Compliance
Our Basic Position on Efforts for Compliance
Compliance goes beyond merely following the letter of the law. In its true sense, compliance means that corporations, as members of society, meet the expectations of all stakeholders, earn their trust, and fulfill their social responsibility.
The Marubeni Group regards compliance to be a top management priority, and in 2002, we strengthened our compliance system by establishing the "Compliance Committee" (under the direct control of the President) and creating the "Compliance Manual."
The Compliance Committee, in which Compliance Officers from all divisions, branches and offices participate, met twice during Fiscal 2008. The Committee: (1) approved the Fiscal 2008 program of committee activities; (2) reviewed the division, branch and offices action plans for Fiscal 2007, and reported the action plans for Fiscal 2008; (3) ensured compliance with the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors and the Construction Business Act; (4) completed the system for administering industry laws; (5) responded to the audit comments made by the Audit Department in Fiscal 2007; and (6) reported on the results of the Marubeni Group compliance survey.
Pledge for "Compliance Manual"
The Marubeni Group distributes the Compliance Manual to all employees in the Group. An electronic copy is also available on our Intranet. The manual is also available to the public via our website. Moreover, each year, every employee and executive of the Marubeni Group pledges to adhere to the manual, thereby raising awareness for compliance.
During Fiscal 2008, following the publication of the 5th edition of the Compliance Manual, all officers and employees pledged to adhere to the new manual. In Fiscal 2009, we made further revisions in accordance with the enactment of laws and changing times, and published the 6th edition of the Compliance Manual.
Compliance Systems of Domestic Group Companies
Each of Marubeni's group companies has also been developing its own compliance systems suited to their respective businesses. Every year, the Chairman of the Compliance Committee visits the main group companies to receive briefings and to communicate directly the importance of compliance. During Fiscal 2008, the chairman visited 22 domestic group companies, and held discussions on compliance with the company presidents, compliance officers and executives of each company.
We also conduct a survey on compliance activities, targeting the officers and employees of Marubeni and the domestic group companies.
Compliance Systems of Overseas Group Companies
Overseas as well, group companies have been creating compliance systems suited to the laws and business practices of their respective countries. At major overseas sites, group companies reviewed their Fiscal 2007 compliance action plans, and formulated their Fiscal 2008 compliance action plans. In addition, in Fiscal 2008, the Chairman of the Compliance Committee and the Compliance Team Leader conducted compliance training programs at Marubeni America Corporation, Marubeni (Guangzhou) Trading, Marubeni (Shanghai), Marubeni Hong Kong & South China and Marubeni (Beijing) Trading. A total of 305 overseas local staff participated in these programs.
Education and Training on Compliance
Since 2005, Marubeni has been running the "Compliance e-Learning Training Program," which summarizes the knowledge required to practice the Marubeni Group compliance. As of September 30, 2008, 8,415 people from 82 group companies have participated in the program. In light of the enactment and revision of laws and of economic and social trends, Marubeni has also run other theme-based e-Learning training programs and group training program in a timely manner. Below is a list of representative training programs for Fiscal 2008.
- "Intellectual Property Rights e-Learning" (84% of domestic workers had participated as of March 25, 2009)
- "Subcontracting Law e-Learning" (95% of domestic workers had participated as of March 25, 2009)
- "Document Management e-Learning"(commenced November 2008)
- "Insider Trading Regulations e-Learning" (commenced January 2009)
- "Seminar for the Waste Disposal Law"(group training held in September 2008, 293 participants)
- "Learning from Compliance Violations Committed at Marubeni and Other Companies"
(group training held in February-March 2009, 1,647 participants)
-Case-method training on compliance by a visiting speaker, directed at officers in charge of promoting compliance at divisions
"Door of Courage"
It is important that misconduct in a company be curtailed at its initial stages. We need a system in place whereby, if a problem arises, it is communicated immediately to top-level management via reporting lines. While the Marubeni Group aspires to create an open and free environment where advice of any nature can be sought, for some matters, reporting through ordinary means is difficult.
To address this situation, Marubeni established the "Door of Courage" - a reporting and consultation hotline, whereby all members of the Marubeni Group can consult directly with the Compliance Committee or External Legal Counsel. This ensures that reports and consultations are held in the strictest confidence, and will not become the basis for any unfair treatment.
In February 2006, a female lawyer was added to the staff of the "Door of Courage," with a view to creating a safer and more comfortable environment for female employees.
Number of Violations
As a result of our efforts in ensuring compliance, in Fiscal 2008, there were no material violations of compliance.
The "Product Safety Management Manual" and Approaches Taken by Divisions
During Fiscal 2007, each division formulated a "Product Safety Management Manual" for the safety management of products traded by the Marubeni Group. During Fiscal 2008, each division successively ran a training course, based on its "Product Safety Management Manual." The courses were well attended by employees.
-Training in Compliance and the Product Safety Management Manual for the Transportation Machinery Division
-Compliance Training Program for the Finance, Logistics & IT Business Division
- Training in the Product Safety Management Manual for the Plant, Ship & Industrial Machinery Division
Enhancement of the System for Managing Industry Laws
Aimed at responding to the rapidly changing industry laws and strengthening the associated management system, in Fiscal 2008, Marubeni updated the "List of Applicable Work-Related Legal Restrictions" for each department and branch. We also introduced a group-wide system for providing news updates on laws, and another for searching for laws.
