JFE Group Basic Policy on Competition Law Compliance

JFE Group has established "JFE Group Standards of Conduct" to ensure that all business activities are conducted legally through fair and free competition. Reflecting on past violations of competition law, JFE Group has established the system and implemented measures to comply with competition laws of Japan and other countries (hereinafter referred to as "Competition Law") under the policy of not permitting any violation of laws and regulations, including Competition Law, and dealing with them rigorously. In order to further clarify and ensure the implementation of the policy, JFE Group hereby has introduced "JFE Group Basic Policy on Competition Law Compliance".

1. Compliance with Competition Law

JFE Group Standards of Conduct

  • "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."

We shall comply with Competition Law and shall never engage in illegal activities such as cartels and bid rigging.

2. Competition Law Compliance System

JFE Group shall establish and operate the Competition Law compliance system, headed by the Group Sustainability Council, which is composed of top management from JFE Holdings and each operating company, in order to ensure that this Group Basic Policy is thoroughly understood and effective.

Through the activities of the Group Compliance Committee, which is part of the Group Sustainability Council, the Council promotes and oversees measures to comply with Competition Law in cooperation with the operating companies, and reviews and improves the system as appropriate. If any problems are found, the Group Sustainability Council discusses and decides how to deal with the matter as well as develop preventive countermeasures as necessary.

3. Measures to Comply with Competition Law

JFE Group implements the following measures to comply with Competition Law under the Competition Law compliance system described in section 2 above.

  1. Establishment of Basic Rules

    In order to ensure the sustainable establishment and operation of the Competition Law compliance system, each operating company shall establish basic rules for compliance with Competition Law that comprehensively stipulate matters related to the establishment and operation of the system.

  2. Risk Assessment

    According to the basic rules described in (1) above, we regularly assess the risk of Competition Law violations in each business, and review and improve the Competition Law compliance system based on the risk assessment.

  3. Various Measures

    Based on the results of the risk assessment described in (2) above, we consider and implement the following measures in accordance with the importance of the assessed risk to appropriately manage the risk.

    1. Establishment and Operation of Internal Rules on Contact with Competitors
      Considering the high risk that contact with competitors could lead to cartels and bid rigging, we establish and operate internal rules regarding contact with competitors in accordance with the risk of violating Competition Law.
    2. Conducting Legal Training
      We conduct legal training on Competition Law in order to make each director, corporate officer and employee understand the importance of compliance with Competition Law and to disseminate the overview of our Competition Law compliance system.
    3. Establishment and Maintenance of Consultation System
      We establish and maintain a system that allows individual directors, corporate officers, and employees to consult with the legal department in a timely manner and without hesitation when they are unsure whether their actions may violate Competition Law.
    4. Internal Audits
      The internal auditing department conducts internal audits to confirm whether the Competition Law compliance system is properly established and operated. The results of these audits are reported to appropriate committees, such as the Group Sustainability Council.
    5. Establishment and Maintenance of Whistleblowing System
      We establish the Corporate Ethics Hotline, which allows employees to confidentially report or consult with internal or external contacts, even in situations where they are unable to consult with their immediate supervisors. This hotline is available for reporting actual or potential misconduct, legal violations, or ethical concerns related to Competition Law, including circumstances in which employees feel compelled to engage in such conduct themselves.
  4. Response to Suspected Violations of Competition Law

    In the event that any suspected violations of Competition Law arise, we will take appropriate measures, including considering the use of leniency programs, such as applying for surcharge reductions with domestic or foreign competition authorities and cooperating with relevant investigations.

4. Cause Analysis and Strict Measures

JFE Group Standards of Conduct

  • "Senior managers are responsible for communicating these standards to employees of Group companies and their supply chain partners, and in creating effective systems and mechanisms to ensure adherence to ethical standards. Senior managers are also responsible for measures to prevent the recurrence of any violation of these standards. Additionally, they must report violations promptly and accurately to internal and external stakeholders, determine the persons of relevant authority and accountability, and resolve matters rigorously."

In the event that a violation of Competition Law is identified, we will conduct a thorough root cause analysis, formulate and implement effective measures to prevent recurrence, and take strict disciplinary or corrective action as appropriate.