Toyo Seikan Group Sustainability Charter /
Action Policy / Code of Conduct

In October 2024, we established the Toyo Seikan Group Sustainability Charter in place of the Toyo Seikan Group Code of Conduct. In addition, the existing Toyo Seikan Group Guidelines of Behavior were restructured into the Toyo Seikan Group Action Policy and the Toyo Seikan Group Code of Conduct.

Toyo Seikan Group Sustainability Charter

The Toyo Seikan Group Sustainability Charter is a framework of rules to be followed and practiced by companies in the Group for their management. This charter consists of four pillars which are the practice of our management philosophy, dialogues with stakeholders, the identification of material issues (materiality) and implementation of the Group’s concerted business activities. We will conduct our business activities in accordance with this charter to ensure the consistency between the sustainable development of society and our company's sustainable growth.

1. We will practice the management philosophy in pursuit of the establishment of a sustainable society.

The Toyo Seikan Group’s management philosophy is composed of the management policy, the creed and the vision. The management policy reads, “We will constantly create new and innovative value, aspire to achieve a sustainable society and contribute to people’s happiness.” Seeing this management philosophy as the Toyo Seikan Group’s basic stance concerning sustainability, we will practice it with a view toward the establishment of a sustainable society.

2. We will work to improve value co-creation through dialog and collaboration with stakeholders.

The Toyo Seikan Group’s businesses stand on the foundation of relationships of trust with different stakeholders. We will engage in dialog and collaboration with stakeholders to improve value co-creation through our businesses.

All stakeholders

We will respect basic human rights and diversity of people, and communicate and act sincerely.

*The figure can be scrolled left and right.

3. We will identify material issues and strive to solve them in accordance with the Action Policy and the Code of Conduct.

The Toyo Seikan Group identifies the priority material issues that it should address to help establish a sustainable society. We will work to resolve these issues in accordance with the Toyo Seikan Group Action Policy, which specifies the behaviors that it is recommended that all personnel working for the Company engage in, and with the Toyo Seikan Group Code of Conduct, which stipulate the rules that they should follow.

4. We will carry out concerted business activities across the Group based on the spirit of this charter.

The management executives of each company in the Group will manage with an awareness of their duty to realize the spirit of this charter. They will construct effective governance systems, make them known to the Companies ensure they are implemented by the companies in the Group. Then, we will carry out concerted business activities across the Group to increase our corporate value.

Toyo Seikan Group Action Policy

The Toyo Seikan Group Action Policy presents basic viewpoints for specific behaviors that the Group’s officers and employees are expected to practice in going about your day-to-day duties. In accordance with this action policy, we create new value and achieve a sustainable society and contributing to people’s happiness.

Toyo Seikan Group Code of Conduct

The Toyo Seikan Group Code of Conduct is ethical guidelines that the Group’s officers and employees should follow when performing their day-to-day duties. They comprise the 33 commitments that we should fulfill in four areas of quality manufacturing, fair and transparent business activities, the growth of individuals and the prosperity of society, and comprehensive risk management.

Scope of application

This Code of Conduct are the basic standards of behavior which all personnel working^*1 within the Toyo Seikan Group^*2 must implement and comply with.

• (1) full-time and part-time staff members employed by any company in the Toyo Seikan Group and temporary staff and loaned staff performing their duties under the direction and supervision of any Group company (hereinafter “Employees”) and (2) directors, executive officers, audit and supervisory board members, honorary chairpersons and counselors (hereinafter referred to as “officers”).
• The Toyo Seikan Group is Toyo Seikan Group Holdings, Ltd. and its subsidiary companies (as defined in item (iii), Article 2 of the Companies Act).

Countermeasures against violations of the Code of Conduct

Any violation of the Code of Conduct will be strictly punished based on provisions of the work regulations and other rules of the relevant group company according to the extent of the violation.

Toyo Seikan Group Code of Conduct

• Chapter 1　Quality manufacturing

  ―Quality manufacturing

  • We promise to observe the applicable laws, regulations, safety standards and the like of the countries in which we operate to ensure the safety and high quality of the products and services we provide.
  • We promise to clearly define standards and procedures for all processes from development to the sale of products and services in accordance with our internal rules, ensure their implementation, review their effectiveness and correct them as necessary.
  • We promise to take swift and proper response action in accordance with our internal rules in the event of trouble with any of our products and services, and to manage and store information on cases of trouble for making use of it for prevention of recurrence.

  Related policies and regulations

  • Toyo Seikan Group Regulations on Quality Operations

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• Chapter 2　Fair and transparent business activities

  ―Strict implementation for proper protection, management and use of information

  • We will properly manage and make effective use of the Group’s confidential information, the confidential information of our business partners and other companies and the personal information of customers, employees and other individuals and never obtain or use this information in any unauthorized manner.
  • We will strictly manage the security of information systems and never use social media or technologies in any inappropriate manner.

