We make every effort to ensure that all of our business operations are carried out in an appropriate way, and that we focus on compliance risk management to maintain our stakeholders’ trust.
In our Japanese domestic tobacco, pharmaceutical, and processed food businesses, every division is required to assess their compliance risks and submit action plans to address any risks identified. A compliance survey is conducted every year and each organization incorporates the results into their action plan.
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 Codes of Conduct clearly prohibit bribery and forbid corrupt practices in any form. Taking into account legislation such as the Unfair Competition Prevention Act of Japan, the 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.
We take a zero-tolerance approach to corruption and bribery, and all executives and employees must respect and comply with our JT Group Anti-Bribery and Corruption Policy. The training courses help us to reinforce this policy. In our Japanese operations, we run an e-learning course on anti-bribery and corruption every two years. In 2019, 2,419 employees took this course.
In our international tobacco business, in 2019, 4,607 employees completed the anti-bribery and corruption online training. We also provide face-to-face trainings locally for employees without computer access as a part of the general Code of Conduct trainings that includes an anti-bribery and corruption section. In 2019, 5,128 employees attended this training.
The JT Group Code of Conduct
JTI Code of Conduct
The JT Group Anti-Bribery Policy
Gifts, hospitality, and entertainment
Our internal policies and procedures help to prevent bribery and to ensure an appropriate level of exchange of gifts, hospitality, and entertainment, which must be transparent and reasonable, and must respect local regulations. We therefore require all employees in our Japanese operations to seek approval for anything they receive or wish to give. To ensure that compliance is well-embedded within the organization, we conduct regular training and run communications campaigns across the Group.
All exchanges with non-governmental third parties above 250 U.S. dollars in our international tobacco business must be approved. For government and public officials, all requests, regardless of the amount, have to be approved. The number of gifts, hospitality, and entertainment requests sent for approval in 2019 was 632, vs. 603 in 2018.
Fair competition compliance with competition laws is covered by our Codes of Conduct, which require employees to compete fairly in all markets.
Our international tobacco business has a policy with detailed guidelines in place to ensure that business operations are conducted fairly and in compliance with competition laws, wherever we do business. The policy provides guidance for employees on how to conduct business in a compliant and ethical manner. For example, all activities and strategic decisions must be carried out independently of our competitors.
Our customers must be free to make their own business decisions concerning their customers and how they compete in the market. Employees in our international tobacco business are required to attend regular training on compliance with competition laws and the JTI policy.
Preventing financial crime
The JT Group does not tolerate any form of financial crime. In our international tobacco business, we abide by the EU Cooperation Agreement obligations, and take into account the U.K. Criminal Finances Act 2017. We perform policy controls and provide program training, and we publish employee communications on the subject.
The global policy sets out principles and guidelines to prevent employees from being involved in any form of financial crime, including money laundering, tax evasion, and facilitating tax evasion.
The JT Group Tax Policy outlines our approach to tax compliance, tax risk management, the utilization of external tax advisors, and our relationship with tax authorities.