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JFE Group’s Basic Policy on Preventing Bribery of Public Officials

JFE Group’s Basic Policy on Preventing Bribery of Public Officials

Bribery of public officials compromises the fairness and integrity of the officials in question, impedes fair competition, and threatens the social, economic, and democratic stability and sustainable development of countries. Bribery is a crime under the laws of Japan and other countries where it takes place, and amid the ongoing globalization of business, it can even infringe on third-country laws. Most companies convicted of bribery must face the harsh criticism of society, in addition to paying large fines. Moreover, involvement in bribery undermines society’s trust, an essential factor for business, and puts the very existence of the company at risk.

The JFE Group hereby sets out its Basic Policy on Preventing Bribery of Public Officials, aiming to adhere vigilantly to anti-bribery laws, prevent corruption and uphold fair business practices around the world.

1. Prohibition of Bribery

JFE Group Standards of Business Conduct

  • Endeavor to build and maintain sound and proper relationships with governments and political authorities.
  • Comply with all applicable laws and ordinances, endeavor to compete fairly and freely, refrain from illegal business activities, promote sound business practices, and be faithful and sincere in all activities and dealings.

The JFE Group opposes bribery, which is an illegal, anticompetitive and antisocial crime, and shall never attempt to disguise bribes as business entertainment, gifts or donations made directly or via agents, consultants or other third parties. The JFE Group ensures that we will never commit any illegal activities.

2. Punishment for Bribery

The JFE Group shall adhere to this Basic Policy, and deal rigorously with any violation of it in accordance with the preamble of the Standards of Business Conduct as mentioned below.

  • The top management is responsible for communicating these standards to employees of Group companies and their supply chain partners, and for creating effective systems and mechanisms to ensure adherence to ethical standards. The top management shall take the lead in solving problems and in introducing measures to prevent the recurrence of any violation of these standards. Additionally, the top management shall disclose necessary information promptly and accurately to internal and external stakeholders, determine the relevant authority and accountability pertaining to the violation, and discipline the responsible person rigorously.

3. Mechanism to Prevent Bribery

To convey this Basic Policy to employees and to ensure its effectiveness, the JFE Group has established a number of mechanisms.

1) Corporate Social Responsibility Council
The Group Corporate Social Responsibility Council (Group CSR Council) works with each operating company through activities by The JFE Group Compliance Committee which is a part of the Group CSR Council, to prevent bribery and other illegal activities. The Group CSR Council promotes and oversees the mechanisms implemented by each company, as detailed in items i. to iii. below. In addition, the Group CSR Council reviews these bribery-prevention mechanisms and procedures to revise them as required. If any problem is found, the Group CSR Council shall discuss and decide how to deal with the matter as well as develop preventive countermeasures as required. The top management of JFE Holdings and its operating companies shall participate in the Group CSR Council as members.
i.
Bribery-risk assessments for each business, conducted on a regular basis, and revision and improvement of countermeasures based on these assessments.
ii.
Establishment of company rules and guidelines in accordance with perceived risks, and provision of training programs and a compliance guidebook to ensure thorough adherence to this Basic Policy.
iii.
Regular internal audits to confirm adherence to this Basic Policy.
2) Corporate Ethics Hotline
The JFE Group maintains a Corporate Ethics Hotline that employees can call to report observed or suspected illegal, wrongful or unethical conduct to the group’s compliance section or outside attorneys. Even when it is difficult to discuss with one’s direct supervisor, employees who find they are being pressured to engage in such conduct also can call the hotline. No information pertaining to calls will be divulged and there are no negative ramifications for calling. The hotline is available to receive any information regarding bribery.
3) Agents, Consultants and Other Third Parties
In many cases of convicted bribery, the bribes are handled through third parties, such as local consultants. The JFE Group is intensifying measures for the pre-contract review of involved third parties and the ongoing monitoring of such entities. JFE Group companies are encouraged to include anti-bribery provisions in their contracts with third parties.