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 Internal Control Committee with the Company’s president serving as chairman and all company officers as members. The Compliance Subgroup'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 Companywide 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 liaison 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.
■Toyoda Gosei Compliance Promotion System
Specific Initiatives
■Training and Educational Activities
Toyoda Gosei conducts various training and education activities with the aim of raising and solidifying compliance awareness in every employee. Trainings are conducted by level in the company and by risks corresponding to the work. The level-specific trainings target new officers, new managers, mid-level employees, new employees and others as an opportunity to spread and deepen awareness of compliance at various career stages.
Risk-specific training is conducted for specific risks. These trainings include training for transferees prior to overseas assignments, anti-trust law training for people in sales and other business departments, training for sports clubs and more. Educational tools using various case materials are also prepared, including a “Compliance Academy” that is regularly published in the company newsletter, and Compliance KY Case Studies.
List of Workshops/Education at Toyoda Gosei
| Category | Workshop name/education | Recipients | Main content | Frequency | |
|---|---|---|---|---|---|
| Workshops | For each level | Workshops/study sessions for officers | Company officers | Company law, fiduciary duty, etc. | As needed |
| New manager training | New managers | Compliance, mental preparation as a manager, anti-trust laws, bribery, etc. | 1 time/year | ||
| Legal affairs/compliance training | General employees (mid-level) | Compliance, contracts, internal company regulations, laws (anti-trust laws, bribery, etc.) | 1 time/year | ||
| Fifth-year employee training | General employees (skilled workers) | Compliance in manufacturing settings | 1 time/year | ||
| New employee training | New employees | Compliance, laws | When joining the company | ||
| For each risk | Pre-overseas assignment training | Management/General employees | Compliance precautions in other countries (anti-trust laws, bribery, etc.) | As needed | |
| Anti-trust law training | Management/General employees (sales) | Laws, internal company regulations | 1 time/year | ||
| Product liability law training | Management/General employees (technical) | Laws, internal company regulations | 1 time/year | ||
| Training for sports clubs | Management/General employees (athletes, staff) | Compliance overall | 1 time/year | ||
| Education | Compliance Academy (company newsletter) | All employees | Introduction of compliance cases | 4 times/year | |
| Compliance KY Case Studies | All employees | Theme-based cases and interpretations (100) | ― | ||
■Awareness surveys and Self-Inspections
To ascertain the degree to which compliance awareness has penetrated the company and whether there are any signs of problems, we conduct an annual compliance sustainment questionnaire survey of all employees. The results of the survey are reported to the Internal Control Committee, and measures are implemented throughout the company based on the results. Each workplace also engages in educational activities led by compliance advocates.
In the FY2022 survey, the “level of recognition and understanding of the Toyoda Gosei Guidelines for Business Ethics” was 95.6%, and the “level of recognition and understanding of compliance educational tools” was 93.4%.
Domestic and overseas group companies conduct annual self-inspections of the status of their compliance advocacy systems and major risks including antitrust and competition laws, bribery, internal control, labor, accounting, procurement, and quality. The results of the inspections are checked by each of the company’s functional departments, and a feedback report is prepared. Each Group company then makes improvements based on the report and strives for thorough compliance through the PDCA cycle.
■Initiatives for the Prevention of Antitrust and Competition Law Violations
The Toyoda Gosei Group Charter for Business Ethics states that we will conduct business activities with a spirit of “fair and free competition” (compliance with antitrust and competition laws). We have formulated the Codes of Conduct for Antitrust Law Compliance as guidelines to be followed by our employees, and are working to ensure thorough compliance by employees through training and educational activities. Antitrust law compliance manuals based on the laws of each country are prepared for the regions where Group companies are located, and initiatives are made to prevent anticompetitive acts globally.
■Initiatives to Prevent Corruption
The Toyoda Gosei Group Charter for Business Ethics clearly states that in our relationships with government agencies, political parties, and public officials, we shall strictly refrain from any behavior that could be mistaken for “back-scratching” or cronyism in the eyes of society in general, and shall strive to maintain highly transparent and sound relationships. We have also formulated Global Anti-Bribery Guidelines as a common guide for global activities, and are making efforts to prevent bribery, accounting fraud, and other forms of corruption. Education is provided to employees through various types of level-specific training and training for Group companies doing business in regions where there is high risk to prevent corruption.
■Early Detection and Correction of Problems Through an Internal Reporting System
We have established compliance consultation offices both inside and outside the company for the purpose of early detection and correction of problems related to violations of compliance, internal rules, and laws and regulations in the course of business operations. Outside lawyers are in charge of the external offices to deal with problems from an objective standpoint. This system allows all employees of the company and family members living with them to consult anonymously, and the company takes thorough measures to protect their privacy and ensure that they will not be treated unfairly because of their report. In addition to the internal consultation office of each Group company in Japan, inquiries are also handled at an external compliance consultation office that is used in common through external contacts. Overseas Group companies also have external or internal consultation services. In FY2021, as a result of making the consultation offices known to all, 42 reports and consultations were received from within the company and its domestic affiliates, mainly concerning labor management, workplace problems, and harassment. These cases were promptly investigated and appropriate corrective measures were taken to resolve the issues.
No. of Compliance Reports/Consultations (Japan)
| FY | 2018 | 2019 | 2020 | 2021 |
|---|---|---|---|---|
| No. of cases | 40 | 48 | 69 | 42 |