Establishing a Corporate Culture of Total Respect for Corporate Ethics and Legal Compliance

Corporate Ethics and Legal Compliance Code of Conduct and Handbook

The Corporate Ethics and Legal Compliance Code of Conduct is a strict set of standards that every Toray Group executive and employee closely follows when performing corporate activities. In the event that a violation is discovered, strict discipline is carried out in consultation with the Company's Rewards and Sanctions Committee.

At Toray and its group companies in Japan, all executives and employees, including contracted, part-time and dispatched workers, receive a copy of the Corporate Ethics and Legal Compliance Handbook, which explains expectations for proper conduct and Toray's Helpline, an internal whistle-blowing system. All employees are expected to be well-versed in the stipulations of this code.

Group companies outside Japan prepare national and regional editions of the Corporate Ethics and Legal Compliance Handbooks. Every executive and employee of group companies outside Japan receives a copy of the handbook to ensure that they are fully informed of the corporate policy.

Main Content of the Corporate Ethics and Legal Compliance Handbook

  • Carrying out proper transactions based on free, fair, and transparent market competition (compliance with Japan's Antimonopoly Act, Subcontract Act, and Act against Unjustifiable Premiums and Misleading Representations)
  • Protecting the intellectual property rights of Toray and other companies
  • Respecting local laws and regulations in all countries where Toray Group operates
  • Respecting human rights and prohibiting all forms of discrimination
  • Using proper accounting practices (complying with all relevant laws including Japan's Companies Act, all tax-related laws, and the Financial Instruments and Exchange Act)
  • Complying with Japan's Foreign Exchange and Foreign Trade Act, Political Funds Control Act, and Public Offices Election Act
  • Prohibiting any form of bribery involving stakeholders
  • Corporate Ethics and Legal Compliance Helpline, an internal whistle-blowing system
  • Framework for promoting corporate ethics and legal compliance at Toray

Corporate Ethics and Legal Compliance Education

Percentage of group companies providing information and implementing education on major laws and regulations

Reporting scope: Toray Group

Fiscal 2016 target:
80%

Result:
100%

Number of ethics training sessions for new executives

Reporting scope: Toray Group (Japan)

Fiscal 2016 target:
At least once per year

Result:
Once meeting

Percentage of group companies implementing e-learning for corporate ethics and legal compliance

Reporting scope: Toray Group (Japan)

Fiscal 2016 target:
100%

Result:
100%

Toray posts information on CSR and legal compliance on its corporate intranet, and conducts monthly workshops at worksites where cases of misconduct by other companies are reviewed to foster workplace discussion. In addition, Toray relays important information about Japanese and other national legislation that relates to its business, such as antitrust laws, labor laws, and anti-bribery rules, to all group companies including those outside Japan.

Beginning in fiscal 2012, Toray has provided online training courses covering corporate ethics and legal compliance for all employees, including contracted, part-time and dispatched workers. In fiscal 2016, the courses focused on human rights, covering the topics of abuse of power, sexual harassment, discrimination based on pregnancy, and LGBT issues. Group companies in Japan are also implementing the courses using the same materials.

Toray and group companies in Japan implemented bookkeeping and accounting compliance training, and discussed misconduct prevention at departments and group companies.

Expanding the Whistle-Blowing System

Toray established the Corporate Ethics and Legal Compliance Helpline as a whistle-blowing system in fiscal 2003 and expanded the system to include all Toray Group companies in Japan in fiscal 2010. By introducing this system, Toray expects employees first to take the initiative in managing conduct with regard to corporate ethics and legal compliance, and to consult with a supervisor as soon as an issue arises.

Recognizing that reporting or consulting with supervisors may be difficult, Toray ensures that employees have access to alternative means of reporting and consulting at each of its divisions, departments, offices and plants, as well as through the labor union. Employees can also use a dedicated hotline or email service to directly contact the secretariat of the Company-Wide Legal Compliance Committee.

In addition, each Toray Group company in Japan has established a Helpline contact point. Moreover, Toray has also created an external Helpline contact point shared by all group companies in Japan to make it easier for employees to report and consult. Group companies outside Japan have established internal contact points and started operating the Helpline in most regions.
In fiscal 2016, Toray established a whistle-blowing system for group companies to directly report serious misconduct such as violations of antitrust laws and bribery.

 

Corporate Ethics and Legal Compliance Helpline System (Toray and its Group Companies in Japan)1

Corporate Ethics and Legal Compliance Helpline System (Toray and its Group Companies in Japan)*

Implementing Legal Internal Audits

In fiscal 2016, Toray adopted a group-wide system for self-inspections and mutual internal control audits. Designated divisions of Toray and designated group companies in and outside Japan must receive a legal internal audit every other year.

In the first year of the system, legal internal audits were implemented for all designated divisions of Toray and designated group companies in Japan. The Group changed the implementation method for legal internal audits and timing for aggregating data. Consequently, the rate of improvement for deficiencies that were identified in fiscal 2016 will be disclosed in fiscal 2017.