Compliance
Basic Perspective
"Toyo Seikan Group Sustainability Charter" "Toyo Seikan Group Action Policy / Toyo Seikan Group Code of Conduct"
Toyo Seikan Group has reorganized and revised the "Toyo Seikan Group Charter of Corporate Behavior/Corporate Code of Conduct," which was established as a code of conduct to be practiced and observed by all executives and employees working at each company, and established the new "Toyo Seikan Group Sustainability Charter" and "Toyo Seikan Group Action Policy / Toyo Seikan Group Code of Conduct" as of October 1, 2024. To ensure widespread understanding and dissemination of these guidelines, we have posted them on our website and on internal bulletin boards, and distributed explanatory booklets so that executives and employees can review their contents at any time. In addition, we require domestic employees to sign a pledge once a year to comply with the Code of Conduct.
In fiscal 2024, we implemented e-learning in Japanese, English, Thai, and Chinese for employees both in Japan and overseas. Through case studies, we aim to deepen understanding of the Group Code of Conduct and to ensure that it is continuously disseminated.
Related regulations
Group Regulations to Prevent Bribery Involving Public Officials, etc.
The Toyo Seikan Group Code of Conduct, which is a code of conduct that all officers and employees working at Toyo Seikan Group must practice and comply with, sets out rules prohibiting all forms of corrupt practices, including bribery of domestic and foreign public officials and business partners, embezzlement, and money laundering, in the "Prohibition of Corrupt Practices, Including Bribery" section.
To prevent corruption, including bribery both domestically and internationally, Toyo Seikan Group has established the "Group Regulations to Prevent Bribery Involving Public Officials, etc." and guidelines, and manages business activities based on these regulations. When entering into mergers, acquisitions, or joint ventures with other companies, we conduct appropriate corporate investigations to confirm that the other company has not engaged in any current or past acts that violate anti-bribery laws, etc. The "Group Regulations to Prevent Bribery Involving Public Officials, etc." and guidelines have been translated into Japanese, English, Chinese, Thai, and Indonesian, and are disseminated to all group companies both in Japan and overseas.
Regulations on Compliance with Antitrust Laws
We strongly encourage our group companies to comply with antitrust laws and other laws, and as a holding company, we have established "Rules for Compliance with Antitrust Laws, etc." to ensure that our business activities are based on fair and free competition, and we implement management in accordance with these rules.
"Declaration of Complete Separation from Cartel Involvement" Resolution
In fiscal 2019, the Board of Directors of both Toyo Seikan Group Holdings and Toyo Seikan resolved to "Declaration of Complete Separation from Cartel Involvement" regarding compliance with antitrust laws.
Declaration of Complete Separation from Cartel Involvement
The Toyo Seikan Group (the “Group”) shall conduct transactions through free and fair competition that complies
with the Antimonopoly Act (the “Act”) and shall not engage in any activity that violates the Act or that leads to a
suspected violation of the Act with any business operator that competes with companies in the Group.
Group Risk and Compliance Promotion System
To promote compliance throughout the Group, we have established the following system.
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Toyo Seikan Group 's Main Activities and Achievements
In fiscal 2024, Toyo Seikan Group Holdings and its domestic and overseas group companies carried out the following activities.
Initiatives to prevent bribery and other corruption
Following the revision of the Ministry of Economy, Trade and Industry's "Guidelines for Preventing Bribery of Foreign Public Officials," in fiscal 2022 we revised the "Group Regulations to Prevent Bribery Involving Public Officials, etc." and guidelines and conducted awareness-raising activities.
We regularly conduct status surveys at domestic and major overseas subsidiaries to ensure that management is conducted in accordance with regulations and guidelines.We also provide ongoing e-learning on anti-bribery and anti-corruption measures for all managers and employees in accordance with Toyo Seikan Group Code of Conduct and Group Regulations to Prevent Bribery Involving Public Officials, etc. for Preventing Bribery of Public Officials, etc.
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- The e-learning companies are reviewing their practices as appropriate based on their scores in the CORRUPTION PERCEPTIONS INDEX published by Transparency International.
Initiatives to comply with antitrust laws
Establishment of Antimonopoly Act Violation Prevention Day
Starting in fiscal 2024, April 20th of each year will be designated as "Toyo Seikan Group Antimonopoly Act Violation Prevention Day," and as a day to reaffirm our commitment to compliance with the Antimonopoly Act, each group company will undertake various measures to ensure compliance with the Antimonopoly Act. In the first year, the Group Compliance Committee Chairperson and the presidents of major group companies sent messages to all group executives and employees.
Response based on the results of a third-party evaluation of the Antimonopoly Act compliance system
As a result of a third-party evaluation by an external lawyer of the antitrust compliance systems of major group companies conducted in fiscal 2023, it was confirmed that the systems for compliance with the antitrust laws are being properly maintained. To further strengthen the systems, the following measures were taken at major group companies in fiscal 2024.