  Related policies and regulations

  • Basic regulations on information management
  • Regulations on information system security
  • Toyo Seikan Group Rules to Comply with the Insider Trading Regulations

  ―Fair competition

  • Never forgetting our past errors, we will comply with the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade and with competition laws in countries and regions where we do business and we will never obstruct fair competitive relationships with our competitors.
  • We promise to take necessary procedures for contacting any competitor in accordance with our internal rules in the case where there is any lawful and justifiable business reason.
  • We will never exchange information or make arrangements with any competitor on any matter related to competition, including pricing, estimated prices, price revisions, sales regions, sales quantity, production volume, costs, market shares, allocation of customers, supply and demand forecasts and willingness to receive orders.
  • We promise to take action such as objecting or leaving a place when we come across any act that could cause people to suspect that a cartel is being formed during a meeting, party, golf event or the like in which any competitor participates, then to report the details of the matter to the relevant department in the company and keep records of the event in accordance with our internal rules.

  Related policies and regulations

  • Regulations on Compliance with Antitrust Laws

  ― Proper partnerships and transactions

  • We promise to rigidly conduct proper transactions in compliance with the Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors.
  • We promise to conduct sincere, fair, equitable and responsible procurement activities in accordance with the Toyo Seikan Group Basic Policy on Procurement and to always pay attention to whether or not our suppliers understand and observe the Toyo Seikan Group CSR Guidelines for Suppliers.
  • We will observe laws and regulations relating to security trade control and will not be involved in any transaction that may hamper international peace and security and maintenance of the world order.

  Related policies and regulations

  • Toyo Seikan Group Procurement Policy
  • Toyo Seikan Group CSR Guidelines for Suppliers

  ―Prohibition of corruption and bribery

  • We will not engage in any form of corruption, including the monetary or non-monetary bribery of a public employee of any country or any business partner, embezzlement and money laundering.
  • We will not give any entertainment, money or other gifts to any business partner or receive them from them to gain or maintain an unreasonable benefit or preferential treatment.
  • We will not offer any entertainment, money or other gifts that are prohibited by the laws or regulations of countries and regions to the public employees of any country.

  Related policies and regulations

  • Group Regulations to Prevent Bribery Involving Public Officials, etc.

  ―Prohibition of conflicts of interest and confusion of official duties and private interests

  • We will not seek to achieve our own interests or the interests of any third party, such as relatives, friends or acquaintances, over the interests of the company.
  • We will properly control the company’s tangible and intangible assets and not use them for private purposes or other non-business purposes.
  • We will not engage in any political, ideological, religious or other personal activities in the workplace.

  ―Communication and disclosure of corporate information and constructive dialog

  • We promise to disclose information to shareholders, investors and other stakeholders in a timely and appropriate manner in accordance with applicable laws and regulations and with our internal rules if we are appointed to communicate corporate information.
  • We promise to endeavor to engage in two-way communication with shareholders, investors and other stakeholders.
  • We promise to properly implement accounting and tax accounting activities in accordance with applicable accounting standards, taxation laws and other similar rules.

  Related policies and regulations

  • IR Policy

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• Chapter 3　The growth of individuals and the prosperity of society

  ―Respect for human rights

  • We will understand and respect the laws and regulations of the countries where we do business and international standards for human rights and will never violate human rights in every aspect of our business.
  • We promise to understand the Toyo Seikan Group Human Rights Policy and to always pay attention to whether or not we negatively impact human rights in all the business activities we are engaged in.

  Related policies and regulations

  • Toyo Seikan Group Human Rights Policy

  ―Respect for employees

  • We promise to never discriminate against anyone because of their nationality, race, ethnicity, religion, belief, gender, age, disability or sexual orientation and to develop and promote diverse human resources.
  • We will not engage in any sexual harassment, abuse our authority over subordinates, unfairly treat workers in relation to pregnancy, childbirth or childcare, coerce people to consume alcohol or engage in other forms of harassment.

  Related policies and regulations

  • Toyo Seikan Group Human Rights Policy
  • Toyo Seikan Group Personnel Policy

  ―Comfortable workplace environment

  • We promise to provide and improve work environments that enable individual employees to balance work and childcare, nursing care, medical treatment, learning, recreational activities and other activities and to work flexibly.
  • We promise to take steps to prevent overwork and reduce overtime hours and to address the reform of workstyles in consideration of the improvement of productivity.
  • We will always conduct everyday health and safety activities, including risk prediction (kiken yochi or KY) activities and 5S activities (seiri, seiton, seiso, seiketsu and shitsuke which are sort, set in order, shine (clean), standardize and sustain (maintain through training)).

  Related policies and regulations

  • Toyo Seikan Group Personnel Policy

  ―Initiatives for the environment and society

  • We promise to work towards fulfilling the Group’s environmental targets in accordance with the Toyo Seikan Group Environmental Policy.
  • We promise to actively participate in society, the international community and local communities as a good corporate citizen and to help achieve the continuous development of these communities.

  Related policies and regulations

  • Toyo Seikan Group Environmental Policy

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• Chapter 4　Comprehensive risk management

  ―Comprehensive risk management

  • We promise to completely manage risk in preparation for acts of terrorism, cyberattacks, natural disasters and other risks.
  • We will firmly reject any unreasonable request from anti-social forces or groups that jeopardize the order and security of civic society and will have no relationship with them at all.
  • We promise to act fairly, sincerely and transparently in accordance with instructions from superiors and relevant departments in the event of a disaster, accident or other crisis.

  Related policies and regulations

  • Regulations on Risk and Crisis Management
  • Rules for Emergency Management in the Group’s Overseas Operations

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