ComplianceSustainability
- Fundamental Approach and Issue Awareness
- Compliance Promotion System
- Compliance Promoting Education and Training
- Corruption Prevention
- Fair and Just Trade with Suppliers(CSR- and ESG-Based Responsible Procurement)
- Whistleblower System and Harassment Consultation Hotline
- JERA Transaction Monitoring Committee Launched in June
- Tax Compliance
Fundamental Approach and Issue Awareness
Under our mission to provide cutting edge solutions to the world’s energy issues,JERA is committed to earning and maintaining the trust of our stakeholders throughrigorous compliance based on the JERA Group Compliance Policy and JERA GroupCompliance Code of Conduct.
As a key player in supporting the stable supply of domestic electricity andan international leader in fuel procurement, renewable energy, and low-carbonthermal power, we have a responsibility to address a variety of compliancechallenges related to competition law, bribery, human rights, the environment, and more. Additionally, in keeping with our stature as a global company, our employeesact with a heightened sense of ethics, faithfully observing laws, regulations, andsocial standards concerning these matters.
Even as the business environment surrounding the energy industry undergoessweeping change, we will engage in compliance on a group-wide scale to enableour officers and employees to act in an appropriate manner in accordance with theirresponsibilities.
Compliance Promotion System
We have established the Compliance Committee to review and decide on various compliance-related measures and thereby promote compliance-oriented management. This committee is composed of internal members, including the Global CEO and Chair, and the President, Director, CEO and COO, along with external experts. The content of compliance measures, investigations into misconduct, corrective actions, measures to prevent recurrence, and other matters deliberated and reported on by the committee are to be discussed with or reported to the Board of Directors as necessary. The Legal Group, which serves as the committee's secretariat, works closely with compliance managers and program officers at each workplace and office, as well as with heads of compliance from group companies, to promote group-wide compliance among all levels of the JERA group.
Compliance Program Structure(As of July 1, 2023)
Compliance Promoting Education and Training
In our Compliance Committee, we incorporate the opinions of outside experts and employee survey results, deliberating on and determining compliance-related measures and monitoring their progress each fiscal year.
In FY2022, we promoted compliance by developing our Declaration of Partnership Building and Group Policy against Anti-Social Forces, holding meetings with our liaison group of compliance managers and compliance promotion members, visiting power plants, strengthening messaging from top management, and thoroughly overhauling our intranet site, all to raise awareness of our Compliance Policy and Code of Conduct.
In FY2023, we will focus on boosting employee compliance by establishing clear rules in ways that are easy to understand and placing further emphasis on strengthening information sharing and training while also ensuring that an awareness of compliance takes root in our organization.
April 2022–July 2023 Primary Compliance Initiatives
Corruption Prevention
In order to comprehensively prevent corruption as stipulated by the JERA Group Compliance Policy and JERA Group Compliance Code of Conduct, we have established Anti-Bribery Regulations and Anti-Corruption Regulations. These policies establish approval procedures for entertainment, gifts, and donations to domestic and foreign public officials or agents of those officials, delineate prohibited activities, and describe reporting procedures for the exchange of money or goods with business partners. Further, we raise awareness of these policies through a training system, the Legal Group monitors and supervises related processes and operations, and the Compliance Committee receives reports on these and other efforts.
Additionally, our due diligence efforts for preventing corruption in transactions will be focused on transactions and M&A in countries and regions with high corruption indices, ensuring that we will not assume any unforeseen corruption risks.
Basic Policy on Anti-Corruption
(Excerpted from JERA Group Compliance Code of Conduct)
- We always maintain proper and healthy relationships with our business partners and do not provide them with money, gifts, entertainment, or any other economic benefits that exceed good judgment. We also do not receive any economic benefits that exceed good judgment.
- In our procurement activities, we provide open, fair, and equal participation opportunities in both domestic and overseas markets and select suppliers through rational and transparent procedures.
- We establish and maintain fair and open relations with the political and governmental counterparts of each country and region in compliance with domestic and international laws and regulations, and internal rules.
- We do not entertain, provide gifts, or provide any other economic benefits to public officials or anyone in an equivalent position, domestic or foreign.
- We do not make such payments if we are aware that a portion of the payments made to agents or consultants, or any such parties, is being or is suspected of being diverted for the purpose of engaging in improper activities with public officials or persons in an equivalent position.
Fair and Just Trade with Suppliers
(CSR- and ESG-Based Responsible Procurement)
We uphold the principles of free trade and market competition and conduct our transactions and business activities in compliance with laws and regulations as well as with the principles of fairness and impartiality.
