Rigorous Compliance

The JX Advanced Metals Group Code of Conduct and the JX Advanced Metals Group Compliance Regulations define compliance as not only complying with domestic and foreign laws, rules, and regulations, but also acting in compliance with social standards 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 our compliance structure 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 officers, etc., 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.
The Compliance Committee, a subcommittee under the Sustainability Committee, receives reports on the state of compliance from each department of the Company and from Group companies. Based on these reports, the committee evaluates the risks of fraudulent acts, legal violations, and other compliance violations related to business operations, and reflects the results in setting priority issues and formulating education plans.
The Group also established reporting standards and requires prompt reporting to ensure that appropriate action can be taken in the event of compliance violations or the risk of such violations.

The JX Advanced Metals Group established the JX Advanced Metals Group Hotline, a whistleblower system established to detect and correct violations of laws or internal regulations within the Group at an early stage. The hotline is available to not only officers, employees, and temporary staff of Group companies, but also to employees of contractors engaged in Group business activities. To increase reliability of our whistleblower system, we have outsourced the JX Advanced Metals Group Hotline to an external organization. This external organization also accepts anonymous reports. No one using the Group hotline for consulting or reporting shall be subjected to disadvantageous treatment for its use.
We have also taken a wide range of measures to increase awareness of the system 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 2024, we received 13 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 Basic Regulation on Handling of Antisocial Forces and the JX Advanced Metals Group Detailed Regulation on Handling of Antisocial Forces 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 2024, we continued to monitor the application of these regulations, confirming that the system was generally being implemented appropriately.
(There were no adverse dispositions issued by regulators in regard to bribery.)

The JX Advanced Metals Group established an anti-bribery framework based on the JX Advanced Metals Group Regulation for Preventing Bribery, aiming to prevent bribery of public officials in various countries, as well as prevent acts that violate or could be suspected of violating anti-bribery laws and regulations, by officers and employees of JX Advanced Metals Group companies. This framework prohibits acts that violate or could be suspected of violating anti-bribery laws and regulations. The framework also requires prescribed checks before providing entertainment or gifts to public officials and other similar parties, and in certain cases, approval from each company’s designated Person Responsible for Preventing Bribery, as part of our efforts to prevent misconduct before it occurs.
In fiscal 2024, we continued to monitor the application of said regulations, confirming that the framework was generally being implemented appropriately. (There were no adverse dispositions issued by regulators in regard to bribery.)

The JX Advanced Metals Group established the JX Advanced Metals Group Regulation for Compliance with Competition Laws to prevent cartels and other conduct that may violate competition laws in the countries in which we conduct business activities. We prohibit not only acts that violate competition laws but also any behavior that could give rise to suspicion of such violations. At the same time, we established the Program for Compliance With Competition Laws to prevent issue occurrence. This program requires, among other measures, obtaining approval from each company’s designated Person Responsible for Compliance with Competition Laws before attending meetings with competitors and reporting back afterward, submitting an annual report from each company’s designated Person Responsible for Compliance with Competition Laws to the Legal Department at JX Advanced Metals Headquarters, conducting prescribed checks in advance when entering into transactions that may raise competition law concerns, and having the responsible person submit periodic reports to the program secretariat.
In fiscal 2024, 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 laws related to environment and safety in fiscal 2024.
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 appropriately to matters requiring improvement.

The Group facilitates the fulfillment of compliance education to increase awareness and knowledge of compliance among officers and other employees, and conducts a variety of compliance training sessions in Japan and overseas based on business characteristics and social trends.
In fiscal 2024, in addition to the annual rank-specific compliance training (for officers, managers, new employees, etc.), the Group implemented a compliance program common to all JX Advanced Metals Group companies. We also took business characteristics and social trends into consideration and conducted various field-specific legal and regulatory education sessions on topics including human rights, harassment, security trade controls, and the Stamp Tax Act. Other training included the prevention of insider trading, in light of the Company’s recent listing on the stock market. At overseas bases, we conducted education for expatriates held by headquarters or the overseas bases themselves, taking into account business characteristics, social trends, and other factors. In Germany and China, lectures on important laws and regulations, such as those dealing with competition law compliance, anti-bribery, and personal information protection, were presented mainly to national staff managers by lawyers, legal staff, and other instructors.
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 is committed to ensuring tax compliance and proper tax payments in all countries and regions where we deploy business activities. To this end, we have built a global tax governance framework in accordance with the JX Advanced Metals Group Tax Policy and endeavor to improve tax awareness and compliance within the Group. In this way, we aim to boost corporate value through tax optimization and tax transparency.

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 maintained 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 mitigating tax risks by consulting with outside experts seeking advice from independent tax experts and obtaining advance rulings from 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 parties 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.