Compliance

Establishing a Compliance Framework for the Antimonopoly Act

We are implementing measures to establish a unified framework across the group for compliance with the Antimonopoly Act.

Establishment of Internal Regulations to Comply with Antimonopoly Act

We have established internal regulations to comply with the Antimonopoly Act in order to ensure that all group companies comply with the Act and that the Company as the holding company conducts business activities based on fair and open competition. In fiscal 2022, we updated the regulations following changes in our business environment. We also issued reminders about the increased likelihood of contact with competitors in the course of responding to environmental policies and implementing new business initiatives.

Educational Programs for Newly Appointed General Managers, Managers and Assistant Managers

The Legal Department conducted educational programs for newly appointed general managers, managers and assistant managers of major group companies. In fiscal 2022, these programs were provided both in person and online to avoid the risk of COVID-19 infection. There were 302 participants for the programs. They learned about the topics related to the themes for each level as well as about the effective use of the Group’s internal reporting system. We will continue to conduct these programs to further enhance compliance.

• Program for newly appointed assistant managers (3-day session), attended by 135 participants

• Program for newly appointed managers (2-day session), attended by 111 participants

• Program for newly appointed general managers (1-day session), attended by 56 participants, including participants in the video-recoded program

Other Activities

• On-site learning course on risk management under Antimonopoly Act, provided for 41 officers in charge of the sales of major domestic group companies
• E-learning course on Antimonopoly Act (Advanced), conducted with 1,717 attendees from sales departments across major domestic group companies
• E-learning course on competition law, provided for 438 managers from overseas subsidiaries
• Hearings planned and conducted by the Legal Department for newly appointed presidents of group companies to prevent the experiences of violation from being forgotten and to grasp the status of compliance framework of group companies.
• Written pledge to comply with the Antimonopoly Act submitted by all staff in sales departments
• Constant carrying of Antimonopoly Act Compliance Card(Sales department)

Prevention of Bribery and Corruption

• The Toyo Seikan Group Guidelines of Behavior, which are common standards for all officers and employees in the Group to adhere to, establish rules to prevent all forms of corruption. This includes bribery involving domestic and foreign government officials, customers, or suppliers, as well as misappropriation, and money laundering.
• To manage the risk of bribery and corruption, including commercial bribery, we have established the Group Regulations to Prevent Bribery Involving Public Officials and accompanying guidelines.
• The regulations and guidelines have been translated into English, Chinese, Thai and Indonesian to be disseminated to all group members inside and outside Japan.
• n fiscal 2022, in response to the Ministry of Economy, Trade and Industry’s revision of the Guidelines for the Prevention of Bribery of Foreign Public Officials, we updated our regulations and guidelines. We also raised employees’ awareness to ensure their full understanding of these revised regulations and guidelines.
• We checked the status of management of domestic subsidiaries and major foreign group companies, and confirmed that they were properly managing bribery and corruption risks in accordance with the regulations and guidelines.
• Since fiscal 2018, we have also been conducting e-learning programs on the prevention of bribery and corruption for all managers and employees, pursuant to the Guidelines of Behavior and the bribery prevention regulations.
• In fiscal 2022, we provided an e-learning course on bribery involving public officials for 2,434 managers from domestic major group companies; meanwhile, an e-learning course on anti-corruption law was attended by 445 managers from overseas subsidiaries.
• Based on the Guidelines of Behavior and the bribery prevention regulations, we will continue to conduct our e-learning programs on the prevention of bribery and corruption for domestic and overseas group companies

• The list of group companies joining the e-learning program may change according to the scores of the Corruption Perceptions Index released by Transparency International.

Promoting Understanding of the Group’s Code of Conduct and Guidelines of Behavior

Month-Long Group Compliance Promotion Campaign (October)

Structure of Our Internal Reporting System

Protection of Hotline Users

Under the Rules for Management of Group Compliance Whistleblowing and Consultation System, we ensure protection of hotline users by enforcing the rules below and informing the whole Group of our protection approaches. The English, Thai and Chinese translations are also available for employees of foreign group companies to correctly understand the rules.

• Those who access these hotlines can either reveal their real names or remain anonymous (provided that the person who anonymously contacted the hotline cannot receive feedback, including confirmed facts and investigation results).
• All companies in the Toyo Seikan Group shall strictly protect the privacy and confidentiality of individuals who accessed the hotlines.
• No one will suffer disadvantages as a result of using any of the hotlines unless the use was for illicit purposes.
• Any act of retaliation against individuals who used the hotlines for reporting or consultation will not be tolerated.
• Since the details of reporting and consultation via website are managed with encryption, any user can access the website without concern about leakage of information.

