Compliance
Basic philosophy
Toyoda Gosei’s management philosophy states, “We promote business operations with integrity through the establishment of a system founded on thorough compliance and corporate ethics.” Together with highly ethical and fair business practices, we strive for thorough compliance in all areas based on this philosophy.
The Toyoda Gosei Group Charter for Business Ethics sets forth shared values and behavioral standards for the entire Toyoda Gosei Group. Group companies in Japan and other countries then formulate and implement their own behavioral guidelines based on the Charter. Toyoda Gosei Co., Ltd. has also established the Toyoda Gosei Guidelines for Business Ethics, which it expects every employee to follow, and has worked to familiarize all employees with these guidelines.
Compliance system
Toyoda Gosei has established the Compliance and Risk Management Committee with the Company’s president serving as chairman and all company officers as members. The Committee’s activities include reporting on and discussing the status of compliance with business ethics, laws, and regulations. The items reported and discussed in the Committee are shared with the compliance advocates selected by each department in Compliance Advocates’ Meetings so that they will be reflected in the activities of each workplace. The committee works for thorough compliance with a unified approach between management and the workplace.
Regular compliance conferences are also held with Group companies in Japan. Group companies in other countries have also established compliance committees, appointed compliance advocates, or set up other compliance systems suited to the circumstances in their region and company. Compliance activities are carried out globally in coordination with Toyoda Gosei Co., Ltd.
■Compliance
Specific efforts
■Compliance activities
Compliance KY Case Studies
Compliance Academy
Toyoda Gosei conducts ongoing education and training activities with the aim of raising and solidifying compliance awareness in every employee. This education includes level-specific and risk-specific training. The level-specific training targets newly appointed officers, newly appointed managers, mid-level employees, and new employees, and provides opportunities to familiarize them with and reinforce compliance. The risk-specific training provides training aligned with specific risks, including training for people before overseas assignments, antitrust law training for people in sales and other business departments, and training for sports clubs.
Each year, a compliance questionnaire survey is conducted for all employees to check the depth of compliance awareness and whether there are signs of violations. The results of the survey are reported to the Compliance and Risk Management Committee, and company-wide measures are implemented. Educational activities are also conducted in each workplace with compliance advocates in central roles. Educational tools based on various case studies are used in the activities of each workplace, including the “Compliance Academy” in the company’s monthly newsletter, as well as “Compliance News” and “Compliance KY Case Studies.” These activities contribute to higher levels of compliance awareness among employees.
In the FY2020 survey, 95.7% of respondents said that they had “Read the Toyoda Gosei Guidelines for Business Ethics.” In addition, 94.1% said that they had “Read compliance training tools.” These high levels show the results of educational activities.
At the same time, both domestic and international Group companies are establishing basic policies and advocacy systems for compliance each year, and carrying out their self-check for risks in their main activities. This includes things such as the status of compliance with major laws, including antimonopoly and competition laws and anti-bribery regulations, as well as in internal regulations, human resources, accounting, purchasing, and quality. The results of the self-check are confirmed by each functional department in Toyoda Gosei, and efforts are made for thorough compliance in the entire Toyoda Gosei Group with support for the kaizen and responses of each company through feedback reports.
■Efforts for the prevention of antimonopoly and competition law violations
The Toyoda Gosei Group has declared in the Toyoda Gosei Group Charter for Business Ethics that it will conduct its business activities with the aim of “Fair and free competition (compliance with antimonopoly and competition laws).” The behavioral guidelines that Toyoda Gosei expects employees to follow in various business activities, especially sales, are specified in the Codes of Conduct for Antitrust Law Compliance in the company’s internal regulations. Efforts are made for thorough compliance through training and education for employees.
Antitrust law compliance manuals based on the laws of each country are prepared for the regions where Group companies are located, and efforts are made to prevent anticompetitive acts globally. Continuing education activities are also conducted through training specifically for antitrust and competition laws, regular level-specific compliance training, and other training.
■Anti-bribery efforts
In the Toyoda Gosei Group Charter for Business Ethics, the Toyoda Gosei Group clearly that in their dealings with public agencies and political parties all Group companies will strictly refrain from acts that could be misconstrued as collusion or “back-scratching” in the eyes of society, and will strive to maintain a high level of transparency and healthy relationships. The Group has formulated Global Anti-Bribery Guidelines as a common guide for global activities, and is making efforts to prevent bribery, accounting fraud, and other forms of corruption. With level-specific training and training for Group companies doing business in regions where there is high risk, education to prevent corruption is provided to employees.
Overseas compliance training
■Early detection and correction of issues with whistleblowing system
Compliance consultation service have been set up both inside and outside the company with the aim of early detection and correction of compliance issues in company business, violations of the company’s internal rules, and legal violations. In external service, consultation is provided by outside lawyers who can deal with issues from an objective standpoint. In this system all company employees and cohabiting family members can seek consultation. In these consultations, the privacy of the people who come forward is strictly protected so that they will suffer no disadvantage from their reports.
In addition to internal consultation service in all Group companies in Japan, an external compliance consultation service shared with Toyoda Gosei has been established. At overseas Group companies, external or internal consultations service have been established. In FY2020, 69 reports or consultations were received from people at Toyoda Gosei and domestic affiliates, mainly on matters of labor management, workplace trouble, and harassment. Appropriate measures were taken after conducting investigations and confirming the facts.
Number of reports/consultations at consultation service (Japan)
| FY | 2018 | 2019 | 2020 |
|---|---|---|---|
| Number of reports/consultations | 40 | 48 | 69 |