The Corporate Ethics Committee, which is chaired by the president, discusses policies related to corporate ethics and the employee code of conduct while simultaneously encouraging labor and management to work together in their efforts to improve CSR. The Company-Ｗide Legal Compliance Committee, which is primarily comprised of section managers, has an open operational framework, placing considerable importance on direct communication with top management. The Committee also plays a key role in facilitating various activities initiated by the employees themselves: comprehensively addressing Group-wide issues and ensuring legal compliance. At the division- and plant-level, CSR/Legal Compliance Committees also encourage each employee to practice on-site activities based on his/her awareness of related issues.
CSR/Legal Compliance Committees have also been established at every domestic subsidiary and affiliate with appointed executives and section managers in charge of legal compliance. Furthermore, a Corporate Ethics and Legal Compliance Group has been established at Toray's Affiliated Companies Division as a point of contact for legal and compliance issues.
At overseas subsidiaries and affiliates, steps are being taken to establish proactive CSR/Legal Compliance Committees. This initiative is based on a strategy coordinated by Toray's International Division, the CSR Operations Department and relevant decision-makers at each company. Companies worldwide that will undertake activities to strengthen CSR/legal compliance have been targeted and as of March 31, 2009, 57 companies were implementing such activities.

The Corporate Ethics and Legal Compliance Code of Conduct is a concrete set of standards that must be strictly observed by all Toray Group executives and employees in relation to all corporate activities both in Japan and abroad.
Violations of these rules that are upheld by an inquiry conducted by the Rewards and Sanctions Committee are penalized strictly. Proven violations also result in disclosure of relevant information, an investigation of the cause, and action to prevent a recurrence.
All Toray executives and employees (including part-time and temporary personnel) receive a copy of the Corporate Ethics and Legal Compliance Handbook, which contains the Code of Conduct with a detailed explanation. The second edition of the Handbook was published in April 2007 in response to revisions of the Toray Group's Management Philosophy, changes in applicable laws and regulations, and other new information. Toray Group also publishes similar codes of conduct, guidelines, handbooks, and other information for Japanese employees and those at overseas subsidiaries and affiliates which have CSR/Legal Compliance Committees.

Toray Group strives to ensure a thorough understanding and acceptance of its corporate ethics and legal compliance standards. One way in which it does this is by having each workplace devise and implement a range of educational activities. For example, corporate ethics and legal compliance issues are taken up at monthly meetings, study groups are organized, and public reports of instances of corporate misconduct are reviewed.
The Group has introduced a Legal Reform Information Distribution System, under which bulletins relating to amendments to laws relevant to administration within Toray Group are emailed to all Toray departments and Japanese subsidiaries and affiliates on a weekly basis. The System includes a Toray Group intranet that allows employees and managers to check items in detail. The Company-Wide CSR/Legal Compliance Bulletin Board has also been set up on the company intranet, which enhances Toray Group's ability to distribute information on legal compliance issues.

Any actions that might be subject to Corporate Ethics and Legal Compliance Code of Conduct should, in the first instance, be reported to and discussed with a direct supervisor. Should that avenue present difficulties, several alternative options have been created. These include reporting or discussing matters at consultation offices that have been established in each division, plant and labor union. Employees can also use a dedicated hotline or email service to directly report to or consult with the chairperson or secretariat of the Company-Wide Legal Compliance Committee. In addition, the Executive Committee attended by representative directors welcomes a wide range of proposals and opinions from employees.
The confidentiality of employees using these reporting and consultation channels is strictly maintained. Labor contracts and company regulations specifically prohibit discrimination against employees making reports or seeking advice, and they clearly stipulate disciplinary action against those attempting to illegally seek gains through false accusations. Current operation conditions for the internal hotline system are now being investigated, and improvements will be made as necessary based on investigation results.