Commitment by the Top Management
We recognize that the commitment by the top management toward the maintenance and strengthening of compliance is important. President and CEO annually issues a message that appeals the importance of compliance to Directors and employees of the whole Group Companies.
Codes and Manuals
To ensure that the execution of duties complies with laws and regulations, we formulate Code of Conduct, Compliance Manual, and other related rules. Furthermore, all Directors, Executive Officers and employees annually submit written oaths and comply with them.
We organize the Compliance Committee headed by Chief Compliance Officer (CCO), and endeavor to operate and monitor the educational and promotional campaigns on compliance and the compliance system in the following procedures.
(1) The Compliance Committee plans the educational and promotional campaigns out, which is executed mainly by the Compliance Department, which is its Secretariat, and the division/department heads.
(2) Division/Department heads arrange and confirm the laws and regulations to comply with in their execution of duties, develop and revise the work procedures and check lists, and strive to fully comply with them.
(3) The Compliance Committee receives reports on compliance violation cases and reviews the situation to cope with them.
(4) The Compliance Committee confirms and evaluates the state of execution of the above, and the CCO periodically reports the results to the Board of Directors and the Corporate Management Meeting. The Board of Directors, based on the reports, annually conduct a management review.
Internal Whistleblowing System
We develop internal whistleblowing system concerning compliance such as the violation of laws, regulations and others as a system to ensure appropriate reporting to the Board of Directors and the Audit & Supervisory Board. For this purpose, we establish points of contact for consultation and internal whistleblowing in and outside of the Company, and also develop internal rules to strictly prohibit any disadvantageous treatment of those who provided such information.
◇Number of cases of internal reporting and consultation in FY2019: 9 (1 case of legal violation / corruption; 8 cases of harassment)
Number of cases in FY2018: 16
■TOYO’s Consultation & Reporting Counters
-General Manager of Compliance Department
-General Manager of Human Capital Development Department
(For harassment matter)
■External Counter of Consultation & Reporting Okamura Law Office (TOYO’s Advisory Law Office)
Mr.Tetsuro Kitao : email@example.com
Ms.Takako Miyoshi : firstname.lastname@example.org
10th floor 1005 Marunouchi Mitsui Building Marunouchi 2-2-2, Chiyodaku, 100-0005 Tokyo
* For consultation and report concerning compliance, you may contact with either real name or anonymous. In case of contact with your real name, the name or other information that may identify the reporter shall be strictly kept confidential.
Training on Compliance
We endeavor to boost awareness about compliance with promotion activities by implementing group training, e-learning, mini tests and in-company lectures on compliance
◇Results of training in FY2019
Training for new recruits, newly appointed officers (on compliance, and security and export control)
Participants of lectures (on prevention of harassment): 260 persons
Number of e-Learning trainees (those in this business year): 33 persons
Total participants of mini tests on compliance: 1,440 persons
Approach to the Bribery Risk
We are working to enhance and expand our program for preventing the bribery of foreign public officials. We establish Compliance Committees at respective overseas locations and assign their persons responsible to ensure the deployment of integrated compliance activities as TOYO Group, and establish a system to facilitate constant exchange of opinions with our Compliance Department.
Audit & Supervisory Board Members audit the execution of duties by Directors regularly and from time to time, whether there is any major fact that violates any laws, regulations and the Articles of Incorporation, and whether the business decision made by the Board of Directors and others is fair from the viewpoints of good manager’s duty of care and duty of loyalty of Directors or not. Audit & Supervisory Board Members and Internal Auditing Division also audit the situation of compliance of each department and report the results to the Board of Directors and others.