Toyoda Gosei has established the Internal Controls Committee with the Company’s president serving as chairman and all company officers as members, whose 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 the Company-wide Compliance Implementation Council so that they will be incorporated into the activities of each workplace. The Committee works for thorough compliance with a unified approach between management and the workplace.

■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 Newsletter 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 been incorporated into the company and whether there are any signs of problems, we conduct an annual compliance implementation questionnaire survey of all employees. The results of the survey are reported to the Internal Controls Committee, and measures are implemented throughout the company, and each workplace also conducts improvement activities led by compliance advocates by referring to the departmental feedback reports of the questionnaires.

In the FY2023 survey, awareness of the Toyoda Gosei Guidelines for Business Ethics was 94%, and the implementation of activities to promote compliance and make the Guidelines known to people was 95% (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, other important laws and regulations, and on the absence of corrupt practices including bribery, as well as risks in key functions including internal controls, human resources, accounting, procurement, and quality. Based on these results, our functional departments guide each company in rule-setting and training, continuously reinforcing compliance across the Toyoda Gosei Group 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.

■Initiatives to Prevent Corruption

The Group Charter for Business Ethics clearly states that in Toyoda Gosei Group’s relationships with government agencies and political parties, we shall strictly refrain from any corrupt activities (e.g. “back-scratching,” cronyism) including bribery, and shall strive to maintain sound relationships. We have also formulated Global Anti-Bribery Guidelines as a common guide for global activities, which clearly prohibit bribery, facilitation payments, accounting fraud, and other forms of corruption, ensuring all employees are aware. For suppliers, we have developed a “Supplier Sustainability Guidelines” to prevent corrupt practices throughout the supply chain. These initiatives are reported to the Internal Controls Committee, which includes participation of directors.

■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.