Competition Laws/Anti-corruption Laws

Approach

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. We are also implementing the following initiatives at our company.

 

Competition Law Compliance
Based on the IHI Group Competition Law Compliance Policy, that embodies the IHI Group Code of Action, we have established Operational Standards for Competition Law Compliance that are tailored to our company business. Under a system headed by the President, we are thoroughly ensuring compliance with competition laws.

 

Anti-corruption Law Compliance
The IHI Group Basic Policy Against Bribery of Public Officials prohibits bribery of all persons, including government officials, and unjust or unreasonable expenses or donations, including facilitation payments. In addition, we have established operating guidelines and has defined specific procedures and chief administrators, thereby working to improve the effectiveness of the regulations.

Governance

As a part of its internal control, we undergo regular audits conducted by IHI to ensure that we are in compliance with the IHI Group Competition Law Compliance Policy and the IHI Group Basic Policy Against Bribery of Public Officials.
Additionally, we conduct risk assessments, education, and training on competition laws and anti-corruption laws, and reports the status of these activities to the Compliance Committee once every six months.
Furthermore, the IHI Group has established a system to identify and address any compliance issues at the earliest possible stage through the Compliance Hotline.
If any serious compliance issues are discovered, we set up an emergency headquarters based on the Crisis Response Regulations to quickly and flexibly handle the issue.

Risk Management

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. Based on the results, we take appropriate measures according to the level of risk.

Initiative

Education/Awareness Building

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 and Unfair Competition Prevention Act 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.
Our officers and employees also participate in these training programs.