Operation of a Trustworthy Whistleblowing System / Promoting Fair Business Practices

As a trusted member of society in the global community, corporations are strongly expected to conduct their activities with fairness and transparency. With the advancement of globalization and the increasing complexity of business operations, compliance violations, misconduct, and information security incidents can ripple beyond the Group to affect the entire supply chain and broader society, posing significant risks to corporate trustworthiness and business continuity.
Under these circumstances, ensuring thorough compliance and robust information security is not only a fundamental corporate duty but also a critical element underpinning our management foundation. The Fuji Oil Group positions the promotion of fair and transparent business conduct and the establishment of an effective information management system as key management priorities.

Corruption preventionGRI: 205-1

Preventing bribery and corruption is one of our key compliance issues. The Group is committed to eliminating such practices and has established basic regulations for preventing bribery (not externally disclosed), prohibiting such acts across the Group.
We also require business partners who conduct business on behalf of the Group to comply with the same standards. To this end, we conduct due diligence prior to entering into transactions, incorporate anti-bribery and anti-corruption clauses into contracts, and implement other measures to reduce risks throughout the supply chain.
To ensure the effectiveness of these measures, we regularly conduct educational programs and awareness-raising activities on bribery and corruption. In addition to promoting understanding through case studies in the Fuji Oil Group Business Ethics Guidelines, we provide e-learning and face-to-face training for employees. The global e-learning on preventing bribery and corruption held in FY2024 had a 96.2%^* participation rate.
In FY2025, we developed the infrastructure and provided the environment necessary for European and select U.S. Group companies to conduct their own anti-bribery and anti-corruption e-learning programs upon request.

• * Targeted at Group officers, executive officers, and employees in positions or departments closely connected to these issues

TrainingGRI: 205-2

Business Ethics Guidelines

The Fuji Oil Group Management Philosophy and Three Principles of the Code of Conduct represent the Group’s fundamental values and principles of conduct. Building on these values and principles, the Fuji Oil Group Business Ethics Guidelines provide practical guidance to help employees make appropriate decisions when confronted with specific legal or ethical issues in their daily work. The guidelines are distributed throughout the Group in both booklet and PDF formats and are available in nine languages to accommodate the legal requirements and business environments of the countries in which we operate.
By advancing the use of these guidelines, we foster a consistent awareness of compliance across our global operations.
Group companies also encourage the application of these guidelines in their daily operations through study sessions and other activities that utilize the case studies included in the guidelines. Through these initiatives, we seek to further cultivate a compliance mindset among all employees and establish fair and transparent business conduct.

Compliance training

With the aim of enhancing compliance awareness and practical skills among all Group employees, we conduct global e-learning training programs annually on key compliance issues, including major laws and regulations related to fair business transactions, such as anti-bribery, anti-corruption, and antitrust laws. These programs are targeted at Group company employees^* worldwide and are available in ten languages.
In addition, we conduct annual group training programs on relevant topics tailored to the target participants, taking into account each country’s laws and regulations, business environment, and risk profile, with the aim of strengthening our response to region-specific issues.
In FY2025, we held several training programs for relevant divisions in Japan to address amendments to the Subcontracting Act (officially, Act on Ensuring Proper Transactions Involving Specified Entrusted Business Operators) and shared related information through newsletters. We also conducted training programs on antitrust laws (anti-cartel) for relevant divisions. Outside Japan, we provided group training programs at Group companies in China, covering topics tailored to regional issues such as conflict of interest, prevention of commercial bribery and legal liability related to food safety.
Through these initiatives, we are working to further strengthen our foundation for consistent compliance across our global operations and to build highly effective training programs that address region-specific risks.

Group training sessions at Group companies in China

• * Targeted at Group officers, executive officers, and employees in positions or departments closely connected to these issues

Monitoring

In our Group, the Legal Division takes the lead in conducting compliance monitoring of Group companies worldwide in cooperation with Audit and Supervisory Committee members and Internal Audit Division, risk management and other relevant divisions.
Specifically, the Division endeavors to identify compliance risks, including cartels, bribery, and corruption, and verify the status of compliance activities. They do this by periodically distributing and collecting legal compliance sheets for internal control to all Group companies and analyzing their responses, and by conducting interviews with each Group company.
Through these initiatives, we continuously identify compliance risks associated with our global business operations based on actual conditions. By enabling the early detection and remediation of issues, we aim to further reinforce the Group’s overall control functions.

Whistleblowing systemGRI: 2-26

The Group has established a global reporting system,^* consisting of the Whistleblower Hotline in Japan and the Compliance Helpline for officers and employees at our Group companies outside Japan, to promptly identify and appropriately respond to incidents involving, or potentially involving, compliance violations, misconduct, and other issues.
Our Whistleblowing Regulations clearly stipulate proper reporting procedures and protections for whistleblowers and prohibit dismissal or unfair treatment of Group officers and employees who report through the Whistleblower Hotline or Compliance Helpline. The regulations also stipulate that those who unfairly treat or harass a whistleblower may be subject to disciplinary action in accordance with work regulations and other applicable rules.
In FY2025, the Group received 84 reports through our whistleblowing system, with no serious violations of laws or regulations identified. To further strengthen the system, we regularly conduct awareness-raising activities, including information campaigns on the use of the hotline. In addition, the Board of Directors oversees the operations of the whistleblowing system, receiving regular reports from the Legal Division on the number and status of reports, along with summaries and corrective actions taken.
Through these efforts, we aim to leverage the whistleblowing system to detect and remediate risks at an early stage and to further reinforce the Group’s overall compliance framework.

• * Compliance

  https://www.fujioil.co.jp/en/about/governance/compliance/

• Compliance > Whistleblowing Sysytem

  https://www.fujioil.co.jp/en/about/governance/compliance/

Analysis

Our Group conducts global e-learning and group training programs at each company every year to enhance employees’ compliance awareness and practical skills. Through these initiatives, we have been strengthening our foundation for consistent compliance across our global operations and continuously developing highly effective training programs that address region-specific risks.
As a result, employee compliance awareness has remained consistently high — exceeding 90% for several consecutive years. We have also continued to receive strong evaluations for fostering an open organizational culture, through initiatives such as management-led messaging on the importance of compliance at Group companies.
Moving forward, we will continue these efforts and further embed compliance across the Group through better communication, including stronger messaging from upper management.

Next steps

In FY2026, we aim to achieve again zero cases of serious violations of laws or regulations. Employee awareness of compliance remains high across the Group, supported by the compliance measures implemented to date.
Going forward, we plan to further streamline the processes for monitoring the level of compliance and assessing the actual state of our organizational culture, using engagement surveys and other tools. We also plan to work on the following priority measures to enhance the effectiveness of our programs and their implementation.