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. All Toray 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 in detail. All employees are expected to be well-versed in the stipulations of this code. In fiscal 2015, this handbook underwent a sizable revision. Items were added and amended as needed to reflect laws, internal policies and manuals that had been introduced or changed since the previous revision of this handbook. The overall content of the handbook was also enhanced and expanded. The latest revision expands the scope to include group companies in Japan. Toray is currently working to cover all operations by developing guidelines and handbooks tailored to each of the countries and regions in which it operates.

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 hotline 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

Number of ethics training sessions for new executives

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

Toray posts information on CSR and legal compliance on its corporate intranet, and conducts monthly workshops at worksites where it reviews cases of external corporate misconduct. 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 2015, the training covered the Corporate Ethics and Legal Compliance Helpline. Group companies in Japan also conduct training using the same training materials.

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. Toray expects employees 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 fiscal 2015, members of the Legal & Compliance Department joined this secretariat and the department began to serve as a Helpline contact point.
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.
Toray also works to review and improve whistle-blowing systems for group companies outside of Japan. The Helpline has also been made available at certain companies and in certain regions, and Toray plans to roll it out globally, going forward.

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

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