Corporate Ethics and Legal ComplianceImproving Security Trade Controls

Providing Thorough Training

The Toray Group recognizes that the reliable execution of security trade controls requires employees to be equipped with the necessary knowledge and management procedures and to follow those procedures. In order to boost the abilities of employees in this regard, the Group conducted 16 different types of training focused on specific topics for a total of 14,108 employees in fiscal 2016.

Furthermore, the Toray Group has been arranging for employees to take an exam authorized by the Center for Information on Security Trade Controls in Japan to test their abilities related to imports and exports governed by security trade controls. In fiscal 2016, a total of 245 Toray Group employees passed the exam, bringing the cumulative total of Toray Group employees who have passed the exam to 3,018.

 

Practically Addressing Risks

The Toray Group performs risk management of security trade controls with regard to the export of all products, devices, materials, and samples, as well as the transfer of technologies outside Japan. Particularly strict management is necessary for TORAYCATM carbon fiber and its composite materials, semiconductor coating agents, and water treatment membranes, which are listed as restricted items requiring export permission from the Japanese Minister of Economy, Trade and Industry.

The following measures to enhance risk management associated with security trade controls have been implemented based on conditions in and outside of Japan.

 

(1) Enhanced employees' capacity for accurate judgment

A new system that ensures the reliability of export control compliance checks has already become well-established. To further enhance the accuracy and efficiency of the checks conducted by employees, Toray reviewed past filings and identified issues at the division level. Additionally, Toray reviewed its specialized training program and implemented practical training at its main offices and plants.

(2) Conducted regular audits

Toray carried out paper audits and onsite audits of group companies, and provided individualized guidance based on the results to help group companies make improvements.

(3) Enhanced information sharing and reporting

Toray integrated and centralized information on concerns such as suspicious trade inquiries, reported or consulted with the appropriate authorities as required, and took the appropriate measures. The Company also shared suspicious trade information at various company meetings, and took steps to improve its risk management.

(4) Improved inspection systems

Toray is pursuing a three-term plan for developing the next security trade control system. The Company launched a new system for conducting export control compliance checks and issuing compliance certificates efficiently and unerringly in April 2015, and it also added a system to manage reviews of business deals in March 2017.