Compliance
Basic Perspective
"Toyo Seikan Group Sustainability Charter" "Toyo Seikan Group Action Policy / Toyo Seikan Group Code of Conduct"
Toyo Seikan Group has organized and revised the contents of the "Toyo Seikan Group Corporate Code of Conduct," which was established as a code of conduct for all officers and employees working at each company, and as of October 1, 2024, we established "Toyo Seikan Group Sustainability Charter" and "Toyo Seikan Group Action Policy / Toyo Seikan Group Code of Conduct." To widely understand and disseminate these principles, we publish them on our website and internal bulletin boards, and distribute explanatory booklets to all officers and employees so that they can check the contents at any time. Additionally, we obtain a pledge to comply with the Code of Conduct once a year from domestic officers and employees.
Following FY2024, we conducted e-learning in Japanese, English, Chinese, and Thai for employees both domestically and internationally in FY2025. Through case studies, we deepen our understanding of the Group Code of Conduct and strive for continuous and thorough awareness.
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 year 2025, the following activities were carried out at Toyo Seikan Group Holdings and group companies both domestically and overseas.
Initiatives to prevent bribery and other corruption
We regularly conduct surveys on whether domestic subsidiaries and major overseas subsidiaries are managing in accordance with regulations and guidelines. In accordance with the "Toyo Seikan Group Code of Conduct" and "Group Regulations to Prevent Bribery Involving Public Officials, etc.," we continuously conduct e-learning on anti-bribery and corruption for all managers and employees, and in fiscal 2025, we will conduct e-learning on bribery and corruption prevention for the following 17 domestic and 20 overseas companies.
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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
Toyo Seikan Group, to prevent past antitrust violations from becoming outdated, starting in fiscal year 2024, April 20 has been designated annually as "Toyo Seikan Group Antimonopoly Law Violation Prevention Day," and various measures are being implemented at each group company to ensure compliance. In fiscal year 2025, a message video by the Group Compliance Committee Chairperson was created and sent to all executives and employees of 33 domestic and 18 overseas companies.
Conducting training for newly appointed section chiefs, department managers, and division managers
The Legal Department organized and hosted training sessions for newly appointed section chiefs, department managers, and managers at major group companies. A total of 297 participants attended (including online and recorded sessions), covering topics tailored to each hierarchical level, as well as "Effective Use of Our Group's Internal Whistleblowing System." This training will be continued and improved in the future.
- New Section Chief Training (Total days: 2 days) 142 participants
Document creation techniques to avoid risks such as antitrust violations. - New Manager Training (Total days: 2 days) 115 participants
Case studies for preventing violations of antitrust laws - New Department Head Training (Duration: 1 day) 40 participants
Key management points for preventing violations of antitrust laws
Other Initiatives
- 85 executives and managers in charge of sales at major domestic group companies participated in "Antitrust Law Risk Management Training" (total of 3 days).
- 1,833 domestic employees took the e-learning course "Antitrust Law (Advanced)".
- 384 overseas employees took the e-learning course "Competition Law".
- 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)
- "Antitrust Law Compliance Card" must be carried at all times (Sales Department)
In-group training sessions and educational activities
We conducted various training sessions and awareness-raising activities for our domestic group companies.
Group Compliance Promotion Month Activities (October)
- Activities related to the group's common activity theme were carried out.
(Common theme) Reconfirming reporting lines to protect your company and yourself - Reporting line verification training conducted.
- Ethics and Legal Compliance Pledge
Reporting line verification training
We conducted a reporting line verification drill for domestic group companies to confirm whether they could report events defined in the group-wide regulations * based on the prescribed reporting lines. After the drill, each company worked to promote understanding of the group-wide regulations and reporting lines by re-disseminating the regulations and reviewing and disseminating emergency contact networks within the group and within their own company.
* Common group regulations covered in the training: Group Risk and Crisis Management Regulations, Group Regulations to Prevent Bribery Involving Public Officials, etc., Group Information Management Regulations, Group Quality Operations RegulationsLegal Training for New Group Executives
In May 2025, we invited an external lawyer to serve as an instructor for a training seminar for newly appointed executives of the group (attendance was limited to one of two days), and 28 people participated.
Topic: Duties and responsibilities of directors, auditors, and executive officers
Various training sessions and in-house education support
We hold training sessions on laws and regulations relevant to our company and our group companies, with instructors from our legal department and external experts. In fiscal year 2025, we conducted a total of 11 sessions. In addition, we continuously support internal training by making educational content aimed at compliance and legal explanations available to our group companies.
Main training themes
- Antimonopoly Act/Subcontract Act: 4 times
- Contract work: 2 times
- General compliance: 2 times
- Debt management: 3 times
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 year 2026, we will further strengthen the group's compliance with the following activity plan.
- Promotion of measures based on compliance risk maps within each group company.
- Confirmation of compliance systems with the Act on Proper Transactions by Small and Medium-Sized Enterprises within the Group Companies.
