CSR Activity Report (CSR Guideline Activity Reports) - Ethics and Compliance

Establishing a Corporate Culture of Total Respect for Ethics and Compliance

Toray Group Ethics & Compliance Code of Conduct

The Ethics & Compliance Code of Conduct was updated in June 2023, 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. This code of conduct is subject to periodic review by the Ethics and Compliance Committee, which is chaired by the president with membership comprising the Group's vice-presidents, and the results are reported to the directors. All of the employees are fully informed of this code of conduct.

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

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

Toray Group translates and distributes its code of conduct in eight languages (English, Chinese, Korean, Thai, Malay, Indonesian, Spanish, and Hungarian) to ensure that Toray Group employees around the world understand the content.

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 infringing 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.

Major violations of laws or ordinances

Number of major violations of laws or ordinances

■Reporting scope
Toray Group
■Target in fiscal 2022

Result in fiscal 2022


Ethics and Compliance Education

Group companies providing information and implementing education on major laws and regulations and other compliance-related matters (%)

■Reporting scope
Toray Group
■Target in fiscal 2022

Result in fiscal 2022


Toray Industries posts links to 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 Toray ethics and legal compliance for all executives and employees, including contracted, part-time and dispatched workers. In addition to training designed to instill an understanding of the Ethics and Compliance Code of Conduct and whistleblowing system, the Company sets specific course themes for each year on such topics as anti-corruption/bribery, human rights, and harassment. In fiscal 2022, the Company provided training on the Toray Group Ethics & Compliance Code of Conduct and the Group’s whistleblowing system. Participation in this course was 96.4% of targeted employees. In a survey of participants who took part in the online course, 60.8% responded that they “understand” the content of the Ethics and Compliance Code of Conduct, and 38.9% responded that they “understand to some extent.” Toray Industries will continue to disseminate information and provide education to ensure that ethics and legal compliance is even more fully understood moving forward. Group companies in Japan are using these materials to implement their own training.

In fiscal 2022, in response to inappropriate actions relating to UL certification, the Company provided thorough company-wide compliance education that included an introduction to the case, analysis of the causes, and countermeasures to address the issue.

Expanding the Whistleblowing System

Toray Industries established the Corporate Ethics and Legal Compliance Helpline as a whistleblowing system in fiscal 2003 and expanded the system to include all Toray Group companies in Japan in fiscal 2010. In 2022, the Company revised its internal rules in accordance with revisions to the Whistleblower Protection Act that went into effect in June of the same year. Executives, employees who have been retired for a year or less, and business partners were added as users of the whistleblowing system, and a provision regarding the designation of those who respond to reports to the whistleblowing system (whistleblowing report responders) was also added.
Further, Toray Industries endeavored to encourage greater use of the whistleblowing system by, for example, providing examples of how to utilize the system.
The Company ensures that employees have access to alternative means of reporting and consulting such as via internal contact points at its offices and plants or directly to the secretariat of the Ethics and Compliance Committee via email or a dedicated form on the corporate intranet.
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. Toray Group has worked to resolve reported issues, while carefully confirming circumstances in interviews and investigations, based on the laws, customs, and other regulations of each country and region.
Since fiscal 2016, Toray Industries has also maintained an additional whistleblowing 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.
In fiscal 2022, Toray Industries and its group companies received a total of 97 whistleblowing reports and consultations, with seven cases resulting in disciplinary action. The facts were investigated with complete discretion to protect against any risk of negative impact on the individual reporting to or consulting with the hotline. If a problem was identified, efforts were made to solve the problem and measures were taken in accordance with the internal rules of each company, such as employment rules.

Number and Subject of Reports (Consultations) Across Toray Group
Number and Subject of Reports (Consultations) Across Toray Group

The number of reports (consultations) and the details of the cases are reported to the Board of Directors and the Board of Corporate Auditors by the Ethics and Compliance Committee.

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

■Reporting scope
Toray Group
Audits: Conduct at Toray Industries, Inc. and its group companies in and outside Japan
Percent that improved: 100% for all audits by the following fiscal year

Result in fiscal 2022

Improvement rate: 100%

(No problems found in the previous year's audit)

In fiscal 2022, Toray Industries undertook an internal legal and compliance audit of designated divisions of Toray Industries and designated group companies in Japan to ensure compliance with the highly important antitrust laws, anti-bribery regulations, insider trading regulations, and contract signing rules. Although no inappropriate transactions were found under any of the audit items, the Company plans to continue working to ensure thorough awareness of legal compliance through educational activities and the dissemination of information in media such as company magazines.

Click here for the main initiatives for CSR Guideline 2, “Ethics and Compliance” in CSR Roadmap 2022.