■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, antitrust law training for people in sales and other business departments, training for sports clubs, and more. The training programs are proactive in incorporating online training so that a large number of eligible participants can participate.

Educational tools are also prepared, including a Compliance Academy that is regularly published in the company newsletter, and Compliance KY Case Studies using various case study materials.

List of Workshops/Education at Toyoda Gosei

■Compliance 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, an annual compliance sustainment questionnaire survey of all employees is conducted. The results of the survey are reported to the Internal Control Committee, and companywide measures are implemented while each workplace undertakes improvement activities centered on a compliance advocate with reference to feedback reports for each section of the questionnaire. In the FY2022 survey, awareness of the Toyoda Gosei Guidelines for Business Ethics was 93.9%, and the implementation of activities to promote compliance and make the Guidelines known to people was 95.1% (see figures above).

Domestic and overseas Group companies conduct annual self-inspections of the status of their compliance implementation systems, status of compliance with antitrust and competition laws, bribery regulations, and other important laws and regulations, as well as risks in key functions including internal controls, human resources, accounting, procurement, and quality. The results of these inspections are reviewed by each functional department of the Company, and feedback reports are provided to support each company in making improvements and taking action so that the entire Toyoda Gosei Group is working to ensure thorough compliance by implementing the PDCA cycle.

■Initiatives for the Prevention of Antitrust and Competition Law Violations

Initiatives for the Prevention of Antitrust and Competition Law Violations The Group Charter for Business Ethics states that the Toyoda Gosei Group 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.

■Anti-Bribery Initiatives

The Toyoda Gosei Group Charter for Business Ethics clearly states that in its relationships with government agencies, political parties, and public officials, the company 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. Global Anti-Bribery Guidelines have also been formulated as a common guide for global activities, and efforts are being made to prevent bribery, accounting fraud, and other forms of corruption. Education to prevent corruption is provided to employees through level-specific training and training for Group companies doing business in high risk regions.

■Initiatives to Ensure thorough Export Controls

Toyoda Gosei has established an import/export controls system to ensure that goods, technical materials, software, and other items subject to import/export restrictions, as well as items that violate laws and regulations (such as counterfeit products), are not taken out of the country or brought into the country without proper authorization.

In addition to ensuring compliance with laws and regulations through the Security Export Control System and company regulations, the Company ensures that domestic and overseas Group companies conduct installation and check for defects through self-inspection, and provide appropriate support in cooperation with the head office and overseas control companies.