Japanese Companies

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Laws: In Japan the Ethics Act establishes the Ethics Board and grants it legislative power. The Board is responsible for investigating, either by itself or in cooperation with the person who appointed the public official, suspected misconduct. In order to safeguard public trust, all public officials must report to their heads of ministries or agencies any gift or hospitality worth more than JPY5000 (~£40). If the gift is more JPY20000 (~£160), the declaration can be made public. Under Japanese law, both the person attempting to bribe and the official who accepts it are liable. The law was recently revised to comply with the OECD anti-bribery provisions. Further, the law makes no special provisions for facilitation payments.

Japan like other countries in the Asia-Pacific region such as Thailand, Vietnam, Taiwan, Indonesia and the Philippines, does not criminalise private sector bribery. However, due to the introduction of the UK Bribery Act (which does cover this form of bribery) companies that are incorporated under UK law can be held liable for private sector bribery.  

 

RESULTS BASED ON PUBLICLY AVAILABLE INFORMATION ONLY

FUJITSU* - BAND B

NEC CORPORATION* - BAND D

IHI MARINE,  MITSUBISHI ELECTRIC CORPORATION,  MITSUBISHI HEAVY INDUSTRIES* - BAND E 

KAWASAKI HEAVY INDUSTRIES - BAND F

Fujitsu scores well in Band B as they provided good amounts of public evidence of their anti-corruption programmes. Four companies score in Band E and F (IHI Marine, Kawasaki Heavy Industries, Mitsubishi Electric, and Mitsubishi Heavy Industries) as they provided little to no public evidence of their anti-corruption systems.  

 

RESULTS FOR COMPANIES PROVIDING INTERNAL INFORMATION

Company

Band based on

Public Information only

Band based on

Public and Internal Information

Fujitsu

B

A

Mitsubishi Heavy Industries

E

C

NEC Corporation

D

B

Three of the six Japanese companies provided internal documentation.

Fujitsu is the highest scoring company as they demonstrate significant anti-corruption controls. Further, the company takes a very values-based approach to compliance and ethics. Termed the ‘Fujitsu Way’, the company aims to instil a corporate philosophy of integrity and transparency. It is pertinent to note that the company scores very well based on public information alone as they provide substantial information on the company’s ethics programme on their corporate website. Two other companies, Mitsubishi Heavy Industries and NEC Corporation, also chose to provide internal information, which results in their scores improving significantly as they were able to demonstrate good evidence of basic anti-corruption provisions.

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