Fiscal 2019 CSR Activity Report - Corporate Ethics and Legal Compliance

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


Toray Group Ethics & Compliance Code of Conduct

Toray Group Ethics & Compliance Code of ConductDownload (0.4MB)

The Ethics & Compliance Code of Conduct was updated in May 2020, and is an important set of rules that must be followed by every Toray Group executive and employee, including contracted, part-time and dispatched workers. They are fully informed of this code of conduct, along with the Group's internal whistle-blowing system and promotion framework for ethics and compliance.

Distribution rate of the Toray Group Ethics & Compliance Code of Conduct

Distribution rate of the Toray Group Ethics & Compliance Code of Conduct
Toray Group

Major Contents of Toray Group Ethics & Compliance Code of Conduct

  1. 1. Compliance for safety and the environment
    1. (1). Working environment
      We must protect the health and safety of ourselves and our co-workers by maintaining safe equipment, working conditions and working procedures. Besides following related laws and company rules, we should continue to take an active part in safety initiatives, with the aim of reducing workplace accidents to zero.
      Also, we should be mindful of the importance of close communication in promoting mental health in the workplace. Showing respect for others helps to create a positive and healthy work environment for all.
    2. (2). Caring for the environment
      We must follow all laws and company rules that relate to the environment, disaster prevention and the handling of chemical substances, based on the principle that we must leave the environment in a better state.
      We should strive to reduce the impact that our business activities, products and services have on the environment, while also promoting diversity and sustainable use of resources.
  2. 2. Compliance for quality
    1. (1). Safe and satisfactory products
      We must always act according to the law and in the interests and spirit of product safety to ensure that we continue to make safe and satisfactory products in response to requirements of our customers. Also, we must understand the requirements of our customers appropriately, and design, manufacture and provide products in response to such requirements. If a problem should arise, we must respond quickly.
    2. (2). Quality data management
      We must obtain, forward, store and confirm quality data in agreed ways, and correctly inform customers of the data as necessary to ensure that we continue to keep our promise to customers. We as a company do not permit quality data falsification.
  3. 3. Compliance for human rights
    1. (1). Respect for the character and individuality of employees
      We must respect the individuality of every Toray Group employee and must not engage in spiteful treatment or discrimination. We must respect the privacy of other employees and handle personal information with the utmost care.
    2. (2). Preventing harassment and discrimination
      We as Toray Group do not tolerate any form of harassment or discrimination, including sexual harassment and power harassment.
    3. (3). Respect for the human rights of all stakeholders
      We will not infringe on human rights or be complicit in in fringing on the human rights. We must respect international human rights norms and act consistently with the Toray Group Policy for Human Rights.
  4. 4. Compliance for fair business activities
    1. (1). Competing fairly
      We must not participate in cartels or other illegal concerted practices, unfair treatment of business partners, or any conduct violating competition laws of each country/region.
      We must not give or receive bribes both in relation to public officials and other business partners, or participate in any other form of corrupt practice. We must follow relevant laws and company rules in making political contributions and charitable donations.
      We must accurately communicate information about the quality, functions and price of our products and services so as not to mislead our business partners and end users.
    2. (2). Fair transaction and asset management
      All transactions including purchase, sales and payment of expense must be done appropriately in accordance with the law and general accounting principles.
      All company assets such as inventories and fixed assets must be controlled, used and maintained for business purpose only.
    3. (3). International trade control and security trade administration
      We must follow the relevant laws and regulations and comply with appropriate import and export procedures and trade controls when purchasing, exporting or importing products, machines, materials and samples, or when sharing our technology overseas, to avoid violation of sanctions imposed by the United Nations and governments such as the United States.
    4. (4). Compliance with applicable laws in general
      We must acknowledge that a violation of laws and regulations could undermine trust in the company, and comply with any and all laws and regulations including those related to;
      ・ Insider trading
      ・ Shut off of any relationship with antisocial forces
      ・ Conflicts of interest
  5. 5. Compliance for intellectual property
    1. (1). Respect for intellectual property rights of others
      We must ensure that we do not infringe intellectual property rights of others, either intentionally or as the result of insufficient investigation.
  6. 6. Compliance for information management
    1. (1). Information management
      When we become aware of confidential information owned by either Toray Group or others, we must not disclose, publicize or use such information for unauthorized purposes both during and after our employment at Toray Group.
      When handling personal information as part of our work, we must follow company policies for protecting such information and manage such information carefully and appropriately.
    2. (2). Reporting and public disclosures
      We must make disclosures as required by law and follow the Toray Group’s Information Disclosure Principles with the aim of providing full, fair, accurate and timely reports and public disclosures about our business.

