Itochu Corporation

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board publishes a statement supporting the ethics and anti-corruption agenda of the company. TI notes that the President and CEO makes various statements on the company website, including on the company’s commitment to CSR; however, these statements were not considered strong enough evidence of a commitment to ethics and anti-corruption specifically to award a higher score here.

Based on public information, there is no readily available evidence that the Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure.

Based on public information, there is evidence that the company publishes a statement of values or principles. TI notes that the wider company values statement represents only one high standard of ethical business conduct, sought by the question, namely integrity. However, the company goes into detail about what this means for the company and clearly demonstrates that this value is translated into company working practices. The company therefore scores 1.

Based on public information, there is evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption. Specifically, TI notes that the company joined the UN Global Compact in 2009.

Based on public information, there is evidence that the company has appointed a Compliance Committee with overall corporate responsibility for ‘issues related to compliance’. However, TI notes that it is only implicit that this covers the company’s ethics and anti-corruption agenda. Therefore the company scores 1.

Based on public information, there is evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s compliance agenda. This individual is named: Toru Matsushima, Chief Officer for Compliance.

Based on public information, there is some evidence that there is regular monitoring and review of the performance of the company’s ethics and anti-corruption agenda; however, it is not clear to what extent the Board conducts a regular monitoring and review of the performance of the company’s ethics and anti-corruption programme.

Based on public information, there is no readily available evidence that there is a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based; however, there is evidence of improvement plans being implemented when issues are identified as a result of monitoring and review. The company therefore scores 1.

Based on public information, there is some evidence that the company has a process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption. However, the extent to which this is part of a formal review process remains unclear. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure. Specifically, the company notes that it has undertaken ‘risk assessment with respect to bribery, payoffs and similar impropriety’. However, TI has found no readily available evidence to suggest that the company develops mitigation plans with clear ownership and timelines to minimize such risks. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a formal risk assessment procedure for assessing proposed business decisions.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

Based on public information, there is some evidence that the company makes clear to suppliers, through policy terms, its stance on bribery and corruption. However, it is not clear whether there are contractual terms in place and the consequences of breaches to this stance are not outlined. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is no readily available evidence that the company engages in offset contracting.

Based on public information, there is some evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. However, TI notes that there appears to be no Code of Ethics document and the focus is on the giving of improper advantages rather than the receiving. The company therefore scores 1.

Based on public information, there is no readily available evidence of a zero-tolerance anti-corruption policy.

Based on public information, there is evidence that the company’s anti-corruption agenda is easily available. TI notes that all documentation is available in at least Japanese and English.

Based on public information, there is evidence that the company’s anti-corruption agenda is easily understandable and clear.

Based on public information, there is evidence that the company’s anti-corruption agenda applies to all employees and members of the Board.

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest.

Based on public information, there is no readily available evidence that the company has a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. TI notes that the company makes reference to ‘giving any improper advantage’ but it is not clear that this includes a policy on exchange of gifts.

Based on public information, there is no readily available evidence of a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery. TI notes that the company makes reference to ‘giving any improper advantage’ but it is not clear that this includes a policy on exchange of hospitality.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is no readily available evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which the company lobbies.

Based on public information, there is no readily available evidence that the company prohibits charitable contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent. TI notes that the company undertakes extensive community and charitable activities.

Based on public information, there is limited evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. TI notes that much of the publicly available information is presented at a high level and may not provide adequate guidance for employees and Board members facing issues on a daily basis.

Based on public information, there is evidence that the company has a training programme that covers compliance; however, it is not clear that this specifically covers anti-corruption. The company therefore scores 1.

Based on public information, there is evidence that the company’s compliance training programme is provided in the principal countries where the company operates or has company sites. However, it is not clear that this is provided in all countries where the company operates or has sites. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

Based on public information, there is no readily available evidence that the company provides tailored ethics and anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is no readily available evidence that the company is explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities.

Based on public information, there is some evidence that the company has a hotline system where employees can report concerns or instances of suspected corrupt activity. However, it is not clear that the system guarantees confidentiality or anonymity and TI notes this does not appear to be particularly well-publicised. The company therefore scores 1.

Based on public information, there is evidence that the company has a hotline for employees to report concerns. The company therefore scores 1. To score higher, the company needs to provide evidence of more than one whistleblowing channel available to all employees in all sites where the company operates.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively.

Based on public information, there is some evidence that the company has resources available to all employees where help and advice can be sought on corruption-related issues. However, there is no readily available evidence whether the independent counselors have been properly trained in assisting employees with corruption-related issues. The company therefore scores 1.

Based on public information, there is no readily available evidence that there is a commitment to non-retaliation for bona fide reporting of corruption.