The Management Ethics Committee, chaired by the president, meets twice a year, in principle during March and October, to formulate Company-wide policy and confirm and discuss matters, such as the handling of inquiries and consultation by the consultation desks and the results of the monitoring of compliance awareness among employees.
We have also established Compliance Committees in each unit to consistently and proactively engage in initiatives for promoting compliance.
Over 300 management-level personnel have been appointed as compliance managers and compliance promoters at each workplace to lead in promoting 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 2017, with 280 participants).
Compliance Promotion Structure
Consultation DesksTokyo Gas has set up consultation desks internally through its Compliance Department and externally through a law firm and communication support center. All individuals working at the Tokyo Gas Group, including officers, regular and temporary staff members as well as the employees of our suppliers can directly contact these desks by phone or email whenever they feel uncomfortable raising a matter within their organization. The Compliance Department also handles consultation for our suppliers. These consultation systems for employees and suppliers serve as internal points of contact, as stipulated in the Whistleblower Protection Act.
|Consultation Topics||Number of Cases|
|Interpersonal relations and employment matters||35|
|Laws and regulations||4|
|Communication and other issues||58|
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 (28,726 employees participated in fiscal 2017). These workshops feature 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, the resources are used to improve participant understanding of the laws, ordinances and regulations governing the practice of Our Code of Conduct and to help them apply the code in practice.
Instilling a Compliance-oriented Mindset through TrainingLevel-specific training for new employees and others is provided with the active participation of subsidiaries and LIFEVAL employees to foster a compliance mindset (1,527 employees underwent training in fiscal 2017).
Strict Compliance with the Antimonopoly Act, the Act against Unjustifiable Premiums and Misleading Representations and the Subcontract Proceeds Act
Training is provided annually to the Tokyo Gas Group employees to improve understanding of legal compliance.
In fiscal 2017, around 600 Group employees took part in 9 training sessions on the Antimonopoly Act, the Act against Unjustifiable Premiums and Misleading Representations, and the Subcontract Proceeds Act. During the sessions, concrete instances of legal violations released by the Fair Trade Commission and Consumer Agency*were explained as practical case studies.
*Case studies include examples of cartels and abuses of superior bargaining position (Antimonopoly Act), and misleading representation (Act against Unjustifiable Premiums and Misleading Representations).
Training session on the Antimonopoly Act
Training session provided to managers and staff related to misleading representation
Sharing Information on Compliance
We are working to raise the standard of compliance by widely publicizing across the Tokyo Gas Group up-to-date information on the compliance risks associated with changes in the Group’s business environment, including those associated with our evolution as a total energy business, acceleration of our global business development, and the revision and stricter enforcement of prevailing legislation.
One way in which we share this information is by publishing the bimonthly newsletter “Compliance Information” as a resource for compliance managers and promoters who lead activities at the Company, subsidiaries, LIFEVAL companies and some partner companies. In fiscal 2017, information on changes in public expectations was quickly shared, including information on compliance check points for the revised Act on the Protection of Personal Information and information on the revised Consumer Contract Act enforced in June 2017. These newsletters are also used in workplace workshops to share information on cases within and outside the Company.
Support for Tokyo Gas Group Compliance PromotionTokyo Gas promotes compliance by LIFEVAL and other partner companies, which provide regional services on behalf of Tokyo Gas. We conduct onsite training and provide educational tools tailored to the current status of each company and assist in encouraging the adoption of PDCA cycles.
Basic PoliciesThe Tokyo Gas Group is fully committed to preventing bribery and corruption in all domestic and international transactions by complying with the anti-bribery and corruption laws in each country and region and specifying in Tokyo Gas Group Our Code of Conduct our obligations to comply with laws and be fair and honest with our customers and suppliers.
Outline of the Foreign Public Official Anti-Bribery and Corruption Guidelines
Effective Application of the Guidelines to Prevent Bribery and CorruptionThe Tokyo Gas Group provides training to employees primarily involved in business overseas to ensure proper compliance with the guidelines. In fiscal 2017, 344 personnel received this training. We have produced an English version of the guidelines for locally hired employees and have distributed the English edition of Tokyo Gas Group Our Code of Conduct to ensure that everyone understands its content. We have also established a system to enable Group employees working overseas to report and seek advice. We implement PDCA cycles to ensure that bribery and corruption are being prevented by monitoring the situation through internal audits and other means to confirm that the procedures established by the guidelines are being followed.
Compliance Awareness Surveys
We regularly conduct surveys of all employees, including officers, regular and temporary employees at the Company and subsidiaries, to monitor the effectiveness of compliance promotion activities.
In fiscal 2017, we made the contents of our survey more specific by increasing the number of survey items related to reporting, contact and consultations in the event of problems. In addition to all employees of the Company and subsidiaries, we distributed the survey to those at Tokyo Gas LIFEVAL (“LIFEVAL”) companies to which we outsource various tasks.
As the following figures show, Tokyo Gas, its subsidiaries and LIFEVAL companies have maintained high average scores of over 3 out of a maximum of 4 in every category.
As a reference for future improvement, general feedback on the survey results and corresponding actions to be taken was provided by the Compliance Promoter Liaison Committee in January 2018 and individual feedback on survey results was provided to each company between February and March of the same year. These survey results are posted on the intranet for review by all employees of Tokyo Gas, our subsidiaries and LIFEVAL companies.
Compliance AuditingThe Internal Audit Department regularly conducts audits of Tokyo Gas and its subsidiaries and affiliates focusing on the severity of risks and the probability of their materialization from the perspective of legislation related to the audited unit’s operations, as well as corporate ethics and social norms.