- Confirmation of the status of internal rules regarding contact with competitors
- Review and review of Antimonopoly Act compliance regulations
Conducting training for newly appointed section chiefs, department managers, and division managers
The Legal Department planned and hosted training for newly appointed section chiefs, department managers, and division managers at major group companies. In addition to themes tailored to each level, training on "effective use of the Group's internal reporting system" was also covered, with a total of 275 people attending (including online and recorded sessions). We will continue to hold this training and strive to improve it.
- New section chief training (2 days in total) 131 people
Document preparation techniques to avoid risks such as antitrust violations - New manager training (2 days in total) 93 people
Case studies for preventing antitrust violations - New department manager training (1 day) 51 people
Management points to prevent violations of the Antimonopoly Act
Other Initiatives
- 6,200 domestic employees take e-learning course "Antimonopoly Act (Basics)"
- The Legal Department conducted interviews with newly appointed presidents of each group company to prevent cases of violations within the group from being forgotten and to understand the status of each company's compliance system.
- Submission of a pledge regarding compliance with the Antimonopoly Act (Sales Division)
- Always carry an "Antitrust Law Compliance Card" (Sales Department)
In-group training sessions and educational activities
In fiscal 2024, we conducted various training sessions and awareness-raising activities for domestic group companies, including the following:
Group Compliance Promotion Month Activities (October)
- Conducting activities related to the group's common activity theme
(Common theme) Understanding Toyo Seikan Group Sustainability Charter /Group Code of Conduct/Group Code of Conduct - Group compliance training seminar held
- Ethics and Legal Compliance Pledge
Group Compliance Training Session
In October 2024, we held a Group Compliance Training Session, inviting an external lawyer as the lecturer, on the theme of compliance and risk management practices required in an era of change. 137 executives from each Group company attended the session.
Legal Training for New Group Executives
In May 2024, we held a training session for newly appointed Group executives (attending one of two days) with an external lawyer as the lecturer, on the theme of the duties and responsibilities of directors, auditors, and executive officers. 34 people attended.
Various training sessions and in-house education support
We hold training sessions on laws and regulations related to our company and group companies, with lecturers from the Legal Department and external experts. A total of seven sessions were held in fiscal 2024. We also provide educational content aimed at explaining compliance and laws and regulations to group companies, and continue to support in-house education.
Main training themes
- Antimonopoly Act/Subcontract Act: 4 times
- Contract practice: 1 time
- General compliance: 1 time
- Accounts receivable management: 1 time
Collection and dissemination of compliance information
In compliance awareness-raising, we create a compliance risk map, comprehensively identify and evaluate management compliance risks, and then set priorities to ensure more effective activities.We also work to raise compliance awareness throughout the entire group by sharing compliance activities at each group company and examples of accidents that have occurred in society.
Main Activity Plans
In fiscal 2025, we will further strengthen compliance within the Group through the following action plans.
- Promotion activities based on compliance risk maps at each group company
- Promotional activities under the theme of "Reconfirming reporting lines to protect the company and yourself"
- Group Compliance Promotion Month Activities
Consultation System (Internal Reporting System)
Toyo Seikan Group has established consultation hotlines (internal reporting systems) at group companies both in Japan and overseas to quickly identify and correct any compliance violations, including unfair business practices, human rights violations, workplace fraud and harassment, violations of laws and regulations, and bribery and corruption.To ensure that the consultation hotlines (internal reporting systems) function effectively, we have established the "Group Compliance Consultation Hotline Operating Regulations" based on the Whistleblower Protection Act, and have put in place a system to protect users.
Consultation desk response flow
In addition to the internal consultation hotlines at each group company, we have also set up an external consultation hotline operated by a third party independent of the group. The domestic external consultation hotlines have been set up with two hotlines, "Compliance" and "Harassment/Human Relations," depending on the type of complaints they receive, and are open to executives, employees (all people working at Toyo Seikan Group, regardless of their title, such as contract employees, part-time employees, casual employees, and dispatched employees), and former employees. The overseas external consultation hotlines are open to executives and employees.
The consultation desk accepts inquiries by phone or via web form 24 hours a day, 365 days a year, and also allows anonymous consultations.
Consultation desk reception response flow
Response after receiving a report or consultation
After receiving a report or consultation from a whistleblower, an investigation process will begin, led by the investigator, in accordance with the Group Compliance Consultation Desk Operating Regulations. The investigator will notify the whistleblower that the report or consultation has been received, the results of the investigation, and future actions. During the investigation and notification process, careful attention will be paid to preventing the disclosure of information that could identify the whistleblower or the contents of the report, and confidentiality will be strictly maintained by keeping related documents locked so that only those involved can view them.
Once the investigation is complete, the results and any issues that need to be corrected will be reported to the officer in charge of the consultation desk, and if any violations are discovered, corrective measures will be promptly implemented and any necessary measures to prevent recurrence will be taken. The whistleblower will also be promptly notified of the status of the response, and any employees involved in any misconduct will be disciplined in accordance with work regulations and other internal rules. Reports and consultations are reported to management at the Group Risk and Compliance Committee and the Board of Directors by the Group Consultation Desk Promotion Office.
