activities, we aim to enhance Group employees’ sensitivity to risks and issues that may be hidden in their daily work and workplace life, and encourage them to act in good faith based on the Code of Conduct.
In fiscal 2016, we added a bat character who engages in problematic behavior. By presenting specific cases and encouraging employees to consider how they themselves might act in similar situations, the magazine helps them deepen their understanding of the importance of acting in good faith.
In fiscal 2025, while continuing to focus on the practice of the Code of Conduct, we included topics such as common compliance violations, violations of internal rules, and near-miss incidents that may occur in everyday work. We also incorporated content based on actual cases and circumstances, with the aim of helping employees recognize these issues as familiar and relevant to their own work and workplace.
Topics (Fiscal 2025)
| SNS Postings | May 26, 2025 |
| Corporate Ethics Hotline | July 25, 2025 |
| Unintentional Power Harassment | September 25, 2025 |
| Harassment related to drinking parties | November 25, 2025 |
| Amendments to the Subcontracting Act and the Fair-Trade Act | January 26, 2025 |
| Not everything is power harassment | March 25, 2026 |
| SNS Postings | May 24, 2024 |
| Sexual harassment | July 25, 2024 |
| Smoking rules at work | September 25, 2024 |
| Handling of Internal Information | November 25, 2024 |
| Rules for entertainment and gifts | January 27, 2024 |
| Violation of Laws and Regulations without Noticing | March 25, 2025 |
| Sustainable Procurement | May 25, 2023 |
| Being aware of International Money Transfer Fraud | July 25, 2023 |
| Business communication and information sharing | September 25, 2023 |
| Mandatory alcohol detection by alcohol detector | November 25, 2023 |
| Smoking Manners | January 25, 2024 |
| Sexual harassment | March 25, 2024 |
| 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 |
Avoiding Any Relationship with Organized Crime Groups
The Cosmo Energy Group Code of Conduct stipulates that the Group will have no relationship whatsoever with organized criminal group or organizations, will not provide them with any benefits, and will not engage in illegal activities such as money laundering. Based on this policy, the Group is committed to avoiding all interaction with organized criminal groups.
We also include clauses on the exclusion of organized criminal groups in contracts with business partners and confirm, both when starting transactions and throughout ongoing business relationships, they have no relationship with such groups.
Restricting Entertainment and Gifts (Prohibiting Bribery and Preventing Corruption)
To promote fair and honest business activities, the Cosmo Energy Group Code of Conduct establishes appropriate rules concerning entertainment and gifts and thoroughly prohibits bribery and prevents corruption.
The Group not only refrains from engaging in corrupt practices itself, but also requires business partners, including designated dealers and agents, to undertake similar efforts. Accordingly, the Group strives to maintain fair and highly transparent business relationships.
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 2025 Activities Related to Preventing Corruption
The Cosmo Energy Group is committed to thoroughly preventing corruption, including bribery.
In the fiscal 2025 corporate ethics and human rights training, Shigeru Yamada, our Group CEO, delivered a message emphasizing the importance of compliance with laws and regulations. The training also highlighted the “prohibition of bribery” as one of the key topics, seeking to enhance Group employees’ compliance awareness.
In addition, the Sustainable Procurement Guidelines stipulate that business partners must not engage in corrupt practices, including corruption and bribery, as an important requirement for business transactions. At the same time, we seek the understanding and cooperation of business partners in efforts to prevent corruption, thereby working to prevent corruption throughout the entire supply chain.
In fiscal 2025, there were no cases of corruption, including entertainment and gifts or bribery, that violated laws and regulations, etc.