Our Codes of Conduct form the foundation of our business ethics. Reflecting our commitment to the 4S model, they outline our responsibilities towards our consumers, our shareholders, our employees, and the wider society. Our Reporting Concerns Mechanism allows employees and business partners to report concerns in a confidential manner. We take a zero-tolerance approach to bribery, corruption, and other financial crime, and we actively manage risks related to these areas.
We train employees on the Codes, and there are communication channels for employees to report concerns about potential breaches or violations.
Besides the JT Group Code of Conduct, our tobacco business* and Torii Pharmaceutical have developed their own versions of the Code of Conduct to reflect the needs of their operations.
Our Codes of Conduct guide us to conduct business ethically and be a responsible corporate citizen. To ensure that the codes are communicated effectively throughout the entire business, we run various training courses for employees.
Our employees sign an acknowledgment form to show their commitment to following our Codes of Conduct. In the bi-annual performance appraisal of employees in JT, confirmation of compliance with our Codes of Conduct is integrated in the process.
Our Codes of Conduct are reviewed every few years and revised when necessary, considering the environment in which we operate. We revised and updated the Codes of Conduct in 2012, 2015, and 2018, respectively. In 2021, we reviewed the whole contents and evaluated the necessity of update. As a result, after consulting with relevant divisions, we thought the Codes of Conduct were sufficient at that timing. Therefore, we decided to keep the contents. In the future, we will continue to review our Codes of Conduct periodically and revise when necessary. In our tobacco business*, JTI Code of Conduct has been digitalized into an accessible, easy-to-read document, including a decision-making guide to assist employees in making the right choices. It is available in 42 languages.
*Tobacco business excluding Japan market
Training and communication
We continued to provide training on the Codes of Conduct to our employees in 2022. We provide training programs to all employees, regardless of their employment status (e.g. directly or indirectly employed, full or part time).
In our Japanese operations, 99.9% of employees completed the online courses.
To ensure that JTI Code of Conduct is communicated effectively throughout the entire tobacco business*, we run various communication campaigns, initiatives and training courses for all employees. We also use an interactive Code of Conduct video in multiple languages to guide our employees to make the right choices.
*Tobacco business excluding Japan market
Compliance survey in Japan
In order to better implement compliance in our workplace, each department in our Japanese operations makes Compliance Action Plans. These Action Plans are rolled out on a yearly basis, which means that we base the plans on the results of the compliance survey and the status of our initiatives in the previous year.
We conduct a compliance survey every year. In 2022, 94.1% of employees completed the survey. The survey outcomes are analyzed by the JT Legal and Compliance division, and reported to the head of each department while ensuring confidentiality. Next, the JT Legal and Compliance division develops an Annual Compliance Action Plan based on the results of the analysis. The relevant departments then introduce a remediation plan to address any issues raised, using quantitative targets to evaluate the effectiveness of the plan.
Based on the survey results and compliance-related matters in 2022, we set preventing harassment* and improving health and safety awareness as Company priority issues in 2023. We will provide training programs including about these issues in the Compliance Promotion Month in June and strengthen and implement necessary measures with related departments.
* Harassment includes sexual harassment and bullying.
Reporting concerns
Across the JT Group, each of our operating companies has specially trained members who handle compliance matters. If an employee is concerned about a potential violation of our Code of Conduct, they can contact their line manager, their HR lead, or a member of the compliance team. We also provide an external concern-reporting service, run by an independent provider and available 24/7. In addition, the Audit & Supervisory Board members in our Japanese operations have established a consultation and reporting contact independent of business operations. Every reported concern and investigation report is treated on a strictly confidential basis, and retaliation against anyone reporting a concern will not be tolerated. Employees can file a report anonymously if they prefer. Our approach is explicitly described in our internal policy and employee handbook so that our employees can be aware of their rights and free from fear.
* In our Japanese operations, we distribute a Reporting Concerns Booklet to all employees with detailed information about the process for reporting concerns.
We believe that everyone should be able to raise concerns and have their voice heard, even if they do not have access to a company computer and/or the company network. That’s why we ensure secure access to reporting system for all of our employees, at all times and from anywhere.
We offer multiple communication channels for employees, customers, and business partners to confidentially raise concerns about potential violations of our Codes of Conduct or policies. We review all concerns raised, launch investigations as needed, and take appropriate corrective actions.
Employees are informed about our Reporting Concerns Mechanism through various channels, including the JT Group intranet. In our Japanese operations, the Mechanism is available in four languages (Japanese, English, Vietnamese, and Nepalese) to meet the needs of our diverse workforce.
Any concerns are then dealt with by specially trained contact persons, who all follow a mandatory training course.
In our tobacco business*, we are committed to achieving and maintaining the highest standards of ethical behavior and acting responsibly in all we do. JTI Reporting Concerns Mechanism, called “Your Voice”, helps meet these standards by allowing employees and business partners to confidentially report behavior related to our business, which they believe is in breach of JTI Code of Conduct, JTI policies and procedures, or applicable laws.
We believe that everyone should be able to raise concerns in relation to our business and have their voice heard. We ensure secured access to the Your Voice for all of our employees and business partners, either via a portal run by an independent provider, accessible 24/7 in more than 70 countries and 50 languages with a computer or phone, or via a dedicated email address.
Every reported concern and investigation report is treated confidentially. All substantiated instances of misconduct are addressed appropriately, and retaliation against anyone reporting a concern is not tolerated.
Examples of the types of issues that can be reported through our Reporting Concerns Mechanism are: human rights concerns, fraud, theft, corruption, money laundering, illicit trade, discrimination, moral and sexual harassment, or other forms of inappropriate behavior.
In 2022, we received 631 reports across the JT Group. In the case of proven violations of our Codes of Conduct, we took remediation action towards 361 cases in total in the form of dismissal, verbal or written warnings, financial penalties, or other measures. For instance, we took remediation actions towards 169 cases concerning fraud and misuse of company assets and 88 cases concerning labor practices (excluding human rights). More specifically, we took remediation actions towards 2 cases concerning corruption, 1 case concerning data privacy violation, 8 cases concerning conflict of interest, 1 case concerning discrimination. Regarding money laundering or insider trading, there was no substantiated cases thus no remediation actions were taken.
