Improving Training Related to Security Trade Controls
Providing Thorough Training
The Toray Group recognizes that to effectively execute security trade controls it is essential to raise employee awareness of these issues and thoroughly train staff in the necessary expertise and management procedures. In order to boost the abilities of employees in this regard, the Group conducted 13 different types of training focused on specific topics for a total of 872 employees in fiscal 2015.
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 2015, a total of 308 Toray Group employees passed the exam, bringing the cumulative total of Toray Group employees who have passed the exam to 2,809.
Executing Best Practices
The Toray Group performs risk management of security trade controls with regard to the export of products, devices, materials, and samples, as well as the transfer of technologies outside Japan. Particularly strict management is necessary for TORAYCA™ 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
To correctly identify products and technologies categorized as restricted items, export control compliance checks conducted by employees are critical. Toray has created an original template to ensure simple yet highly reliable inspection and verification. In April 2015, the Company launched a new system that ensures that employees use the template efficiently. Toray developed and conducted special training sessions for users of this new system at major Toray 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 pursued its three-year plan for developing the next security trade control system. As a result of the first stage of development, the Company launched a system in April 2015 to efficiently and unerringly conduct export control compliance checks and issue compliance certificates. In the second stage of development, Toray will develop a function to manage reviews of business deals.