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 the JT Group Anti-Bribery and Corruption Policy. Our training courses help us to reinforce this policy. We run an e-learning course on anti-bribery and corruption every two years. The next one will take place in 2021.
In our international tobacco business, employees in our acquisitions are trained in the first 12 months. Anti-bribery and corruption are also covered in the training we provide locally for employees as a part of our general Code of Conduct 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 communication campaigns across the JT Group.
In our international tobacco business, where possible, we require all employees to obtain approval for the Gift, Hospitality and Entertainment policy before offering or accepting any GHE. To ensure compliance with every relevant laws and regulations, and to prevent bribery or a conflict of interest, all exchanges with non-governmental third parties above 250 U.S. dollars 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 2020 was 268, vs. 632 in 2019.
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 our policy.
Preventing financial crime
The JT Group does not tolerate any form of financial crime. In our international tobacco business, we perform policy controls and provide program training to our employees. We also publish communications on the subject regularly. 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. Read more on Tax practices.