The Management Ethics Committee, chaired by the president, meets twice a year, in principle during March and November, 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.
■Compliance Promotion Structure
Consultation DesksThe Tokyo Gas Group 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 serve as internal points of contact, as stipulated in the Whistleblower Protection Act.
■Number of Cases Handled by Consultation Desks (FY2018)
|Consultation Topics||Number of Cases|
|Interpersonal relations and harassment||51|
|Compensation, working hours, and related issues||20|
|Laws and regulations, and other issues||16|
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 (32,796 employees participated in fiscal 2018). 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 (1,291 employees underwent training in fiscal 2018).
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 2018, around 900 Group employees took part in 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*1 were explained as practical case studies.
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 organization’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.
Specifically, information is shared through the regularly published “Compliance Information” newsletter, a resource for compliance managers and promoters who lead activities at the Company, subsidiaries, LIFEVAL companies, and some partner companies. Contemporary issues are shared quickly to keep people abreast of changes in society, such as information about the enforcement of regulations concerning work style reform, which was featured in the publication in fiscal 2018. The newsletter is also used in workplace workshops to share details about cases in and outside the Company.
Support for Tokyo Gas Group Compliance PromotionTokyo Gas promotes compliance by LIFEVAL and partner companies providing regional services on behalf of Tokyo Gas. We also make educational tools available that are tailored to the circumstances of each company and assist in implementing PDCA cycles.
Basic PoliciesThe 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 2018, 371 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 of Tokyo Gas and its subsidiaries to monitor the effectiveness of compliance promotion activities.
In fiscal 2018, we sought responses from employees at Tokyo Gas, its subsidiaries, and LIFEVAL companies with a focus on the following points.
The results showed that Tokyo Gas, its subsidiaries, and LIFEVAL companies have maintained high average scores, generally above 3 out of a maximum of 4 in every category.
As a reference for future improvement, we offered feedback on common tendencies and, where necessary, individual corporate tendencies with respect to the survey results and corresponding actions to be taken. The results are posted on the intranet for review by all employees of Tokyo Gas, its subsidiaries, and LIFEVAL companies.
Overview of the FY2018 Compliance Survey Results
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.