As a power producer, we are firmly committed to promoting appropriate electric power competition, most notably by operating in compliance with the Guidelines for Proper Electric Power Trade and by ensuring non-discrimination between domestic and foreign entities. As a purchaser supporting the energy value chain, we engage with business partners and subcontractors in accordance with the Declaration of Partnership Building, fostering partnerships and co-prosperity.
We have also established a Procurement Policy alongside our acquisition activities. We are committed to responsible procurement in consideration of corporate social responsibility (CSR) and of environmental, social, and governance (ESG), including quality assurance, appropriate procurement cost management, compliance with laws, regulations, and corporate ethics, safety assurance, and business continuity planning (BCP). Additionally, we hold procurement policy briefing sessions to promote mutual study and close communication with business partners, taking opinions and requests into account while seeking cooperation with JERA Group Compliance Policy and Code of Conduct and thereby endeavoring to build even stronger relationships of trust with our business partners.
Whistleblower System and Harassment Consultation Hotline
We have established a whistleblower hotline to prevent compliance violations and quickly detect and resolve any violations that do arise. The hotline can be used with either a real name or anonymously, via email or postal mail, and allows communication with both internal and external contacts. A wide range of topics, including domestic and foreign law violations, as well as violations of employment regulations and internal rules, can be discussed via this hotline. As of FY2021, we have a new harassment consultation service specifically established for discussing or reporting harassment and other work-related issues. In FY2022, the whistleblower hotline received a total of 13 cases, while the harassment consultation hotline had 11.
Whistleblowing Case Overview (FY2022)
In response to the enactment of the amended Whistleblower Protection Act (June 2022), we have established internal reporting channels via our whistleblower and harassment consultation hotlines. This includes designating and providing training and education for individuals engaged in public interest reporting activities.
We promote the use of these internal reporting channels by continuing to share information about the whistleblower system regularly and seeking to build trust through efforts such as assessment of intention, protection of confidentiality, and prohibition of discriminatory treatment or retaliation against whistleblowers.
A Word From the Head of the Legal Group
Kenji Tagaya
Head of the Legal Group
For us, compliance does not simply mean abiding by laws and regulations. It means a commitment to honest, fair business practices under external observation and public scrutiny, even when no one is watching.
Naturally, compliance involves our entire company—every department, every workplace, and everyone from top management to employees—so the compliance unit cannot handle this task alone. However, the legal group also seeks to emphasize a compliance-oriented company culture through actions such as assigning compliance managers and promotion members to each organization and workplace who share information and provide training to support voluntary engagement in compliance.
In recent years, the electric power and energy industry has seen a spate of compliance-related issues. We take this trend very seriously. Top management has repeatedly stressed to employees that compliance should not be difficult. Instead, it hinges on understanding the perspectives and emotions of various stakeholders, including customers, business partners, investors, and colleagues. As such, upholding the truth and fostering respect and trust among colleagues are paramount. Concerning our core business in electricity and gas, we've taken the initiative in establishing the JERA Transaction Monitoring Committee (detailed below) to continuously incorporate insights from external experts.
We will remain conscious of our great social responsibility as a public utility company and will continue to conduct ourselves and our business with composure.
JERA Transaction Monitoring Committee Launched in June
Background Behind the Establishment of the JERA Transaction Monitoring Committee
We respect market competition, abide by laws and regulations, and conduct transactions and business activities fairly and equitably, ensuring our actions align with our responsibilities as an energy provider providing electricity and gas in Japan.
The JERA Transaction Monitoring Committee, which includes outside experts, was established under the direct supervision of the President, Director, CEO and COO to confirm and verify such transactions and activities from a third-party perspective to further improve transparency.
Scope of Activities
- To check the legality and appropriateness of wholesale electricity and gas market transactions
- To check the internal vs. external non-discrimination and appropriateness of Power Purchase Agreements and Gas Sale Agreements
- To check the legality and appropriateness of other transactions (including transactions with shareholders) under competition and business laws
Structure(As of July 1, 2023)
With the establishment and operation of this committee, we will lead the way in creating a market for fair and equitable electricity and gas transactions in Japan. At the same time, by further pursuing fair and equitable transactions, we strive to ensure that business profits are passed on through market competition to the end consumer—our valued customers.
Tax Compliance
In February 2022, JERA established and announced to the public JERA Group Tax Policy, which outlines the company’s fundamental position and aims to strengthen tax governance with management involvement.
In order to fulfill our ethical tax obligations and social responsibilities, we are committed to further reducing tax risk by strengthening our tax governance.