Corporate Ethics and Legal Compliance Education

Group companies providing information and implementing education on major laws and regulations

■Reporting scope
Toray Group
■Target in fiscal 2019

Result in fiscal 2019


Toray Industries posts information on CSR and legal compliance on its corporate intranet. Toray Group circulates important information about legal and compliance matters that are highly relevant to its business in Japan and other countries. Group companies implement workshops to examine these matters and study cases of corporate misconduct in an effort to foster discussion in the workplace.
Since fiscal 2012, Toray Industries has provided online training courses on corporate ethics and legal compliance for all executives and employees, including contracted, part-time and dispatched workers. In fiscal 2019 the Company conducted online training on human rights issues and Toray Group Anti-Bribery Regulations issues. For human rights issues, the Company worked to raise awareness using case studies based on actual reports and consultations within Toray Group, reminding all participants that issues can occur in any department. Group companies in Japan are using these materials to implement their own training.

Expanding the Whistle-Blowing System

Toray Industries 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, the Company 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, the Company ensures that employees have access to alternative means of reporting and consulting such as via contact points at its offices, plants and labor unions or directly to the secretariat of the Ethics and Compliance Committee via phone or email.
In addition, each Toray Group company in Japan has established a Helpline contact point. Moreover, Toray Industries 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.
Each group company outside Japan has also established a Helpline contact point (internal, outside, or regional contact points). These Helpline contact points have been in operation at all companies since fiscal 2017. There were reports in several countries/regions, and Toray Group is working to resolve the issues, while carefully confirming circumstances in interviews and investigations.
Since fiscal 2016, Toray Industries has also maintained an additional whistle-blowing system for group companies to directly report serious misconduct such as violations of antitrust laws and bribery, and it is working to inform all Toray Group companies about the system.
The number of inquiries (consultations) received through the hotline and the details of the cases are reported to directors by the Ethics and Compliance Committee, which convenes twice a year.

Group companies in and outside Japan that have established a whistle-blowing system
Corporate Ethics and Legal Compliance Helpline System (Toray Industries, Inc. and its Group Companies in Japan)1
Corporate Ethics and Legal Compliance Helpline System (Toray Industries, Inc. and its Group Companies in Japan)
  1. 1 In addition to the above avenues, Toray Industries, Inc. receives reports on and addresses serious misconduct at all group companies in and outside Japan.

Implementing Internal Legal Audits

Implementing internal legal and compliance audits of group companies, group companies improving problems found in internal legal and compliance audits in the previous year (%)

■Reporting scope
Toray Group
■Target in fiscal 2019

Results in fiscal 2019


(including companies under improvement)

In fiscal 2016, Toray Group adopted a group-wide system for self-inspections and mutual internal control audits. Designated divisions of Toray Industries and designated group companies in and outside Japan must receive an internal legal and compliance audit every other year.
In fiscal 2018, Toray Industries undertook an internal legal and compliance audit of the designated divisions of Toray and the designated group companies in Japan. In fiscal 2019, the Company confirmed the improvement status of problems found in the audit, verifying that 100% of the companies had made improvements (including companies under improvement).
Audits are carried out to ensure compliance with the highly important antitrust laws, bribery regulations, whistleblowing systems, and contract signing rules.
To enhance the effectiveness of these legal and compliance audits, the methods are being revised in fiscal 2019, and the new methods will be implemented starting in fiscal 2020.