Compliance

Materiality
Related ESG: SG SDGs16
Compliance

Compliance Management

Policy and approach

TOYOBO Group Compliance Manual

TOYOBO Group Compliance Manual

The Toyobo Group Corporate Philosophy, Jun-Ri-Soku-Yu (adhering to reason leads to prosperity), forms the basis of our compliance activities. In particular, the idea of “thinking rationally and logically, as well as respect for ethics and morals, the fundamental nature of being human.”

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. The manual has been translated into the languages of countries and regions where Toyobo and its Group companies operate, including English and Chinese, and has also been distributed to employees of overseas affiliates.

<TOYOBO Group Compliance Manual/TOYOBO Group Employee Conduct Standards (theme excerpts only)> (19th edition, November 1, 2020)

  1. Handling of company secrets
  2. Handling of personal information
  3. Engaging in fair transactions
  4. Appropriate transactions with subcontractors
  5. Responsible procurement and logistics
  6. Rules on security trade control (export management)
  7. Management of export/import cargo and prevention of undeclared exports and imports
  8. Handling of gifts and entertainment (prevention of bribery)
  9. Handling of political donations, etc.
  10. Intellectual property
  11. Proper accounting
  12. Conclusion of contracts
  13. Rules on credit management
  14. Timely and appropriate information disclosure
  15. Prohibition of insider trading
  16. Respect for human rights
  17. Ensuring quality and safety
  18. Provision of information on products and services
  19. Appropriate handling of quality data, etc.
  20. Rules on research and development activities
  21. Customer service
  22. Respect for diversity in the workplace
  23. Prevention of harassment
  24. Safety and health
  25. Appropriate working hours management
  26. Business activities taking the global environment into consideration
  27. Promotion of social contribution
  28. Process safety and disaster prevention
  29. Duty of care on overseas assignments and business trips
  30. Response to anti-social forces, etc.
  31. Ensuring cybersecurity
  32. Social rules

Relevant Policies and Guidelines, etc.

Promotion structure

A Compliance Committee is comprised of members from the Board of Corporate 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 and promotes specific initiatives.

In fiscal 2020, the Compliance Committee convened twice, and the Compliance Promotion Committee convened four times. The committees clarified their policy and standards, and debated/finalized various measures related to enhancing the effectiveness of education, training and preventive measures.

Compliance promotion cycle

Compliance Promotion Cycle

Compliance consultation centers

Toyobo provides the Complaint Handling Committee and Compliance Consultation Centers as the internal reporting service, which is for all Group employees and accepts consultations and reports on human rights. So that employees can use the consultation centers with peace of mind, we guarantee protection of privacy, including the names of people who seek consultations, and that there will be no disadvantage for employees who consult or report. This prevents as well as quickly detects workplace legal violations and other instances of wrongdoing.

  1. Users of consultation centers
    • Toyobo Group officers and employees
    • Temporary employees and employees seconded from other companies who are engaged in the Toyobo Group's business
    • Officers and employees of the Toyobo Group's trading partners
      * Retirees are also included in the above.
  2. Topics for consultation
    (1) Legal violations and violations of internal regulations and rules
    (2) Conduct contrary to the Compliance Manual
    (3) Workplace harassment
    (4) Other conduct suspected of being illegal or dishonest, etc.

Number of consultations

FY2016 FY2017 FY2018 FY2019 FY2020
12 20 15 32 35

Targets and KPI

<Targets>

Each and every employee complies with laws, regulations, and rules and acts transparently and appropriately, fostering an ethical corporate environment and culture.

<KPI and Results>

Initiatives KPI Targets (FY2026) Results (FY2020)
  • Legal compliance and reports of violations
  • Develop and maintain internal reporting system
  • Prevent corruption
  • Reinforce business resilience
  1. No. of serious legal violations
  1. 0 per year
  1. 0
  1. Improvement rate of following compliance questionnaire items
    • Whether company emphasizes compliance
    • Awareness/ease of use of compliance consultation centers
    • Awareness of “Compliance Mini Study”
    • Awareness of management compliance message
  1. Year-on-year increase
  1. No. of compliance study sessions and various other training held
  1. Disclose results
  1. 57

Initiatives in fiscal 2020

In fiscal 2020, we developed various activities to enhance awareness of compliance, based on the slogan “Sensitivity and Reporting” as well as working to clarify policies and standards and working to increase the effectiveness of education, training, and preventative measures.

Revision and dissemination of compliance manual

The TOYOBO Group Compliance Manual, which is the foundation of the Group’s compliance activities, has been revised and distributed to Group employees, who also read through the texts together in each workplace in Compliance Enforcement Month in November.

Tackling the key issue of bribery, gifts, entertainment

Policies and guidelines have been established to address bribery, gifts, entertainment. Rules concerning gifts and entertainment have also been put in place in order to build fair and healthy relationships with our clients as well as partner companies, and we have introduced a reporting system for the receipt of such gifts and entertainment.

Compliance education

Seminar on bribery/entertainment

Seminar on bribery/entertainment

We provide compliance education by job level for managers, new employees, and employees who have been promoted. We also provide education for expats and study session and seminars on specific key topics such as cyber security and bribery, gifts, and entertainment.

Hosting seminars

Members of the Compliance Department and IT Department, acting as lecturers, host seminars at nine business sites and 31 affiliated companies on topics such as preventing misconduct and cyber security. Attendees are management-level personnel from the Company and Group companies. Seminars were also given concerning gifts and entertainment, mainly for the upper management.

Issuing case study reports

A “Compliance Mini Study,” which educates employees about cases of violation in case study format, is issued monthly, and heads-up reports (occasional publication) are also issued based on cases that occurred within the Toyobo Group.

Carrying out surveys

In the November Compliance Enforcement Month, a compliance survey was carried out to identify issues related to the status of compliance and promotion activities. Improvement measures were then taken.