Compliance

Basic Policies

Compliance helps form the foundation for corporate activities.
The following conduct is specified in the Basic Code of Conduct for IHI’s group companies.

  • Observing strictly all laws, company rules and other regulations
  • Acting in a fair and responsible manner as businesspeople

This supports not only legal compliance but also efforts to accurately assess changing social values and demands, a necessary step in meeting society’s expectations.

Basic Code of Conduct Guidelines

Basic Code of Conduct Guidelines

System for Implementing Compliance Activities

Compliance Committee

The Compliance Committee reviews and plans important compliance policies and oversees compliance activities.
The committee meets four times a year. It comprises the Chief Compliance Officer as the chairperson and Divisional Compliance Officers who serve as managers responsible for implementing policies. In response to decisions made at committee meetings, each compliance officer engages in compliance activities suited to the business of that officer’s division. Each compliance officer also shares information about the compliance activities in their divisions with the Compliance Committee. Activities are managed with the PDCA cycle.

Compliance Activity Promotion

The Corporate Social Responsibility Division, acting in accordance with policies set by the Compliance Committee, plans and implements activities and provides related guidance and support, as well as monitors the status of activities within each division.

Compliance Activity Promotion

As of April 1, 2017

Compliance Hotline

IHI established a Compliance Hotline as an internal whistleblowing system to facilitate reporting of possible illegal, unethical or improper conduct by officers or employees of any IHI company and to prompt corporate responses to remedy any such action. Officers and employees can directly report and consult to Corporate Ethics Hotline, an independent third-party organization without going through an ordinary reporting line. Hotline Cards explaining the system and how to use it are distributed to all officers and employees, from senior managers to temporary staffers.
The Hotline received 218 calls in FY2016, of which 98 resulted in investigations. A higher number of calls were about interpersonal relations in the workplace than consultations relating to rule violations, etc.

Compliance Hotline

Compliance Hotline reports

As of March 31, 2017

Promoting Compliance Awareness

Compliance Activities

IHI conducts multifaceted training and education to improve compliance awareness. Creative approaches help to ensure that the activities are highly effective and carefully tailored to each target audience.

■e-Learning
Compliance education is provided to employees in the form of e-learning focused on set themes. For the FY2016 theme, “preventing data falsification,” education was provided to IHI companies worldwide.

■Officer Training
All IHI officers participate in compliance training. In FY2016, an external lecturer provided training on “The roles of management executives in preventing and responding to scandals.”

■Training for Line Management
Outside guest speakers are retained to deliver compliance training to line managers who guide personnel in daily operations. The program has trained about 740 persons since 2006.
In 2016, the goals of the program were established as:
(1)Properly understand the keys to avoiding compliance violations;
(2)Recognize the importance of creating workplaces where self-esteem is high, and;
(3)Uphold management principles.
The training covered characteristics of workplaces in which compliance violations are likely to occur and considering the points of preventing compliance violations from the perspective of case studies and self-esteem to learn about the importance of workplace culture.

Compliance training results

PositionParticipants
IHI Corporation executives28
IHI group executives27
Managers at IHI Corporation and group companies40
Line managers73

Corporate Ethics Month

October is designated by the Japan Business Federation (Keidanren) as the month for improving corporate ethics. In October 2016, IHI's president and CEO responded to the federation's initiative by sending the following message to officers and employees: “In our pursuit of sustainable growth and enhanced corporate value, it is essential that we gain the trust of society through ethical conduct. I ask all those in positions of responsibility within the organization to lead by example and directly evaluate how people are doing and how work is progressing in their teams, and then implement any necessary measures regarding corporate ethics and compliance.”

Compliance Poetry Contest

To encourage employees to reflect on actions in their workplace, including one's own actions, we invited them to submit senryu, a satirical style of Japanese poetry, on the topics of compliance and CSR. More than 200 senryus were submitted, the best of which were showcased in internal publications.

Plans for FY2017

IHI’s compliance activity policy for 2017 asks every employee to take note of certain fundamental concepts when engaging in compliance activities:
(1)Society is constantly changing. While taking that into consideration, practice the following from the viewpoint of society:
    ・observe rules
    ・be honest
(2)It is people that create an organization. Respect each other to promote good communication, and build positive working environments that allow anyone to promptly discuss any concerns.
(3)Managers’ awareness and behavior greatly impact the workplace. They shall be good role models for subordinates, show healthy attitudes, and lead to resolve problems promptly.
Each organization identifies potential issues and develops action plans in accordance with changes in the business environment. Thereafter, they ensure that action plans are carried out, monitor achievement, and make evaluations. Further improvement measures are studied, and the PDCA Cycle is repeated.
IHI also continues to enhance its overseas internal whistleblowing system for stronger global business management.

Compliance Initiatives

With increasing globalization and borderless implications of corporate actions, fair international competition in terms of price and quality has become increasing necessary to secure commercial opportunities. There is a growing international awareness that corrupt acts such as illegal payoffs must be stamped out.
Against a backdrop of regional conflicts and terrorist attacks around the globe, export controls have never been more important. In response to this environment, IHI has focused on compliance with competition law, anti-corruption law and the IHI's own compliance measures for export control.

Competition Law Compliance

In addition to training employees on Japan's Antimonopoly Act, the U.S. Sherman Antitrust Act and the EU Competition Law, IHI is working to make its bidding process for public works projects more transparent.
No fair trade law violation occurred during FY2016.

Anti-corruption Law Compliance

IHI regularly trains its employees regarding of the U.S. Foreign Corrupt Practices Act (FCPA), the U.K. 2010 Bribery Act and Japan's Unfair Competition Prevention Act. In addition, risk is monitored at both domestic and overseas sales offices throughout the IHI. Currently, IHI implements two sets of internal regulations concerning anti-corruption: a Basic Policy that reflects IHI's commitment to prevent corruption, and Operational Guidelines that set out specific procedures and concrete examples.
No anti-corruption law violation occurred during FY2016.

Export Control Compliance

To manage export control, IHI has internal regulations and an Export Control Committee to ensure compliance with Japan’s Foreign Exchange and Foreign Trade Act and related risk-management requirements.
The committee is comprised of a chairman (representative director), secretariat (Legal Division), members (people in roles of responsibility selected from each division, business area and SBU), and examiners. In the case of international transactions, the committee is responsible for internal screening, self-audits, monitoring, information sharing and raising awareness of related regulations.
Going forward, IHI will continue to improve its quality management by addressing needs and challenges identified through self-auditing.

Export Control Compliance

Topics in 2016

In 2016, IHI began full-fledged efforts at overseas bases to roll out training and awareness-raising activities concerning compliance with competition law and prevention of bribery, including the organization of training sessions for affiliates in the U.S. and Thailand.

Plans in FY2017

IHI will continue providing education to ensure that employees comply with all laws and rules related to competition, anti-bribery and export controls.

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