Commitment to Competition Law Compliance and Anti-corruption

The IHI Group has established the Basic Code of Conduct to be followed by all the officers and the employees of all the Group companies. The management, including the President, takes the lead in promoting compliance with all laws, including competition and anti-corruption laws.
By acting in accordance with this Code of Conduct, the IHI Group thoroughly prohibits bribery of all persons, including government officials.

IHI Group Competition Law Compliance Policy

In order to comply with competition laws, the IHI Group has established the IHI Group Competition Law Compliance Policy, that embodies the IHI Group Code of Action, and is continuously working to prevent anti-competitive behavior. The policy requires each Group company to establish operational standards and appoint a management supervisor who is in charge of compliance in competition laws. In addition, the IHI Legal Division supports the creation of highly effective operational standards that take into account the actual business situations of each Group company.

IHI Group Basic Policy Against Bribery of Public Officials

In order to comply with anti-corruption laws, the IHI Group has established the IHI Group Basic Policy Against Bribery of Public Officials, and is actively engaged in the fight against corruption. The policy prohibits bribery of all persons, including government officials, and unjust or unreasonable expenses or donations, including facilitation payments. In addition, each Group company has established operating guidelines and has defined specific procedures and chief administrators, thereby working to improve the effectiveness of the regulations.

Competition Law and Bribery Risk Assessment

The IHI Group conducts regular assessment on risks to competition laws and anti-corruption laws for each division of IHI and each Group company. Assessments are conducted with consideration to the region in which each business operates, the characteristics of products and services, the market environment, and past violation cases (including those of other companies), and appropriate measures are taken according to the level of risk.

Training on Competition Law Compliance and Anti-corruption

In order to prevent anti-competitive behavior to occur, the IHI Group conducts competition law compliance training for all the officers and the employees of IHI Group, which covers competition laws in various countries, such as the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade in Japan, the Sherman Antitrust Act in United States, and competition laws in the European Union.
Moreover, in order to prevent corruption, the IHI Group conducts awareness-raising activities and education regarding compliance with anti-corruption laws such as the Japanese Penal Code and the Unfair Competition Prevention Act as well as the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.
Starting in fiscal 2023, the IHI Group rolled out basic e-learning on competition law compliance and anti-corruption to all officers and employees as a principle.
Based on the results of risk assessments, additional training programs are provided to IHI divisions and Group companies according to the level of risk. In addition, the training materials are shared on the company’s internal website so that officers and employees are able to refer to them at any time. Also, the IHI Legal Division considers feedback from the participants and recent consultation cases and reviews the training content, then uses the PDCA cycle to make the training more effective.

Raising Awareness Among Officers and Employees

The IHI Group regularly posts articles on competition law and anti-corruption topics on its internal website, which is available to officers and employees, in an effort to increase knowledge of these topics. Relevant internal rules and guidelines are also posted, which officers and employees can read at any time.

Training Participants (Total)

(Unit: People)

Competition Law/Anti-corruption Law Violations

(Unit: Incidents, Scope: IHI and consolidated subsidiaries)

Expenditure to Lobbying, Political Organizations, Economic Organizations, Industry Organizations, etc.

(Unit: Millions of yen, Scope: IHI)

1. The recipient of the expenditure is the People’s Political Association.
2. The main recipients of expenditure to economic and industry organizations are the Society of Japanese Aerospace Companies, Japan Business Federation (Keidanren), and the Japan Bridge Association.