Compliance

Basic stance

The Toyota Boshoku group states in its Corporate Philosophy that the Company will promote corporate growth while fulfilling our responsibilities as a good corporate citizen. At the same time, the Company clarifies the nature and details of its compliance, its overall promotion system, as well as the scope and goals of activities on a global basis, and conducts activities under strong leadership from top management, while personnel in charge of legal affairs in each region share knowledge of issues as well as improve and strengthen compliance activities.

Strengthening compliance and initiatives for human rights

In addition to anti-bribery measures, and adherence to antitrust laws, the importance of respect for human rights is steadily increasing. The Toyota Boshoku group works to raise members’ awareness of compliance and human rights and enhance the level of implementation through various training and educational activities for officers and company members. In doing this, we strive to achieve compliance with laws and regulations as well as co-existence with local communities through respect for various cultures, values and individuality. We have a global legal risk management system and continuously take steps to increase awareness of our whistle-blowing system while promoting continuous improvements to this system.
We have established “Anything Goes Counseling Window” as an internal window for discussing and reporting workplace problems, legal violations, and internal misconduct. Additionally, we have contracted with a law office as an external window(Compliance Consultation Window). Those windows can be used by all group companies in Japan. In terms of our overseas initiatives, we have set up, and are making use of similar windows for countries outside Japan, including both within individual group companies and on a regional level. We are creating an environment in which it is easy to consult without harming the interests of the whistleblowers.

Number of serious legal violations in fiscal 2023

0

Strengthening dissemination and practical application of the Toyota Boshoku Group Guiding Principles

The Toyota Boshoku Group Guiding Principles—which is the basis of compliance, and which forcefully makes the case for the importance of ethical behavior including well-thought-out social initiatives, as well as the prohibition of collusion, cartels (agreements upon bids, prices, allocating the supplier and any item to avoid competition among with competitors), bribery and etc.—is distributed to all Company members. Great effort is made to ensure compliance through education and training, including training received upon joining the Company, promotion, and overseas transfers. Additionally, we are spreading the Guiding Principles globally via translation into foreign languages, including English and Mandarin. We strive to strengthen dissemination and practical application of the Guiding Principles at each and every workplace. We also seek to raise compliance awareness by providing training via e-learning on the topics of compliance and the Guiding Principles, as well as by undertaking various activities at companies throughout the global Toyota Boshoku group during Corporate Ethics Month.
The status of each of these initiatives is periodically monitored, discussed, and reported on under the supervision of the Board of Directors.

Compliance with competition laws

Toyota Boshoku established the Company Policy on competition laws, in which we clearly declared that the Company will not tolerate any behavior violating competition laws and Toyota Boshoku members will not commit any violations, with this declaration being shared globally.
Toyota Boshoku prepared a compliance manual and conducts training globally that includes training for executive officers and relevant departments while related internal rules have also been created at each site. The Company is therefore deepening understanding of its stance toward competition laws, which includes verifying operating conditions, and of cautionary points in conducting business operations. In addition, the Antitrust Law Compliance Rules were established mainly to regulate information exchange with competitors and this forms part of a structure to prevent infringements.

Comprehensive efforts toward anti-bribery

The Toyota Boshoku group has prepared the Anti-bribery Guideline, thereby making efforts to increase understanding of regulations in respective countries related to preventing corruption such as bribery and establishing a framework for compliance. The compliance status of the guideline is inspected globally on a regular basis and the guidelines and its implementation are continuously improved, if necessary.

Compliance with export control

The Toyota Boshoku group promotes activities in compliance with the Security Export Compliance Program (Export CP) in order to appropriately implement security export control aimed at maintaining international peace and security. This includes making decisions on whether or not products and machinery equipment exported overseas, and engineering information such as technical drawings and production technology supplied outside Japan, comply with laws and regulations related to security export control.

Education and awareness raising

Toyota Boshoku conducts training on compliance—including topics such as the Toyota Boshoku Group Guiding Principles and prohibition of business with anti-social forces (i.e. organized crime groups, etc.)—for new and promoted company members. In addition to educating relevant departments on compliance in important areas such as the competition laws and anti-bribery, we are also working to provide e-learning so that all company members can acquire the necessary compliance knowledge.
Personnel in charge of legal affairs from the Legal Division at Toyota Boshoku and RM&CH conduct workshops relating to important laws in consideration of the conditions of each country and each region.

Activities in Corporate Ethics Month

Every year, we have Toyota Boshoku Global Corporate Ethics Month on a global basis with participation by all members. During this month, efforts are made to enhance ethics mind through various activities such as confirming our corporate philosophy and the Toyota Boshoku Group Guiding Principles and reviewing members’ behavior internally and externally.

Establishing and operating a consultation and whistleblowing system

The Anything Goes Counselling Window has been set up internally as well as a reporting contact at a designated law firm externally to establish an environment in which members from group companies in Japan can easily seek advice without fear of reprisal. Members can seek consultation or report workplace problems involving issues such as labor relations, harassment, and interpersonal relationships, as well as legal violations and internal misconduct (such as excessive corporate gifting or entertaining with clients or suppliers, and preferential treatment or collusion with clients or suppliers, etc.). Initiatives are also being pursued to establish a whistle-blowing system in regions outside Japan in order to develop a global system.
Throughout fiscal 2023 we received, investigated, and took appropriate action concerning 217 reports and counseling requests from both within Toyota Boshoku and from group companies in Japan.

Number of consultations from Toyota Boshoku and group companies in Japan

• Internal consultation and reporting desk for compliance and individual concerns, such as those related to work, human relations, and family, etc.
• External consultation and reporting desk for issues such as compliance, violations of laws, regulations and company rules, and unfair practices

Structure of the Anything Goes Counselling Window and the Compliance Consulting Contact Window