ENEOS Group Competition Law Compliance Policy
The ENEOS Group conducts business activities under the ENEOS 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 comply with competition laws in Japan and other countries.
1. Basic Approach
The ENEOS Group recognizes the importance of conducting fair and equitable transactions in the countries and regions where it conducts its business activities.
2. Compliance with Applicable Laws and Regulations
The ENEOS Group complies with competition laws applicable in the countries and regions where it conducts its business activities.
3. Prohibited Actions
The ENEOS Group prohibits its officer and employee, etc., from engaging in activity that violates competition laws including cartels. No activity that would violate competition laws shall be justified by any reason of business custom, the authority or position of the violator, maintaining or expanding business or making profits.
4. Training
The ENEOS Group will provide continuous and effective training to its officers and employees, etc., to ensure that this policy is appropriately implemented in the business activities of all ENEOS Group companies.
5. Penalties for Violations
- (1)The ENEOS Group will review any suspected violation of competition laws and immediately take appropriate measures in response to a violation. Also, ENEOS Group will respond to investigations by competition law authorities in sincere manner.
- (2)The ENEOS 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 ENEOS Group company the officer or employee, etc., belongs to.
6. Compliance System
The presidents of all ENEOS 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 ENEOS Group who detect any action that violates or could violate this policy are required to report such action immediately to their company.
7. Applicable Scope
This policy applies to all officers and employees, etc., of the ENEOS Group. All business partners involved in the ENEOS Group’s business activities will be requested to cooperate with this policy.
8. Positioning
This policy supplements the provisions of the ENEOS Group Philosophy and the ENEOS Group Code of Conduct.
Notes
- ENEOS Group:
- ENEOS Holdings and the subsidiaries of ENEOS Holdings, including both those directly and indirectly owned.
- Competition laws:
- The laws and regulations of a country aimed at promoting fair and free competition in markets and restricting anticompetitive activities, including Japan’s “Act on Prohibition of Private Monopolization and Maintenance of Fair Trade”.
- Employees, etc.:
- Employees, contract workers, and part-time employees of the ENEOS Group, temporary workers dispatched to the ENEOS Group, and other persons subject to the instructions or orders of the ENEOS Group.
- Competition law authority:
- Includes Japan Fair Trade Commission and authorities in each country responsible for enforcing competition laws.