JXTG Group Anti-Corruption Policy

The JXTG Group conducts business activities under the JXTG Group Philosophy, which states that we will contribute to the development of our communities and help to ensure a vibrant future through creation and innovation in energy, resources, and materials.
This policy was formulated as a guideline for the entire Group to prevent corrupt practices along with actions complicit in corrupt practices, as well as to fulfill its corporate responsibilities to society.

1. Basic Approach

Under this policy, officers and employees, etc., of the JXTG Group, both inside and outside of Japan, are required to comply with laws on the prevention of corrupt practices in Japan and other countries and prevent corrupt practices as well as actions complicit in corrupt practices.

2. Compliance with Applicable Laws and Regulations

The JXTG Group complies with applicable laws and regulations in the countries and regions where it conducts its business activities.

3. Prohibited Actions

The JXTG Group prohibits, both directly and indirectly, corrupt practices along with actions complicit in corrupt practices among its officers and employees, etc., both inside and outside of Japan, regardless of whether the other party is a public servant or a private individual.

4. Management of Payment Records

In cases where officers and employees, etc., of the JXTG Group provide money or other benefits to third parties involved in business execution processes, the JXTG Group will appropriately retain evidence of such transactions, and require that the money or other benefits be recorded in accounting records, accurately and without exception, in terms of amount, accounting item, etc., in order to prevent off-the-books handling.

5. Training

The JXTG Group will provide appropriate training to its officers and employees, etc., to ensure that this policy is appropriately implemented in the business activities of all JXTG Group companies.

6. Penalties for Violations

The JXTG Group will impose rigorous penalties on any of its officers or employees, etc., found to be in violation of this policy, based on the rules of the JXTG Group company the officer or employee belongs to. In addition, the JXTG Group will impose rigorous penalties on advisors, consultants, agents, or contractors, etc., hired by the JXTG Group if they are found to be in violation of this policy.

7. Compliance System

The presidents of all JXTG Group companies bear a responsibility to ensure that their officers and employees, etc., abide by this policy. In addition, officers or employees, etc., of the JXTG Group who detect any action that violates or could violate this policy are required to report such action immediately to their company.

8. Applicable Scope

This policy applies to all officers and employees, etc., of the JXTG Group. All business partners involved in the JXTG Group’s business activities will be requested to cooperate with this policy.

9. Positioning

This policy supplements the provisions of the JXTG Group Philosophy and the JXTG Group Code of Conduct.

Notes

JXTG Group:
JXTG Holdings and the subsidiaries of JXTG Holdings, including both those directly and indirectly owned.
Corrupt practices:
Bribery, embezzlement, coerced benefit sharing, bid-rigging and other acts that involve the abuse of the authority or position of oneself or a third party.
Bribery:
Refers to both giving bribes, where money or other interests or benefits are offered, promised or actually given, and receiving bribes, where interests or benefits are requested or actually received, for the purpose of obtaining interests or benefits by wielding improper influence over the duties of the other party.
Actions complicit in corrupt practices:
Actions including judicial interference, concealment of corrupt earnings, money laundering, and instigation, assistance or conspiracy to commit corrupt practices.
Employees, etc.:
Employees, contract workers, and part-time employees of the JXTG Group, temporary workers dispatched to the JXTG Group, and other persons subject to the instructions or orders of the JXTG Group.
Public servant:
Includes, but is not limited to, national government employees, local government employees, persons engaged in official duties for international institutions, persons deemed to be engaged in public duties per laws and regulations, and officers and employees of companies effectively controlled by a national government or local government.

Esso and Mobil are trademarks of Exxon Mobil Corporation, used under license.