- Confirmation of the operational status of anti-bribery measures and internal whistleblowing systems in each group company.
- Promotion activities themed on "Correct understanding and proper response to laws and regulations"
- Group Compliance Promotion Month Activities
Consultation System (Internal Reporting System)
Toyo Seikan Group To promptly identify and correct all compliance violations, including unfair business practices, human rights violations, workplace fraud or harassment, legal violations, and corruption, we have established internal reporting systems at domestic and overseas group companies. To ensure that consultation desks (internal reporting systems) function effectively, we have established the "Group Compliance Consultation Desk Operation Regulations" based on the Whistleblower Protection Act, and have established systems to protect users.
Establishment of a consultation service and response flow
In addition to the internal consultation desks of each group company, we have established external consultation desks operated by independent third parties outside our group. Domestic external consultation desks are divided into two types based on the type of consultation: "Compliance" and "Harassment & Human Relations." They target executives, employees (contract employees, part-timers, part-timers, all persons working in Toyo Seikan Group regardless of employment type, such as contract employees, part-timers, temporary and temporary staff), and former employees. Overseas external consultation desks are for officers and employees.
The external consultation desk offers phone calls, 24-hour web forms, and 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 year 2025, a total of 125 reports and consultations were received by the consultation desk, both domestically and internationally. Of the reported cases, none involved serious compliance violations or human rights violations.
We respond promptly to all reported or consulted cases in accordance with our internal regulations. Furthermore, to prevent recurrence, we make appropriate changes, including establishing systems, revising relevant regulations, and adding or modifying training 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
- FY2025: 125 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 Year 2025
Toyo Seikan 's Initiatives
Toyo Seikan undertakes various initiatives aimed at adhering to the rules.
- In conjunction with Compliance Promotion Month in October, compliance consultation meetings were held at the Kuki Plant, Chitose Plant, Yokohama Plant, and Saitama Plant by the Risk and Compliance Committee Chairpersons.
- In November, we conducted compliance training for managers on the theme of "How to communicate in a way that improves interpersonal relationships."
- We conducted activities to raise awareness of reporting lines in order to clarify the reporting process.
- In conjunction with Compliance Awareness Month in October, we posted posters throughout the company urging employees to adhere to compliance regulations.
Compliance Promotion Month Notice Poster
Tokan Kogyo 's Initiatives
Tokan Kogyo undertakes various initiatives aimed at adhering to the rules.
- To foster an organizational culture that prevents harassment, we conducted training sessions at each of our locations.
- We conducted a compliance training session for managers.
- From September to November, we conducted e-learning sessions on bribery of educators and public officials in relation to antitrust laws.
- In January, Toyo Seikan Group conducted e-learning on the Code of Conduct.
- From July 2025 to February 2026, we conducted e-learning sessions on anti-bribery and competition laws for our overseas offices.
Higashikan Takayama's Initiatives
In conjunction with Compliance Awareness Month in October, Tokan Takayama provided explanations to all employees on "What constitutes workplace sexual harassment and power harassment?" and "The importance of consistently using the honorific 'san' when addressing others."
Nippon Closures 's Initiatives
Nippon Closures set the activity themes for fiscal 2025 as "Eradication of Harassment," "Strengthening Information Security," and "Re-checking the Reporting Line to Protect the Company and Yourself," and implemented initiatives to realize these goals.
- Eliminating harassment: We conducted separate in-house training sessions for managers and all employees.
- Strengthening information security: In addition to training for managers, we implemented e-learning and email response training.
- Reconfirming reporting lines to protect the company and ourselves: We conducted incident reporting training.
TOYO GLASS Initiatives
TOYO GLASS At the Shiga Factory, we held in-house human resource development training sessions in September and November aimed at preventing harassment. The training was themed 'Do not tolerate, do not cause harassment, do not leave it alive ~ Never give up on creating a workplace where people can work with peace of mind for a long time ~' and invited Mr. Takayuki Hasegawa of Create Co., Ltd. to give a lecture.
TOMATEC's Initiatives
At TOMATEC, we are undertaking various initiatives aimed at ensuring compliance.
- In conjunction with Compliance Promotion Month in October, we invited a lecturer from the Osaka Corporate Human Rights Council to conduct a compliance and human rights training session on the theme of "Human Rights in the Age of Diversity: Understanding Unconscious Biases."
- We have established a contract management log and conducted checks to ensure compliance with the terms of the agreement.
- We conducted activities to raise awareness of reporting lines in order to clarify the reporting process.
Scenes from the compliance and human rights training session
Nippon Tokan Package 's Initiatives
Nippon Tokan Package conducted report line confirmation training for employees and management under the theme "Rechecking the Report Line to Protect the Company and Yourself" in conjunction with Compliance Promotion Month in October. By conducting training assuming situations described in each common regulation, we aimed to promote understanding of the regulations and reporting lines.