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About INPEX

Business Principles and Code of Conduct

The INPEX Group has formulated Business Principles, and Code of Conduct. Our Business Principles describes how every officer and employee as individuals of the Group should perform ethically on a daily basis. Additionally, Our Code of Conduct puts our Business Principles into practice.

Business Principles

The Business Principles set forth herein are principles that, in addition to applicable laws, regulations, and internal rules, all officers and employees must be compliant with, without exception, in performing the INPEX Group’s business.

All officers and employees must have a proper understanding of these principles and, if any act that violates these principles occurs or is foreseen, they must report and consult with their superiors and related departments and take appropriate measures.

  1. We endeavor to build relationships of mutual trust with stakeholders and to contribute to society.
  2. We understand and comply with the Health, Safety and Environmental Policy of the INPEX Group.
  3. We respect human rights, do not engage in discrimination, and pay attention not to be involved in infringement of human rights.
  4. We respect employees, do not engage in harassment, and endeavor to create a sound workplace environment.
  5. We do not engage in any acts that are, or appear to be, contrary to the Company’s interests.
  6. We engage in fair and free competition, and comply with agreements on world trade.
  7. We build sound and appropriate relationships with governments and administrative authorities.
  8. We comply with relevant countries’ applicable laws and regulations on prohibitions on bribery and corruption, and engage in gift-giving and entertainment within the scope of social common sense and international norms.
  9. We respond resolutely to antisocial forces and groups and provide no benefits to them at all.
  10. We appropriately manage Company’s assets and information, and properly handle intellectual property rights.
  11. We carry out financial and accounting recording and reporting in a timely and appropriate manner.

Code of Conduct

The Code of Conduct specifies compliance rules to concretize our compliance policy, so that the INPEX Group’s officers and employees will be able to practice, based on the Group’s Mission and the CSR Principles, the Business Principles that they should comply with in their daily business operation. In addition, it summarizes the various systems, and reporting and consultation methods relating to compliance concisely.

Overseas offices and local offices of each project company, etc., will establish their own codes of conduct in accordance with this Code of Conduct, taking into account of and accommodating to the laws and customs peculiar to each country or region.

