Compliance Risk Management

The JT Group makes utmost efforts to ensure all of our business operations are carried out in an appropriate way and gain a high level of trust and confidence from our stakeholders by reinforcing compliance risk management.

In our Japanese domestic tobacco, pharmaceutical and processed food businesses, every division is required to assess their compliance risks and submit plans to address any risks identified. A compliance survey is carried out each year, and the results of the survey feed into each division's plans for addressing compliance risks.

Anti-bribery and corruption

With operations spanning the world, some of our businesses are conducted in jurisdictions with a high prevalence of bribery and corruption. Our Code of Conduct clearly sets out the "Prohibition of bribery" and forbid corrupt practices in any form. Taking into account legislation such as the Unfair Competition Prevention Act of Japan, U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act, and anti-bribery laws in China, we have introduced the "JT Group Anti-Bribery Policy".
The "JT Group Anti-Bribery Policy" specifically addresses our zero tolerance approach to corruption in our operations and our efforts to prevent corruption in any of our business dealings through education and training, adequate due diligence and reporting systems, etc.
Our management has issued clear messages to the employees that bribery and corruption are unacceptable and the adherence to the "JT Group Anti-Bribery Policy" is vital.

Gifts, hospitality, and entertainment

We do not proactively encourage a culture of exchanging gifts, hospitality, and entertainment (GHE). We believe the purpose of GHE should be to promote healthy business relationships, not to seek preferential treatment, and we comply with all local laws in this area.

As a rule, approval must be sought for all GHE exchanges for any JT Group company including those with government and public officials. In our international tobacco business all GHE exchanges with non-governmental third parties above US$250 must receive prior approval. For government and public officials, all requests, regardless of amount, must be approved.

Anti-competitive behavior

Competition laws and fair competition are covered by our Codes of Conduct, which prohibit employees from discussing business operations with competitors.

In our international tobacco business, for example, if an employee is in a conversation with a competitor and sensitive commercial information is discussed, they must end the conversation, express disagreement with discussing such topics, leave immediately, and report the matter to the legal department.

We provide employees with guidelines on our anti-trust and competition law policy, and all employees in our international tobacco business are required to attend annual training events on anti-competitive behavior.