Initiatives towards Promoting Compliance

Compliance Structure

The officer in charge of compliance and the Compliance Committee cooperate with the Audit & Supervisory Board and its members, the accounting auditor, the Audit Unit (our internal audit department), subsidiaries, and other equivalent bodies or departments. This team develops and implements compliance measures, monitors implementation, and responds to compliance violations (such as investigating, taking corrective action, and preventing reoccurrences). The officer in charge of compliance reports to the Board of Directors in relation to the above activities periodically or as required. Our Business Principles and employee work regulations stipulate the necessary corrective actions to address a compliance violation, which may involve disciplinary actions. There were no confirmed cases of serious compliance violations in FY2023.

To ensure coordination between the Committee and the site, compliance promotion personnel and managers are assigned to each workplace. The General Administration Unit, which serves as the secretariat of the Compliance Committee, regularly holds liaison meetings with compliance promotion personnel to further enhance and solidify their understanding and awareness of compliance. We also carry out anti-bribery and anti-corruption measures, provide compliance education and training, enhance Group compliance coordination, continuously improve our whistleblower system, and implement measures related to our operating status. We conduct internal auditing throughout all compliance processes to ensure appropriate implementation.

Compliance Structure

Development and Operation of Whistleblower System

Internally, we operate a whistleblower system in accordance with the Whistleblower Protection Act. We have set up a helpline for receiving all reports related to discrimination, human rights, and harassment. We have also launched the INPEX Global Hotline with support in roughly 20 languages, which specializes in three business-critical risk areas: bribery and corruption, violation of antitrust laws (competition laws), and accounting fraud. The helpline has internal and external (law firm) contact points, while the INPEX Global Hotline is wholly administered by an external service provider. Reporting can be completed anonymously. Both digital and analogue methods, such as email and telephone, can serve as reporting tools.

Response to Whistleblowing Reports

Whistleblowing Structure

In accordance with the Whistleblowing Rules, the General Administration Unit, which serves as the internal whistleblowing contact point, and the external law firm inform whistleblowers within 20 days of receiving a report either that they will begin a fact-finding investigation or if they will refrain with due cause from investigating the claim. We are committed to protecting whistleblowers from any negative consequences. The officer in charge of compliance collaborates with other divisions, as necessary, to conduct an investigation, take corrective actions, and implement reoccurrence prevention measures.

Whistleblower reports, including the results of investigations and responses, are promptly communicated to the full-time Audit & Supervisory Board Members to enhance the efficiency of the whistleblower system.

We have recently amended some internal regulations in line with the June 2022 revision of the Whistleblower Protection Act. This included adding former employees within one year of their departure from the Company to the list of eligible whistleblower system users, which was previously only available to current officers and employees of our offices in Japan and overseas. We also added provisions for appointing personnel able to respond to whistleblower reports and invited external experts to conduct training for these individuals.

During FY2023, we received seven internal whistleblower reports and four external reports. Of these: eight reports related to suspected human rights, discrimination, and harassment violations; two related to employment; and one related to another matter. As of December 31, 2023, one of the reports—relating to suspected human rights, discrimination, and harassment violations—remained under investigation. There were no compliance violations among the reported cases subject to disciplinary action, as stipulated in the Code of Conduct. The number of consultations for each country is stated in the Performance Data.

Anti-bribery and Anti-corruption Initiatives

Anti-bribery and anti-corruption (ABC) laws and regulations are becoming increasingly stringent each year. As a global company operating in approximately 20 countries worldwide, we recognize the importance of taking a zero-tolerance policy towards bribery and corruption. Accordingly, all officers and employees are required to always act with integrity, which is one of the INPEX Values shared across the Group. These values are integrated as a fundamental component of the competency framework used for assessing work behavior in our human resources evaluations.

In addition to requiring compliance with the ABC laws and regulations in the countries where we operate, the Business Principles and Code of Conduct stipulate the establishment of sound and appropriate relationships with governments and administrative authorities. They also prohibit political donations and facilitation payments, except where legally permitted. We have participated in the United Nations Global Compact since FY2011 and have declared our commitment to preventing corruption.

To strengthen our ABC compliance, we developed ABC policies and procedure guidelines as part of our internal regulations. In FY2019, we established the INPEX Group Global Anti-Bribery and Anti-Corruption (ABC) Policy as a clear and comprehensive statement of our position on ABC. The policy is disclosed on our website.

In line with these policies and procedures, preapproval is required for the giving or receiving of gifts or entertainment. We conduct thorough and necessary due diligence based on the ABC risks associated with potential business partners. In FY2023, 124 cases of due diligence were performed in Japan.

Since FY2015, we have been working to enhance the development and operation of our ABC structure, rooted in a risk-based approach. This involves conducting risk assessments of our head office and overseas offices in stages and implementing improvement measures based on the results of these assessments. In FY2023, we conducted risk assessments and ABC training at our head office-based Europe & Middle East Projects Division, at our Oslo and London offices. We also added ABC training to our ongoing compliance training for new graduates and mid-career employees.

As an ongoing initiative to improve our global ABC compliance structure, we consistently share information and exchange views on compliance activities with our overseas offices in Perth, Jakarta, and Oslo.

In FY2023, there were no major violations or disciplinary actions related to ABC.

Promotion of Training on Compliance and Human Rights

We regularly conduct compliance training for all employees to strengthen their compliance awareness and practice compliance with laws and regulations in their day-to-day work. This training covers specific topics, such as prevention of harassment and discrimination, and involves sessions targeted at specific employment roles/tiers. In FY2023, we conducted compliance training for officers focusing on topics such as preventing corporate fraud and scandals.

We have also adapted and implemented our Code of Conduct at overseas offices in line with local laws, regulations, and culture, to strengthen our global compliance structure. Data on training held in each country are outlined in the Performance Data.

Compliance Awareness Surveys and Harassment Prevention Training for Managers

In addition to a short annual compliance assessment, we conduct compliance awareness surveys for all employees every three to four years. The surveys consist of approximately 80 questions on subjects such as harassment and other compliance violations, organizational culture, and the level of awareness of measures. Based on the assessment results, we then provide harassment prevention training for managers which includes instruction on how to prevent harassment of and between staff.