Our Policy and framework
INPEX is systematically developing a compliance structure—an indispensable requirement for its sustainable development—and strives to ensure compliance with laws and regulations and adherence to corporate ethics. Specifically, we have established the Compliance Committee, which formulates basic policies and plans pertaining to compliance, deliberates significant matters, monitors the effectiveness of compliance-related regulations, and supervises the implementation of compliance programs to promote unified compliance initiatives throughout the INPEX Group. The committee also develops and revises compliance-related rules.
In addition, under the Sustainability Principles,1 we have established the INPEX Group Code of Conduct, which defines the practices to be followed to ensure compliance and thereby supports observance of the Business Principles that guide how we conduct our business.2 We are also working to raise awareness of compliance among our executives and employees. The Business Principles and Code of Conduct were established by respective resolutions of the Compliance Committee and the Board of Directors, and are continuously reviewed in light of changes in the external environment and legislative requirements.
Anti-bribery and Anti-corruption
Anti-bribery and anti-corruption laws and regulations are becoming more and more strict each year. As a global company with projects in about 20 countries around the world, INPEX recognizes the importance of taking a zero-tolerance policy towards bribery and corruption. Accordingly, all executives and employees are required to always act with integrity, which is one of the INPEX Values3 shared across our entire organization.
The Code of Conduct stipulates the building of sound and appropriate relationships with governments and administrative authorities (including prohibition of political donations except in legally permitted cases) and compliance with the anti-bribery and anti-corruption laws and regulations in the countries where we operate. We make no donations relating to political activities.
We have participated in the United Nations Global Compact since December 2011 and have declared our commitment to preventing corruption. Moreover, we established the INPEX Group Global Anti-Bribery and Anti-Corruption (ABC) Policy4 and related rules under our Code of Conduct, and are implementing measures to prevent bribery and corruption.
We have established a system whereby the director in charge of compliance and the Compliance Committee can promptly consider and take actions if a serious compliance-related incident occurs. The director in charge of compliance and the Compliance Committee cooperate with the Audit & Supervisory Board and its members, the accounting auditors, the Audit Unit (our internal audit department), and the equivalent bodies or departments in our subsidiaries to: (1) develop and implement compliance measures; (2) monitor implementation; (3) raise compliance awareness; (4) receive reports on compliance violations and conduct investigations; (5) issue warnings and take other measures in response to violations; and (6) institute measures to prevent the recurrence of violations. In addition, the director in charge of compliance reports to the Board of Directors in relation to the above activities on a regular basis and as required. There were no cases of serious compliance violations in FY2021.
In addition, to ensure coordination between the Committee and INPEX workplaces, we have appointed compliance promotion managers and personnel in every workplace and take action to disseminate and deepen awareness of compliance across the workplace.
We continue to work on the appropriate management of bribery and corruption prevention initiatives, compliance education and the global compliance system, and maintenance and operation of our whistleblower system with undergoing internal audits.
We regularly conduct compliance training for all members of our organization to inform and encourage them to carry out their duties in compliance with laws and regulations. Training covers specific topics—such as prevention of harassment and discrimination—and include sessions targeted at specific employment roles/ranks. The program for FY2021 included harassment prevention training for general employees at operating sites in Japan, and training on anti-bribery/anti-corruption and the Anti-Monopoly Act for operating sites and Group companies in Japan.
We are also adapting and implementing our Code of Conduct at overseas offices in line with local laws and regulations as part of our efforts to strengthen our global compliance structure. Data on trainings held in each country are listed in the ESG Performance Data.5
Compliance assessments and harassment prevention training for managers
In addition to the compliance awareness survey we conduct every three to four years, we carried out compliance assessments in FY2020 and FY2021. The assessment consists of eleven questions in three categories: power harassment, sexual harassment, and communication. We then hold harassment prevention trainings for managers based on the assessment results. Training is conducted through group discussions and other activities, and includes instruction on how to prevent harassment of and interact with staff.
Whistleblower System and Grievance Mechanism
We actively respond to inquiries, complaints and grievances from all stakeholders—internal and external—at our domestic and overseas business locations.
We have set up a Helpline under the Whistleblower System that we established pursuant to Japan’s Whistleblower Protection Act. In June 2020, we also launched the INPEX Global Hotline with local language support, which specializes in three business-critical risk areas: bribery and corruption, violation of antitrust laws (competition laws), and accounting fraud. This hotline is open to all INPEX executives and employees worldwide. The Whistleblower System helpline has internal and external (law firm) contact points, and the INPEX Global Hotline is administered by an external service provider. The Helpline also covers reports on discrimination, human rights violations, harassment and any other misconduct.
Reporting can be completed anonymously, and INPEX is committed to protecting whistleblowers from any negative consequences. In addition, the content of reports from whistleblowers and the results of investigations and responses are promptly reported to the Full-time Audit & Supervisory Board Members to ensure that the Whistleblower System functions more effectively.
During FY2021, five whistleblower reports were made internally, and three to the external contact point. Taking into consideration the advice of attorneys and other experts, the Compliance Committee promptly and appropriately responded to each report in accordance with the Whistleblowing Rules. None of the reports pertained to bribery and corruption, discrimination, or human rights abuses. The number of consultations for each country is stated in the ESG Performance Data.6
We have a dedicated page on our website to manage inquiries and grievances from external stakeholders—including local residents and suppliers—and we respond to their feedback in a timely and appropriate manner.
In Indonesia, in addition to the website, we provide support in the local language. In FY2021, two grievances were filed in Indonesia, and were appropriately addressed in line with the established procedure.
In Australia, a procedure has been established for community engagement and grievance management to appropriately address inquiries and grievances received from local communities.7 In FY2021, no grievances were reported in Australia to which the procedure applies.
Anti-bribery and Anti-corruption (ABC) Initiatives
Our ABC Guidelines went into effect in October 2014 with the approval of the Compliance Committee. In FY2017, we revised those guidelines to establish our ABC Policy and formulated our ABC Procedures.
The INPEX Group Global Anti-bribery and Anti-corruption (ABC) Policy was established in April 2019 as a clear and comprehensive statement of our stance on ABC. The policy is disclosed on the Company’s website.
In line with our policy and procedures, we require pre-approval of giving or receiving gift and entertainment, and we properly conduct the necessary due diligence regarding ABC risks of potential business partners. In FY2021, 57 cases of due diligence were performed in Japan, based on the risk level of each prospective partner.
We have conducted ABC risk assessments at our headquarters and overseas offices since FY2015, and have taken measures based on the results to further enhance the design and operation of ABC compliance systems. In FY2020, we conducted risk assessments at our domestic offices. In FY2021, we added ABC training to our ongoing compliance training for new graduates and mid-career employees, and conducted ABC trainings at our domestic offices and Group companies.
Our head office regularly shares information and exchanges views on compliance activities with our major overseas offices in Perth and Jakarta to further improve our global ABC compliance system. In addition, a global compliance meeting—inaugurated in FY2020—was held again in FY2021. Compliance promotion officers from headquarters and overseas offices in nine countries met to exchange opinions on ABC issues and initiatives.
In FY2021, there were no major violations or disciplinary actions related to ABC.
Heightening Transparency through EITI Participation
Since October 2012, INPEX has been participating in and supporting activities of the EITI.8 This multinational initiative aims to improve the transparency and sound management of the flow of funds from extractive industries to the governments of resource-producing countries. As of December 31, 2021, 56 implementing countries, many supporting countries (including Japan), companies in extractive industries, and nongovernmental organizations were participating in the EITI. We provide the EITI with data concerning the participating countries where we operate projects.
8 Extractive Industries Transparency Initiative