Compliance
- Related ESG :
- S G
Management approach
Policy and approach
Based upon our corporate philosophy of Jun-Ri-Soku-Yu (adhering to reason leads to prosperity), at the core of Toyobo group's compliance activities is the idea of “Do what shoud be done” and “Don't do what shoud not be done.”
Furthermore, based on the fundamental principles stated in the TOYOBO Group Charter of Corporate Behavior, the group has summarized the rules that employees must follow in the TOYOBO Group Compliance Manual in a specific and easy-to-understand manner and works to promote understanding and widespread awareness of the rules among group employees.
TOYOBO Group Compliance Manual / TOYOBO Group Employee Conduct Standards (theme excerpts only)
(21th edition, October 1, 2022)
- Contribution to a sustainable society
- Handling of company secrets
- Handling of personal information
- Engaging in fair transactions
- Appropriate transactions with subcontractors
- Responsible procurement and logistics
- Management of export/import cargo and prevention of undeclared exports and imports
- Rules on security trade control (export management)
- Handling of gifts and entertainment (prevention of bribery)
- Handling of political donations, etc.
- Intellectual property
- Proper accounting
- Conclusion of contracts
- Rules on credit management
- Timely and appropriate information disclosure
- Prohibition of insider trading
- Respect for human rights
- Ensuring quality and safety
- Provision of information on products and services
- Appropriate handling of quality data, etc.
- Rules on research and development activities
- Customer service
- Respect for diversity in the workplace
- Prevention of harassment
- Safety and health
- Appropriate working hours management
- Business activities taking the global environment into consideration
- Promotion of social contribution
- Process safety and disaster prevention
- Duty of care on overseas assignments and business trips
- Response to anti-social forces, etc.
- Ensuring cybersecurity
- Social rules
Structure
A Compliance Committee is comprised of members from the Board of Managing Executive Officers and Controlling Supervisors. The goal is to promote group-wide compliance from a management perspective. A Compliance Promotion Committee has also been established as a sub-committee, which considers specific initiatives, and the Legal and Compliance Department promotes compliance throughout the group as a whole.
Compliance promotion cycle
P Formulate of compliance promotion action plan
- Promotion structure
- Implementation plan
D Rule dissemination and awareness raising
- Revision and distribution of the "Compliance Manual"
- Read through of "Compliance Manual"
- Compliance study sessions
- Compliance training by job level
- Information dissemination through Group newsletters
- Awareness raising through publication of case study reports
- "Compliance Enforcement Month"
C Identification of problems
- "Compliance Checks"
- "Compliance Survey"
- "Compliance Consultation centers"
- "Audits by the internal audit departments"
A Rectification of probrems
- Implementation of solutions and countermeasures for problems
- Company-wide application
- Reflection in plan for following fiscal year
Targets and KPIs
Targets
Each and every employee complies with laws, regulations, and rules and acts transparently and appropriately, fostering an ethical corporate environment and culture.
KPIs and results
| Initiatives | Targets | Results (FY2023) |
|---|---|---|
| Increase in awareness of compliance | Improvement in compliance questionnaire responses |
|
| Expansion of compliance study sessions (Managers) and various other trainings |
|
|
| Awareness and use of compliance consultation desks | Improvement in compliance questionnaire responses |
|
| Disclosure of no. of cases handled | 78 cases handled | |
| No. of serious legal violations | 0 violations per year | 0 violations |
|
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Initiatives
In fiscal 2023, the Compliance Committee convened twice, and the Compliance Promotion Committee convened four times. Working with the theme of “treating an atmosphere of raising compliance awareness,” this worked toward enhancing the effectiveness of education, training, and preventive measures.
Compliance consultation desks
Our group has established various consultation desks shown below as the internal reporting and compliance consultation desks for all employees. These desks receive reports and requests for consultation regarding legal violations, fraudulent acts, violations of competition law, acts of corruption such as bribery and embezzlement, bullying, harassment, and other issues occurring in the workplace, and work toward the early detection, correction, and prevention of these issues. To ensure worry-free use of these consultation desks, we guarantee protection of privacy (including the names of people who seek consultations), ensure that there will be no disadvantage for employees who consult or report, and accept anonymous requests for consultation.
We are making efforts to raise awareness of these consultation desks through means including the distribution of stickers with information on the desks' usage and the publication of monthly mini-studies.
Topics for consultation
- Legal violations and violations of internal regulations and rules
- Acts that violate the Compliance Manual "Corporate Code of Conduct"
- Workplace harassment
- Consultation on other compliance issues that are difficult to judge, etc.