User Protection
To ensure that the consultation hotline (internal reporting system) functions effectively, we have established the Group Compliance Consultation Hotline Operating Regulations, which are based on the Whistleblower Protection Act, and have put in place a system to protect users.
- We provide methods for users to use their real name or to use anonymously, and prohibit employees from searching for users.
- Toyo Seikan Group companies will protect the privacy of users and strictly safeguard confidentiality.
- It is prohibited to treat users, etc. (users and research collaborators) disadvantageously or harass them for making a report or seeking advice in good faith, or for cooperating in good faith.
- It clearly states that if any retaliatory actions are taken against users, etc., they may be subject to disciplinary action in accordance with the company's rules of employment.
- Reports and consultations made via the web (internet) are encrypted and managed, so there is no need to worry about the contents of reports and consultations being leaked to the outside.
Reporting and consultation status
In fiscal 2024, the number of reports and consultations received by the hotline totaled 111, both domestically and internationally. Of the reported cases, there were no cases that led to serious compliance violations or human rights violations.
We respond promptly to any reported or consulted cases in accordance with our internal regulations. In addition, we take appropriate measures to prevent recurrence, such as improving systems, revising related regulations, and adding or changing educational programs.
Number of consultations/breakdown of reports and consultations
Scope of calculation: Toyo Seikan Group Holdings and all consolidated subsidiaries
- FY2022: 108 cases
- FY2023: 97 cases
- FY2024: 111 cases
Initiatives to enhance consultation services (internal reporting system)
To ensure that the consultation hotline (internal reporting system) is used appropriately, we display posters about the external consultation hotline in the workplace and distribute portable cards that explain how to use the external consultation hotline. We also post information on our intranet to raise awareness and publicize the external consultation hotline among employees. Furthermore, we provide information about the internal reporting system in the "Compliance Newsletter" issued to each Group company. In training for newly appointed managers, we explain the internal reporting system, clarify its purpose and significance, and work to raise awareness of how to use it. Through these efforts, we strive to improve the effectiveness of the system.
Initiatives by Operating Companies
Initiatives for fiscal 2024
Toyo Seikan 's Initiatives
Toyo Seikan is taking various measures to ensure compliance and prevent harassment.
- In April 2024, educational materials on how to treat subordinates, junior employees, part-time workers, etc. were distributed to each business location and used for in-house training.
- In May, we held a seminar at our Osaka Plant entitled "Learn Tips for Communication in the Workplace." We invited Mr. Shibamoto from the Osaka Prefecture Corporate Human Rights Council to give a lecture on communication methods that do not lead to harassment.
- To coincide with Compliance Promotion Month in October, we solicited slogans from employees and put up posters around the company calling for compliance.
Compliance Promotion Month Notice Poster
Toyo Kohan 's Initiatives
Toyo Kohan conducts harassment prevention training for employees every year. In fiscal 2024, from September to November, in addition to watching educational DVDs, training was also conducted to reaffirm the company's internal harassment prevention guidelines and internal and external consultation hotlines.
Tokan Kogyo 's Initiatives
Tokan Kogyo has set the themes for its risk management and compliance promotion activities for fiscal 2024 as "Creating an organizational culture that prevents harassment" and "Preventing the recurrence of misconduct and violations of laws and regulations," and has undertaken a variety of activities.
With a particular focus on preventing harassment, we conducted "assertive communication training" aimed at improving communication skills at our head office, Technology Development Center, Atsugi Plant, and Komaki Plant. At our Fukuoka Plant, we conducted a group work training program called "NASA Game Experience" that focused on communication techniques, where participants learned about creating an organization and culture that prevents harassment.
Nippon Tokan Package 's Initiatives
Nippon Tokan Package has been implementing "Vibrant Workplace Creation Training" since fiscal 2023, with the aim of improving lack of communication within the organization and creating an open workplace with psychological safety. In fiscal 2024, we will again invite external lecturers to teach executives, general managers, plant managers, and group leaders about assertive communication and methods of controlling emotions through anger management, reaffirming the need to create a workplace culture where everyone can develop together.
Stolle Group Initiatives
To raise awareness of compliance, Stolle Europe Ltd. and Stolle Machinery UK Ltd. conducted online training for all employees on sexual harassment and its reporting system. Recognizing that protecting human rights and fostering a workplace culture of mutual respect is essential for sustainable growth, the training shared the importance of this and provided specific explanations of reporting procedures and organizational responsibilities.
Stolle Machinery do Brasil Industria e Comercio Equipamentos Ltda. conducted harassment and discrimination prevention training for all employees in July 2024. The training aimed to prevent harassment and discrimination in the workplace and create an environment where everyone can work with peace of mind. The importance of respect, fairness, and diversity was reaffirmed, leading to an improvement in workplace unity and a comfortable working environment.