■Compliance Rules

1. We endeavor to build relationships of mutual trust with stakeholders and to contribute to society.
  1. We promote, not only our projects, but also, through cooperation with the business and economic communities, public institutions, etc., provision of employment opportunities, economic development assistance, and regional contributions (such as educational or cultural assistance, and volunteer work). By doing so, we contribute to the development of economic society in each and every country and region where the INPEX Group carries out its projects.
  2. We respect the culture, customs, and social norms of each and every country or region where the INPEX Group carries out its projects.
  3. We disclose information in a timely and appropriate manner not only to shareholders, investors, etc., but also to the entire public and we actively communicate with the society.
  4. In regard to the quality, price, safety and environmental-protection aspects of the products that we offer, such as oil and natural gas, we develop and supply high-quality products that meet the needs of customers.
  5. If any accidents or other problems relating to a product occur, we collaborate with the related departments, take prompt and appropriate actions, and work to restore trust.
2. We understand and comply with the Health, Safety and Environmental Policy of the INPEX Group.
  1. We understand and implement the matters in each item of the INPEX Group’s Health, Safety and Environmental (HSE) Policy that need to be addressed in a concrete way.
  2. Based on the HSE Management System, we implement our respective duties without fail.
  3. We do not engage in business while under the influence of alcohol. We do not use or possess any banned substances.
3. We respect human rights, do not engage in discrimination, and pay attention not to be involved in infringement of human rights.
  1. We recognize that human rights are important rights that derive from the dignity of individuals, and we respect the human rights of individuals in relevant countries.
  2. We respect international human rights codes, and we pay attention not to be involved in any act that may infringe human rights.
  3. We do not discriminate based on factors such as race, skin color, gender, age, creed, religion, birth, nationality, disabilities, or educational background.
4. We respect employees, do not engage in harassment, and endeavor to create a sound workplace environment.
  1. We respect employees’ individuality and diversity, and we give consideration to making opportunities available to employees for their own self-realization.
  2. We do not force employees to work against their will, and we do not cause children to work.
  3. With regard to the privacy information of officers or employees that is obtained in the course of business, we use the information only for business purposes, and we strictly protect and manage it so that it will not be leaked to outside parties.
  4. We do not engage in any harassment (sexual harassment, power harassment, alcohol harassment, or moral harassment) or acts that may be misunderstood as harassment.
  5. We do not inflict violent acts on officers, employees, or any other persons.
5. We do not engage in any acts that are, or appear to be contrary to the Company’s interests.
  1. Without obtaining the Company’s authorization in advance, we do not engage in any transactions with ourselves or our close relatives as the representative of, or on behalf of, the Company.
  2. When employing or supervising employees, we strive rigorously for fair, impartial, and transparent employment and supervision, and officers and employees do not engage in work related to employment or supervision of, or employment conditions for, their own close relatives.
  3. We do not engage in another occupation without obtaining the Company’s approval in advance.
  4. We do not use the Company’s assets or expenses for personal gain or in any other unauthorized manner.
  5. We do not use the Company’s information systems for personal gain or in any other unauthorized manner.
  6. Without obtaining the Company’s approval in advance, at the workplace, we do not engage in any private activities not related to our work.
  7. We do not provide benefits in relation to the exercise of a right of a shareholder of the Company or a related company.
6. We engage in fair and free competition, and comply with agreements on world trade.
  1. In relevant countries, when carrying out activities such as acquisition of mining rights, we engage in competitions fairly and freely.
  2. When carrying out activities such as procurement of materials or selection of contractors or agents, we fairly compare and assess various conditions, such as quality, price, reliability, or ability, and make the best decision.
  3. We comply with applicable antimonopoly laws or competition laws as well as other laws and regulations on promotion or protection of fair and free competition, and we do not engage in any illegal conduct such as cartels or collusions.
  4. We comply with applicable related laws and regulations, and we do not engage in any acts that unjustly harm the interests of subcontractors or other third parties, such as unfair hard bargaining (when buying) or obtrusion, refusals to receive goods, returning goods, or late payments.
  5. We do not acquire or use another person’s confidential information by means of theft, fraud, coercion, or other unlawful means. We do not acquire or use another person’s confidential information while knowing that the information was acquired by unlawful means or while knowing that it might have been acquired by such means.
  6. In relation to international trade, we comply with applicable related laws and regulations, treaties, etc., and we carry out procedures such as those for necessary permits or licenses.
  7. In relation to relevant countries, if economic sanctions are issued, we understand the contents thereof well and endeavor to be compliant with them.
7. We build sound and appropriate relationships with governments and administrative authorities.
  1. With regard to relationships with governments or administrative authorities of relevant countries, we increase transparency and build sound and appropriate relationships.
  2. Except for cases permitted under relevant laws or regulations, we do not make political donations to politicians, political bodies, or political parties.
8. We comply with relevant countries’ applicable laws and regulations on prohibitions on bribery and corruption, and engage in gift-giving and entertainment within the scope of social common sense and international norms.
  1. As an enterprise that carries out its business internationally, we comply with relevant countries’ applicable laws and regulations on bribery and corruption (including, but not limited to, the Japanese Unfair Competition Prevention Act, the U.S. Foreign Corrupt Practices Act, and the U.K. Bribery Act). We do not provide, promise, or offer money, gifts, entertainment, or other economic benefits to government employees, governments, or local public entities of relevant countries in order to unjustly obtain or retain business, or in order to receive favors for all other unjustifiable purposes or to receive business-related favors.
  2. If we anticipate that the Company’s payments to be made to agents, advisors, consultants, or other third parties will be used for an illegal approach to government employees, governments, or local public entities of relevant countries, we do not make such payments.
  3. Except for exceptions permitted under applicable relevant laws or regulations, we do not engage in what are commonly referred to as small facilitation payments (payments that are made solely for the purpose of facilitating procedures related to ordinary administrative services).
  4. In cases where we give gifts or provide entertainment to our customers or where we receive gifts or entertainment from our customers, we do so within the scope of social common sense and international norms.
9. We respond resolutely to antisocial forces or groups and provide no benefits to them at all.
  1. We do not have any relationships whatsoever with antisocial forces or groups, and if we receive any unreasonable demand from an antisocial force or group, we respond resolutely without providing any benefit at all.
  2. We do not intentionally involve ourselves in terrorist acts, money laundering, or any other organized crime, and we pay considerable attention throughout our business processes to ensure that we will not be used in these crimes.
10. We appropriately manage the Company’s assets and information, and properly handle intellectual property rights.
  1. We use the Company’s assets, whether tangible or intangible, efficiently, and we manage and preserve them appropriately to prevent damage, theft, etc.
  2. We must manage and use the Company’s information systems appropriately, and we prevent unauthorized access by third parties.
  3. We do not use personal information obtained in the course of business for non-business purposes, and we strictly protect and manage personal information so that it will not be leaked to outside parties.
  4. We strictly manage the Company’s confidential information, we use it only for business purposes, and we do not disclose or leak it to outside parties without the Company’s prior consent. If we disclose the Company’s confidential information to outside parties, we endeavor to prevent leaks by taking measures such as concluding nondisclosure agreements.
  5. With regard to confidential information disclosed by others, we use the information only for business purposes. If we conclude a nondisclosure agreement, we abide by the agreement.
  6. We do not use any undisclosed material facts regarding the Company, related companies, or customers to engage in buying or selling of these companies’ shares or other securities (insider trading).
  7. With respect to an inquiry from an outside party, regardless of whether the inquiry is made formally or informally, if a department in charge has been specified therefor, we pass the inquiry to that department without responding on our own.
  8. We recognize that intellectual property rights held by the Company are important company assets, so we use them appropriately, and endeavor to preserve the rights. With regard to results such as inventions and devices obtained in the processes of research, development, or manufacturing, we endeavor to acquire rights expeditiously, by promptly applying for patents or taking other measures.
  9. We respect intellectual property rights of others and we do not engage in any acts that infringe those rights.
11. We carry out financial and accounting recording and reporting in a timely and appropriate manner.
  1. In performing our business activities, we accurately and clearly prepare records, reports, etc., that are required under applicable relevant laws or regulations or under internal rules, etc., and we appropriately retain those records, reports, etc.
  2. Based on the applicable relevant laws or regulations or on internal rules, etc., we carry out fair accounting treatment and appropriate recording of information. We do not carry out fraudulent accounting treatments such as making false or fictitious entries or creating off-balance sheet assets or liabilities.
  3. We appropriately disclose management information, including information regarding business status or financial conditions, to shareholders, investors, etc. We increase transparency of management information and respond seriously to opinions and criticism from shareholders or investors regarding those matters.

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