Compliance
Permeation of a Spirit of Compliance
The misconduct of a single individual can instantly destroy a corporate brand built over many years. The Marubeni Group places the highest importance on compliance in its corporate activities, and pushes for every member of the group to have strong ethical standards.
Our Basic Position on Efforts for Compliance
Compliance, according to the Marubeni Group, goes beyond merely following the letter of the law. In its true sense, compliance means that corporations, as members of society, must respond to the expectations of all stakeholders, obtain their trust,and exercise full social responsibility.
The Marubeni Group has placed the highest priority on compliance and in 2002 :
1. We established the "Compliance Committee"(under the President&CEO and chaired by Masaru Funai, Executive Corporate Officer, Member of the Board)
2. We created the "Compliance Manual."
Since then, in order to instill a spirit of compliance into the heart of every member of the Marubeni Group - from executives to staff members - we have instituted a series of training and awareness programs.
To Achieve Compliance
Revision of the Compliance Manual
The Marubeni Group distributes a hardcopy of the Compliance Manual to each of its employees and executives, as well as making it electronically available on our Intranet (Extranet). The manual is also available to the public on our website :
http://www.marubeni.com/company/policy/compliance.html
The booklet is frequently updated. In the latest revision (April 2007), important items such as"the Prohibition to cooperate with money laundering" were added.
Ensuring Compliance with the Manual
The Compliance Manual is not just distributed. Every employee and executive of the Marubeni Group is tested on its content and makes a pledge each year to adhere to the manual.
The "Door of Courage"
The "Door of Courage" is a compliance reporting and consultation center that is open to employees and executives of the Marubeni Group. It is essential for preventing misconduct.Whenever a problem arises, a direct line to the top of the anagement structure must be available. The Marubeni Group tries to create an open and free environment for consultation, but for some matters, reporting through ordinary means is difficult.
For these kinds of cases, 'the Door of Courage' was established to give employees a way to consult with the Compliance Committee and external legal counsel. This ensures that the report and consultation will be held in the strictest confidence,and will not become a basis for unfair treatment. In February 2006, an additional female lawyer was added to the 'Door of Courage,' with a view to creating a safer and more comfortable environment for female employees.
Organizational Diagram for the Marubeni Group Compliance System
Implementation at Group Companies and Overseas
The companies of the Marubeni Group are each engaged in building up compliance systems suited to their specific ircumstances,while working to raise awareness among their employees. In addition, the chair of the Compliance Committee makes annual visits to the main group companies to receive briefings and directly communicate the importance of compliance. At our overseas sites, the Marubeni Group is creating compliance systems suited to each country?s laws and business practices.
Training with e-Learning
One of the most crucial ways of achieving compliance is through daily, routine work. Because it is important to remind employees and executives about compliance, Marubeni introduced compliance training through e-Learning in fiscal 2005.
The Compliance e-Learning Training Program uses our internal LAN system so that each employee can learn whenever they like at their own computer. Even during busy times, the training curriculum can be broken up into sections to let employees learn during short lulls in work.
The content has been designed with rich visuals and sound to create a program that is easy for employees to use.
Managers are also able to watch the progress of each employee,and those who have not yet gone through the program are encouraged to complete it. As a result, nearly all of our employees have finished their training. Temporary employees and group companies are also using the program.
Putting Compliance into Practice
Constructing Personal Information Protection Systems
Marubeni has created an internal system for protecting personal information, and adopted and published our "Personal Information Protection Policy."
http://www.marubeni.com/privacy/
Laws for protecting personal information came into full effect on April 1, 2005. In response,Marubeni created the "Personal Information Protection Policy.". Also Marubeni has worked to maintain and strengthen our internal systems, and increased our employees? awareness of personal information protection.