Enhancing the Internal Reporting System

In Japan, to allow group members to easily access the reporting system, it is divided into internal and external channels, and each channel has the contact points for reporting on “corporate ethics” and “harassment and Interpersonal relations.” The domestic service is available to officers, employees (including contract employees, part-time workers, temps and employees of contractors), and former employees. Meanwhile, the reporting system for overseas group members is intended for officers and employees.

During fiscal 2021, there were 127 contacts in Japan and overseas, none of which would lead to material noncompliance or human rights violation.

We also formulated the Rules for Management of Group Compliance Whistleblowing and Consultation System on April 1, 2021 to establish and operate the internal reporting system in a unified manner throughout the Group.
When there is a contact to the system, we promptly respond to it in accordance with our internal regulations. We also continuously improve the system, revise relevant regulations, and add and change learning menus in our educational programs in order to prevent recurrence.

We have been promoting employees’ better understanding of the reporting system with posters and self-check cards.

With the Compliance Newsletter issued to group companies, we share information on the internal reporting system with all members to increase their understanding of the significance and purposes of the system and how to use hotlines, aiming to improve its effectiveness.

Legal Training Program for Newly Appointed Group Officers

In May 2022, we invited an external lawyer as a lecturer to conduct a training program designed for newly appointed officers of the Group. There were 27 participants in the program (attending one of two days).

Group Compliance Training Seminar

Various Training Programs and Support for Internal Education

During fiscal 2022, we held 27 training sessions on laws and regulations pertinent to our company and the group companies. These sessions were led by our Legal Department staff and external experts.
In addition, we have created and shared educational content aimed at explaining compliance and legal matters across all group companies, as part of our ongoing commitment to support internal education.

Main themes

Collecting and Sharing Compliance-Related Information

To promote compliance awareness, the Legal Department has created a compliance risk map to comprehensively identify and assess compliance risks in business management. We then prioritize these risks to ensure more effective efforts. We are also working to share information about group companies’ compliance activities and accidents and events occurring in society to enhance compliance consciousness throughout the entire group.

Preventing Harassment and Abuse

We have established a policy regarding the prohibition of discriminatory speech and behavior and harassment in the Toyo Seikan Group Guidelines of Behavior and clearly prohibit harassing speech and behavior in the work rules. We have also set up a group-wide consultation service dedicated to harassment and interpersonal relations to provide consultations and address a range of concerns.
In fiscal 2020 and 2021, we provided e-learning anti-harassment programs for approximately 15,000 employees (managers, leaders and general employees) from 41 group companies to allow them to recognize the risks and causes of harassment and abuse and to help change their behavior. The program for managers focused on how to deal with harassment that has occurred or been reported and what preventive measures to be taken, while that for general employees focused on learning typical cases and countermeasures. With all employees, regardless of generation, raising their awareness and sharing a common understanding of harassment problems, the Group is aiming to create a corporate culture without harassment and abuse.

Compliance Training

Nippon Closures has been conducting ongoing compliance training. In fiscal 2022, from November to December, we conducted training for managers at various locations within the company. The training covered a wide range of topics, including the prevention of power abuse, precautions for using social media and eradication of drunk driving. Going forward, we will continue to raise awareness among our employees’ about social norms and legal compliance, in collaboration with Group companies.

Promoting the Penetration of Power Harassment Prevention Guidelines

In fiscal 2020, the Toyo Kohan group set the Toyo Kohan Group Power Abuse Prevention Guidelines. In April 2022, Toyo Kohan established its corporate philosophy, which states that the company values “acting with good ethics” and “embracing diversity and mutual respect.” Based on the philosophy, the company has been engaged in the creation of a safe and comfortable workplace without power abuse.
In fiscal 2022, based on the results of an internal survey conducted in the past, we focused on “building a workplace that deepens mutual understanding among employees” and “providing opportunities to learn about power harassment”, which were frequently mentioned as effective ways to eliminate power harassment. We conducted power harassment prevention training, which included watching a DVD on power harassment prevention and explaining the contents of the guidelines. In addition, we conducted the Reflection Round Table®* program in the headquarters area where remote work is predominant. The program targets three levels: department heads, group leaders, and members, with the aim of activating communication, deepening mutual understanding, and changing behavior based on this.
We recognize power abuse as a serious issue in our business activities, and will continue to work persistently to eliminate it.

• "Reflection Round Table®” is a training program that allows you objectively analyze your own behavior through introspection and dialogue, and acquire more sound and thoughtful management.