Initiatives Towards Promoting Compliance

Compliance Structure

INPEX has systematically established a compliance system that is indispensable for its sustainable development and strives to ensure compliance with laws and regulations and corporate ethics. Specifically, we have established the Compliance Committee, which deliberates important matters, such as basic policies and activity plans pertaining to compliance, and monitors the activities, including raising awareness of compliance and measures to prevent the recurrence of violations, to promote consistent compliance efforts across the entire INPEX Group.

A system has been established in which the Director in charge of compliance and the Compliance Committee promptly consider and implement the necessary countermeasures in the event of serious compliance-related incidents. The Director in charge of compliance and the Compliance Committee cooperate with the Audit & Supervisory Board and its members, the accounting auditor, and the Audit Unit, as well as with the equivalent bodies and departments at subsidiaries. The Director in charge of compliance makes regular and timely reports to the Board of Directors.

There were no confirmed cases of significant compliance violations in FY2024.

We are also working to expand and strengthen compliance activities throughout the workplace by holding semi-annual meetings between compliance promotion staff assigned to each department and the department in charge of compliance.

Compliance Structure

As ongoing initiatives to enhance cooperation with compliance across the Group, we also regularly share information and exchange views on compliance activities with our overseas sites, including subsidiaries in Perth, Jakarta, Oslo and others, and provide support for compliance training at our subsidiaries in Japan.

Establishment of the Business Principles and Code of Conduct

In line with the Sustainability Principles, we have established the Business Principles that must be observed by all officers and employees without exception in the performance of their duties, as well as the Code of Conduct for implementing these Principles. Furthermore, the Audit Unit checks the status of compliance with the Code of Conduct in its annual assessment of internal controls, and the status of mechanisms and structures for timely and appropriate corrective action in the event of non-compliant behavior being discovered. If behavior that does not comply with the Code of Conduct is discovered in internal audits, the Audit Unit issues improvement instructions and each responsible division or subsidiary implements the necessary measures.

Establishment of Whistle-blowing System

We operate whistle-blowing systems in accordance with the 2022 revision of the Whistleblower Protection Act to accept reports and consultations from officers and employees of the INPEX Group. In the systems, we have a helpline for receiving reports and consultations, and the INPEX Global Hotline for receiving reports and consultations in three areas where the effect of compliance violations on management are particularly significant. The three areas are bribery and corruption, violation of the Antimonopoly Act, and accounting fraud. The use of the systems is introduced in employee training and newsletters. The helpline has internal and external (law firm) desks, while the INPEX Global Hotline is operated by an external service provider. Reports and consultations can be made anonymously through each of them.

Response to Whistle-blower Reports

Whistle-blowing structure

In accordance with the whistle-blowing rules, the Compliance Unit, which serves as the internal whistle-blowing desk, and the external law firm, which serves as the external whistle-blowing desk, notify whistle-blowers within 20 days from receiving a report of its intention to start a factual investigation or its intention, on justifiable grounds, not to start such an investigation. On the investigation, details of reports are kept confidential, and the whistle-blower shall not be treated disadvantageously. The Director in charge of compliance cooperates with relevant departments, as necessary, to conduct investigations. If harassment or other compliance violations are identified, corrective action, including disciplinary action as stipulated in rules of employment, and recurrence prevention measures, including training and internal notice are taken. In addition, the details of reports are promptly reported to the Audit & Supervisory Board Members, and the results of factual investigations/details of measures are also reported to them in a timely manner, to ensure the whistle-blowing system functions more effectively.

During FY2024, the whistle-blowing desks received nine internal and three external whistle-blowing reports and consultations. Of these, one was related to suspected accounting fraud, eight were related to suspected human rights, discrimination, and harassment violations, one was related to employment, and two were related to other matters. There were no compliance violations among the reported cases that were subject to disciplinary action as stipulated in the Code of Conduct. The number of reports and 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. As a global company operating in approximately 20 countries worldwide, we recognize the importance of a zero-tolerance policy towards bribery and corruption. Accordingly, all officers and employees are required to always act with high ethical standards based on integrity, which is one of the INPEX Values shared across the Group. These values are also integrated as a component of the competency framework used for assessing work behavior in our human resource 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 structure, we have ABC policies and procedures as part of our internal regulations. We established the INPEX Group Global Anti-bribery and Anti-corruption (ABC) Policy in FY2019 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, we have established rules on giving and receiving gifts or entertainment, as well as social contributions such as donations. We conduct appropriate and necessary due diligence, based on how high ABC risks are, when engaging in transactions with new business partners, contractors and agents, and include ABC clauses in each contract. In FY2024, 140 cases of due diligence were conducted in Japan.

Since FY2015, we have been working to strengthen our ABC system, rooted in a risk-based approach. This involves regularly conducting risk assessments in Japan and overseas and implementing improvement measures based on the results of those assessments. In FY2024, we conducted risk assessments at the Abu Dhabi Projects Division (now the Europe & Middle East Projects Division) and seven subsidiaries in Japan, and at four subsidiaries conducting business in Abu Dhabi. No significant violations or risks related to ABC were identified at any of these locations.

Enhancement of Transparency Through Participation in EITI

Since FY2012, we have been participating in and supporting the efforts of the Extractive Industries Transparency Initiative (EITI). 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 March 2025, 55 resource-producing countries and 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.

Promotion of Compliance Training

We regularly conduct training by business theme, including the prevention of harassment and discrimination, by job level. These sessions use examples of past incidents within the Group to strengthen employees’ compliance awareness and encourage the practice of compliance in their daily work. The table below shows our main training programs in FY2024. Data on training held in each country is also outlined in the Performance Data.