Types of compliance consultation desks
- Internal consultation desk
- External professional service company consultation desk (corporate ethics hotline)
- External legal counsel desk
- Corporate auditor's consultation desk
In fiscal 2023, there were a total of 78 consultations, four of which were made through the external compliance consultation desk. The most frequent breakdown was communication, personal relationships, harassment, followed by Labor relations (attendance, treatment, etc.). Depending on the contents of the consultation, we implemented corrective measures, recommended disciplinary action, provided advice to the consulting parties, and answered their questions.
Number of consultations for compliance consultation desks (including internal reporting service)
| FY2019 | FY2020 | FY2021 | FY2022 | FY2023 |
|---|---|---|---|---|
| 32 | 35 | 37 | 62 | 78 |
Details of consultations (FY2023)
| Details of consultations | Incidents |
|---|---|
| Communication, personal relations, harassment | 31 |
| Labor-management relations (attendance, treatment, etc.) | 12 |
| Violations of work rules, etc. | 9 |
| Others | 26 |
| Total | 78 |
Education and awareness-raising activities
Revision and dissemination of compliance manual
Based on the principles declared in the TOYOBO Group Charter of Corporate Behavior, we created the TOYOBO Group Compliance Manual, which explains in concrete and easily understood terms the rules that employees should follow.
Every year we revise and distribute the Manual (Japanese and English versions) during Compliance Enforcement Month, while overseas sites create local versions with additional edits. We familiarize all employees with the TOYOBO Group Charter of Corporate Behavior through readings of the Manual during training at workplaces.
Items covered in the Compliance Manual include prevention of bribery, unfair competition, illegal bidding, falsification of financial records, and other corrupt acts, along with health and safety and proper management of working hours.
Awareness-raising activities during Compliance Enforcement Month
In fiscal 2023, we distributed video messages from the President concerning compliance.
We also use posters and digital signage to communicate information about the consultation desk for compliance.
Holding compliance study sessions (training)
In fiscal 2023, we held 20 compliance study sessions (training) targeting management-level personnel (general managers, managers, section chiefs,etc.) from all Toyobo business sites including headquarters, branches, production centers, and at affiliate companies. We also held them face to face in conjunction with remotely as a COVID-19 measure. With members of the Compliance Department, HR and Labor Department, and IT Department serving as instructors, a total of 1,175 employees participated in these sessions, which covered topics such as management's role in preventing misconduct, preventing harassment, and cyber security. We have also created a video of the study sessions (training) edited for general employees, and distributed this to group companies.
Various other trainings
As part of level-specific and occupation-specific training for managers, new employees, sales staff, and personnel being sent on overseas assignments, compliance education is provided. In fiscal 2023, a total of 38 various training sessions were held.
Also, we have implemented discussion-type training activities for managers, focusing on topics that are of particular importance to the company, such as safety, quality, and compliance, from fiscal 2022 onwards.
Seminar on gift giving and entertaining
Issuing case study reports
A “Compliance Mini Study,” which educates employees about cases of violation in a case study format, is issued monthly, and heads-up reports are issued irregularly based on cases that occurred within Toyobo group.
Compliance and risk assessment
During Compliance Enforcement Month held each year, we hold an anonymous questionnaire. This includes a survey on employee awareness of compliance including of ethics, safety, quality, confidential corporate information, harassment, the organizational culture, and use of the consultation desks. Through this, we confirm the status of compliance risks in the workplace.
In fiscal 2023, we received 6,566 responses from employees, and results of the questionnaire are disclosed to all employees. Details on individual problems and issues are shared with related departments in a form that does not identify the respondent—this proves useful in improving the situation and preventing problems.
Anti-corruption initiatives
Our group positions the prevention of corrupt practices, including coercion, bribery, unfair bidding, unfair competition, and falsification of financial records, as a priority issue in compliance. Regarding bribery in particular, along with policies and regulations we have also set guidelines that detail specific rules covering matters such as judgments and monetary standards when giving gifts and entertainment. We work to make these known through inclusion in the Compliance Manual and explanations given during meetings and training.
To build fair and sound business relationships with partners, we have put in place rules for the receipt of gifts or entertainment. These include a requirement to refuse money or the equivalent, or gifts and entertainment that exceed socially accepted norms, and we have introduced a reporting system for the receipt of gifts and entertainment.
In fiscal 2022, as part of our company-wide risk management activities, we implemented a legal compliance risk assessment. Based on a variety of risk scenarios, we performed assessment in terms of the two axes of the severity of impact and the likelihood of a risk occurring. The results obtained confirmed that the level of corruption risk, including bribery, was relatively low across all Sales and Marketing Divisions.
In fiscal 2023, there were no legal violations, administrative dispositions, employee dismissals, fines, surcharges, or other outcomes related to acts of corruption.
Supervision by Directors
Every year, we report to the Board of Directors on the status of our corruption prevention initiatives and other compliance activities to enable for effective supervision including oversight from external perspective by outside both directors and corporate auditors.