Rigorous Compliance

The JX Advanced Metals Group Code of Conduct and the JX Advanced Metals Group Compliance Regulations define compliance as not only observing domestic and foreign laws, rules, and regulations, but also acting in line with social norms and corporate ethics. We conduct our corporate activities with an emphasis on compliance.

Based on the belief that thorough compliance is a prerequisite, the Group, as a member of the community, continues to create value in response to the expectations of our diverse stakeholders, and we have established various internal regulations concerning compliance. If any issues are identified in the system or in operations, we make improvements as we continue various efforts that will enable us to remain a trusted corporate group.
Measures related to compliance in the Group are determined at Compliance Committee meetings (twice yearly in principle). The Committee consists of executives from the Company and other major Group companies in and outside Japan. In response to reports on the state of compliance provided by individual departments of the Company and Group companies, the Compliance Committee evaluates the risk of fraudulent acts, legal violations, and other misconduct related to business operations, and reflects the results in setting priority issues and formulating education plans.

To increase reliability, we have outsourced the Group's whistleblower program to an external organization. This external organization is responsible for accepting anonymous reports from whistleblowers. We have also taken a wide range of measures to increase awareness of the program throughout the Group. Such measures include displaying posters at individual Group company sites to publicize the program, creating a special section on the Company portal site, and introducing the program during compliance education sessions.
In fiscal 2023, we received 14 reports through the program and took necessary measures in all instances in accordance with the relevant rules and regulations while taking due care to protect whistleblowers.

The Group has established a system for eliminating anti-social forces based on the JX Advanced Metals Group Regulations for Dealing with Anti-social Forces and the JX Advanced Metals Group Detailed Rules for Dealing With Anti-social Forces in order to cut off any relationship with anti-social forces. This system includes periodically conducting specified investigations of business partners and their related parties, and taking contractual measures in advance to terminate business relationships, depending on the circumstances. In order to prevent violations or suspected violations of anti-bribery laws and regulations by Group company executives and employees, we have established an anti-bribery system founded on the JX Advanced Metals Group Anti-Bribery Regulation. This system includes the requirement of a prescribed set of checks when providing entertainment, gifts, etc., to a public official or similar person, and approval from a responsible party when certain conditions are met.
In fiscal 2023, we continued to monitor the application of said regulations, confirming that the system was generally being implemented appropriately. (There were no adverse dispositions issued by regulators in regard to bribery.)

The Group has established the Program for Compliance with Competition Laws, which includes rules such as those requiring all employees to report in advance planned transactions or gatherings with competitors to confirm that they do not violate competition laws, requiring individual managers to submit periodic reports to the head office, and so on.
In fiscal 2023, we continued to monitor the application of the aforementioned program, confirming that it was generally being implemented appropriately. (There were no adverse dispositions issued by regulators in regard to anti-competitive behavior.)

We conducted complete inspections for compliance with environmental and safety laws at three Group sites in fiscal 2023. We confirmed that environment-related and occupational health and safety-related laws were thoroughly understood by employees at all Group company sites, and no serious lack of understanding was observed. All sites are also responding appropri-ately to matters requiring improvement.

We conducted inspections for compliance with personnel and labor laws at four Group sites in fiscal 2023 and confirmed proper management.

The Group facilitates the fulfillment of compliance education to increase awareness and knowledge of compliance among executives and other employees, and conducts a variety of compliance and legal training sessions in Japan and overseas based on business characteristics and social trends.
In fiscal 2023, in addition to the annual rank-specific compliance training (for directors, managers, new employees, etc.), we conducted training sessions on internal controls, security trade controls, harassment, human rights, the Stamp Tax Act, information security, etc., as theme-specific legal and regulatory education sessions. At overseas bases, we conducted education for expatriates at the head offices or the bases, taking into account business characteristics and social trends, etc. In the U.S., Germany, and China, lectures on the Group's compliance system and explanations of important laws and regulations, such as those dealing with competition law compliance and anti-bribery, were presented mainly to national staff managers by lawyers, legal staff, and other instructors. It was an opportunity for participants to deepen their understanding of compliance.
Going forward, we plan to continue studying and implementing compliance training programs in Japan and overseas, based on trends in legal revisions, regional characteristics, and other factors.

The JX Advanced Metals Group recognizes that the proper fulfillment of tax obligations in the countries and regions where a company does business is one of the most important social responsibilities that it should fulfill. Based on this, we are fostering awareness of tax compliance and working to maintain our tax governance system in accordance with the ENEOS Group Tax Matters Policy.

The Accounting Department is in charge of corporate taxes and performs duties related to taxes under the management and supervision of the executive officer in charge of the Accounting Department. We also established and maintain an internal control system, including matters related to taxes. We strive to ensure that this system operates properly and that an effective tax governance structure is in place. Whenever important tax-related events occur, the Company reports such to the Executive Council and other relevant bodies in a timely and appropriate manner.

We are committed to reducing tax risks by consulting with outside experts and making advanced inquiries with tax authorities. We are committed to proper tax compliance by providing tax authorities with timely and appropriate information and by responding sincerely and cooperatively. We are a member of the Japan Mining Industry Association. Through this association, we gather information and express our opinions on tax system revisions to government agencies.

The Group recognizes that intellectual property rights are important company assets and strives to protect and utilize such rights. In addition, the JX Advanced Metals Group Basic Policy on Intellectual Property clearly states that we respect the intellectual property rights of other companies and endeavor not to infringe on them. In researching and developing new products and technologies, we conduct preliminary investigations to ensure that our products do not infringe on intellectual property rights.