Twice a year (principally in March and October), the Management Ethics Committee chaired by the President meets to formulate company-wide policy and confirm and discuss matters such as the handling of inquiries and consultations by the compliance advisory service desks, monitoring of compliance awareness among employees, and results of compliance audits.
We have also established Compliance Committees in each unit to build a structure whereby compliance activities are continuously and independently promoted.
Over 300 management-level personnel have been appointed "compliance managers" and "compliance promoters" at each workplace to lead action to promote concrete compliance activities. To further stimulate action on compliance, information is shared through channels such as the Compliance Promoter Liaison Committee (convened in January in fiscal 2016, with 274 participants).
Compliance Promotion Structure
■Compliance advisory service desks
Tokyo Gas established a system of compliance advisory service desks for itself and its subsidiaries in October 2004.
Employees can contact the compliance advisory service desks directly when they feel hesitant about raising a matter within their organization, and they have a choice of two routes: internal (through the Compliance Department) and external (via a law firm and communication support center). Inquiries and consultations are treated in strict confidence, and discriminatory treatment of employees who use the desks is prohibited. The compliance advisory service desks also function as internal points of contact as provided for under the Whistleblower Protection Act. In line with the expansion of protection following the entry into effect of the Whistleblower Protection Act in April 2006, the coverage provided by the desks was expanded to include suppliers and customers as well as members of Tokyo Gas Group.
Independent advisory services have also been established at all subsidiaries and Tokyo Gas LIFEVAL (“LIFEVAL”) companies. In October 2016, training sessions were held for the personnel staffing the compliance advisory service desks at subsidiaries and LIFEVAL companies to enhance their ability to handle inquiries and consultations.
These desks play an effective role in enabling our company to quickly discover and solve problems related to compliance, thus ensuring that our corporate self-governing actions function more effectively.
Status of Use of Compliance Advisory Service Desks (FY2016)
|Type of case||Number of cases|
|Interpersonal relations and employment matters||17|
|Laws and regulations||11|
Tokyo Gas, our subsidiaries, and LIFEVAL companies organize a range of activities to encourage employees to apply Tokyo Gas Group Our Code of Conduct to their own situations and put it into practice.
■Workplace workshops using training resources
Workshops led by compliance promoters are held at the level of individual workplaces at Tokyo Gas, our subsidiaries, and LIFEVAL companies (25,136 employees took part in fiscal 2016). These workshops feature a set of awareness-raising resources entitled “The Case Method,” “Collected Cases of Compliance,” and “Learning from Cases! Collected Statutes.” Developed in light of Tokyo Gas Group Our Code of Conduct, these are used to improve participants’ understanding of the laws, ordinances, and rules pertaining to practice of Our Code of Conduct and to help them apply the code in practice.
■Raising compliance oriented mentality through training sessions
Legal issues that may arise when interacting with customers and managing personnel are explained using the case study approach.
Training is provided annually to Tokyo Gas Group employees to improve understanding of legislation that the Group has to comply with.
In fiscal 2016, around 500 group employees took part in 12 training sessions on the Antimonopoly Act, the Act against Unjustifiable Premiums and Misleading Representations, and the Subcontract Proceeds Act. During these sessions, concrete instances of legal violations* are explained and practical information is provided.
* Cases include examples of cartels and abuses of superior bargaining position (Antimonopoly Act), and misleading representation (Act against Unjustifiable Premiums and Misleading Representations).
A training session on the Antimonopoly Act
We are working to raise the standard of compliance by widely publicizing within Tokyo Gas Group up-to-date information on the compliance risks associated with changes in the business environment facing the Group, including those stemming from our evolution as a total energy business, acceleration of our global business development, and the revision and stricter enforcement of various legislation.
One way in which we share this information is by publishing a bimonthly newsletter called "Compliance Information" to serve as a support resource for the compliance managers and promoters who lead compliance activities at our company, subsidiaries, LIFEVAL companies, and some partner companies. In fiscal 2016, information on changes in public expectations was speedily shared, including information on the revised Act on the Protection of Personal Information and the Act against Unjustifiable Premiums and Misleading Representations, which introduced a new scheme of charges. These newsletters are also used in workplace workshops in order to share information on cases within and outside the company.
Bribery and corruption not only harm society's trust in a company, but can also impede economic growth in developing countries themselves and lead to poverty and other problems of international concern. To keep pace with our globalization in accordance with the goals set forth in the Challenge 2020 Vision, we introduced a set of guidelines in April 2015, entitled the Foreign Public Official Anti-Bribery and Corruption Guidelines, that outline the basic policies to be followed in order to ensure that business is pursued in a fair and transparent manner and in accordance with high ethical standards, overseas in the international community as well as in Japan. These guidelines declare that even acts expected to create opportunities for business growth and profit are prohibited if they infringe our basic policies, and Tokyo Gas’s Our Code of Conduct stipulates that “we will conduct our business globally in compliance with the laws and regulations of the countries and regions concerned, human rights norms, and other international standards, and we will act in a manner that is sensitive to other cultures, customers, and stakeholder concerns.” In April 2017, the guidance on crisis management contained in the Japan Federation of Bar Associations’ Guidance on Prevention of Foreign Bribery was added to the guidelines.
Tokyo Gas regularly surveys all employees and subsidiaries (using questionnaires and other methods) to monitor the effects of compliance promotion activities.
As the following figures show, Tokyo Gas and its subsidiaries have maintained high average scores of over 3 (out of a maximum of 4) in every category.
Feedback on the survey results and courses of action in response was provided by the Compliance Promoter Liaison Committee in January 2017 and information was provided individually to subsidiaries between January and March so that the results could be used to improve the activities planned for future years. These survey results are released on the intranet for the perusal of all employees of Tokyo Gas and our subsidiaries.
Compliance Questionnaire Scores for Tokyo Gas (Out of a Possible Maximum of 4)
Compliance Questionnaire Scores for Subsidiaries (Out of a Possible Maximum of 4)