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 must be done” and “Don't do what must 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
Promotion 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.
In fiscal 2022, 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 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
Compliance consultation desks
Toyobo group provides an internal compliance consultation desk (internal reporting service) and external compliance consultation desk for all group employees. These receive reports and give consultations regarding workplace violations of laws and regulations or fraudulent acts, acts that violate anticompetition laws, corruption—including bribery and embezzlement—and bullying or harassment, and work toward early detection of these problems and toward rectifying them and preventing their recurrence. So that employees can use the consultation desks 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.
To enhance awareness of the consultation desks, in fiscal 2022, special stickers outlining how to use them were produced, and distributed within Toyobo workplaces.
Also, as the quality-related misconduct incidents that were discovered in fiscal 2021, was not reported via the internal compliance consultation desk, in October 2021, an external compliance consultation desk was established, using a specialist external service provider.
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 2022, there were a total of 62 consultations, seven of which were made through the external compliance consultation desk. The most frequent breakdown was communication and labour management, followed by suspected power harassment. 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)
| FY2018 | FY2019 | FY2020 | FY2021 | FY2022 |
|---|---|---|---|---|
| 15 | 32 | 35 | 37 | 62 |
Details of Consultations (FY2022)
| Details of consultations | Incidents |
|---|---|
| Communication and labor management | 14 |
| Suspected abuse of authority | 10 |
| Quality and data related matters | 5 |
| Questions and opinions relating to internal systems and rules, etc. | 5 |
| Matters relating to COVID-19 and/or vaccination | 4 |
| Matters relating to working hours, overwork, etc. | 3 |
| Bullying or harassment | 2 |
| Accounting | 2 |
| Inquiries regarding the reporting system / framework, etc. | 2 |
| Matters relating to occupational safety | 1 |
| Matters relating to the handling of reports | 1 |
| Suspected violations of the law | 1 |
| Others | 12 |
| Total | 62 |
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 (FY2022) |
|---|---|---|
| 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 | 62 cases handled | |
| No. of serious legal violations | 0 violations per year | 0 violations |
|
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Education and awareness-raising activities
Revision and dissemination of compliance manual
To promote understanding of compliance by all employees and make the rules well known, based on the principles declared in the "TOYOBO Group Charter of Corporate Behavior", we have created the "TOYOBO Group Compliance Manual" that explains the rules that the employees should follow in a concrete and easy-to-understand manner.
During Compliance Enforcement Month every year, we revise the manual (both the Japanese-language and English-language versions) and distribute it to group employees. We also edit the manual to produce localized versions at our overseas business sites. We familiarize all employees with the TOYOBO Group Charter of Corporate Behavior through reading the manual together at each workplace and other means.
The items in the compliance manual include anti-corruption including bribery and unfair competition prevention, safety and hygiene, and proper working hours management.
Awareness-raising activities during Compliance Enforcement Month
Video messages (covering safety, quality, and compliance) from the President and other executive officers were disseminated. We are also working to raise awareness of the compliance consultation desks, using posters and digital signage.
Holding compliance study sessions (training)
We held 10 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 37 affiliate companies. We also held them face to face in conjunction with remotely as a COVID-19 measure. With members of the relevant departments of compliance, QA, and IT acting as lecturers, a total of 1,084 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 FY2022, a total of 21 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.
Carrying out surveys
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 2022, we received 6,765 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
Toyobo group positions the prevention of corruption in all forms, such as bribery, as a priority issue for compliance. Particularly with regard to bribery, in addition to Toyobo policies and regulations, we have also decided upon guidelines that detail specific rules covering matters such as judgments and monetary standards when giving gifts and entertainment.
We ensure that these are well understood. Additionally, in order to build fair and healthy relationships with business partners, we have put in place rules regarding the accepting of gifts and entertainment. These include a requirement to decline to accept money or its equivalent, or gifts and entertainment that exceed socially accepted norms, and the introduction of a reporting system for when gifts or entertainment are received.
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.