Sumitomo Corporation

Based on public information, there is evidence that the Chief Executive Officer publishes statements supporting the broader ethics agenda of the company. However, although anti-corruption is a part of the company’s ethics agenda, these statements do not address anti-corruption specifically. The company therefore scores 1.

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 its mission statement and management principles within which there are some high standards of business conduct, including integrity, transparency, and openness. These standards are clearly demonstrated into company policies and codes.

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, the company joined the UN Global Compact in 2009 and remains a signatory.

Based on public information, there is evidence that the company has appointed a Board committee, the Compliance Committee, with responsibility for the compliance manual and the company’s whistleblowing system. TI also notes that ethics and anti-corruption within the company appears to fall under the umbrella of CSR; however, the remit of the CSR Committee is also not clear based on publicly available information. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda. TI notes that the Chair of the CSR Committee, Yasuyuki Abe is also Director, Senior Managing Executive Officer, General Manager, Corporate Planning & Coordination Group and appears to have overall responsibility for CSR underwhich ethics and anti-corruptiona appears to fall, at least in part. However, based on public information it is not clear that he has overall responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is some evidence that there is senior level monitoring and review of the performance of the company’s compliance agenda based on checks conducted by the Internal Auditing Department. However, there is no evidence of a major periodic review of the ethics and anti-corruption agenda. The company therefore scores 1.

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, and no evidence of improvement plans being implemented when issues are identified.

Based on public information, there is no readily available evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption.

Based on public information, there is evidence that the company has a formal risk assessment procedure; this includes the management of ‘non-quantifiable risks’ including ‘fraud or illegal acts by management or employees’. However, TI notes that anti-corruption is not mentioned specifically. The company therefore scores 1.

Based on public information, there is evidence that the company has a formal risk assessment procedure; however, its application when assessing proposed business decisions is not clear.

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 evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy terms, its stance on bribery and corruption; however, it is not clear that this stance and the consequences of breaches to this stance are made clear in contractual terms. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

Based on public information, there is some evidence that the company has an anti-corruption policy that prohibits corruption in some of its various forms. TI notes that the company has ‘19 Compliance Guiding Principles’ which cover prohibition of giving bribes, prevention of unlawful payments to foreign government officials, political contributions and conflicts of interest. However, research revealed no readily available evidence of a clear statement on anti-corruption and TI notes that only the giving of bribes is covered. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is one of zero-tolerance.

Based on public information, there is some evidence that the company’s anti-corruption policy is easily available. TI notes that the company’s full compliance manual is not publicly available and was therefore not assessed. The company therefore scores 1.

Based on public information, there is some evidence that the company’s anti-corruption policy is easily understandable and clear. The documentation available is understandable; however, TI notes that the company’s full compliance manual is not publicly available and was therefore not assessed. The company therefore scores 1.

Based on public information, there is no readily available evidence indicating who the company’s anti-corruption policy applies to. TI notes that it is only implicit that all employees are covered by the policy.

Based on public information, there is some evidence that the company has a policy on potential conflicts of interest. Conflicts of interest are one of the company’s 19 Compliance Guiding Principles outlined in the Compliance Manual; however, no further information was found about this subject. The company therefore scores 1.

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.

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.

Based on public information, there is insufficient evidence that the company has a policy that explicitly prohibits facilitation payments. TI does not that ‘prevention of unlawful payments to foreign government officials’ is one of the company’s 19 Compliance Guiding Principles; however, no further information is provided about this publicly and as such, it is not considered enough to score more here.

Based on public information, there is insufficient evidence that the company prohibits political contributions, or regulates such contributions in order to prevent undue influence or other corrupt intent. TI does not that one of the company’s 19 Compliance Guiding Principles covers political contributions; however, no further information is provided about this publicly and as such, it is not considered enough to score more here.

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 insufficient 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 affirms to try to maintain high levels of transparency around its social contributions; however, no further evidence is provided regarding this and as such, the available evidence is not considered enought to score here.

Based on public information, there is some 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 the company has a Compliance Manual and affirms to provide employees with access to other manuals via the company intranet. Given these documents are not publicly available, TI could not award a higher score here. The company therefore scores 1.

Based on public information, there is evidence that the company has a training programme that explicitly covers anti-corruption.

Based on public information, there is evidence that compliance training is provided to employees in all countries where the company operates.

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 evidence that the company has multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity. However, TI notes that no independent channels are offered. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has whistleblowing channels available to all employees in all geographies. Limited information is provided about the company’s ’Speak-Up’ system and it is not clear if email or telephone options are available.

Based on public information, there is some evidence that the company treats whistleblowers supportively. However, TI found no readily available evidence of formal and comprehensive mechanisms to ensure that whistleblowing by employees is not deterred.

Based on public information, there is insufficient evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues.

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption. However, there is no readily available evidence that disciplinary measures are applied to employees who breach this policy. The company therefore scores 1.