Promoting Compliance

Dissemination of the Charter of Corporate Behavior and the Code of Conduct

Toyo Tires Group Code of Conduct Handbook (Fourth edition)Toyo Tires Group Code of Conduct Handbook (Fourth edition)

The Toyo Tires Group has established the Charter of Corporate Behavior as corporate action principles applied uniformly across the Group, and the Code of Conduct as the rules of conduct for each individual to follow in order to put the Charter into practice. As part of efforts to disseminate the Charter and the Code of Conduct throughout the Group, we published the Code of Conduct Handbook (third edition), which provides concrete guidance for Group members on the day-to-day conduct. We have also created pamphlets, posters and other education and awareness-raising materials in multiple languages, and have distributed them to Group companies both in Japan and abroad. Based on serious reflections on a series of issues, in fiscal 2016 we will revise the Code of Conduct Handbook and work to ensure full compliance by all directors and employees.

Compliance system

On July 1, 2015, we introduced a compliance officer system, in which the Chief Compliance Officer (CCO), Compliance Officers (COs) and Compliance Leaders (CLs) play a leading role in promoting compliance throughout the Group.

The CCO and COs have the authority to investigate, direct (including suspension of business operations and shipping) and propose compliance-related matters for the entire Group, and for their respective departments, respectively. We have also established a system whereby if a compliance problem occurs, the CCO reports it and consults with an external professional organization. The CL is responsible for assisting the CO in implementing various activities in their workplace. CLs are also required to report to their supervisors if they become aware of or suspect non-compliance.

The Compliance Committee has also been established as a consultative and deliberative body (one of the special committees) for promoting compliance.

Compliance reporting system

Compliance reporting system

Enhancement of compliance education

Compliance Leader Training at Toyo Tire Japan Co., Ltd.Compliance Leader training at Toyo Tire Japan Co., Ltd.

To raise the compliance awareness and sensitivity of each individual, compliance education is provided in grade-specific training for all levels of employees—from new employees to managers. Compliance education is based mainly on group discussions and case studies.

Our business sites and subsidiaries conduct their own unique compliance education and awareness-raising activities, under the leadership of their respective Compliance Officers.

In February 2016, a compliance training session was held at Toyo Tire Japan Co., Ltd., one of our tire sales subsidiaries in Japan, by gathering Compliance Leaders from each region. In the training session, participants were encouraged to reconsider their roles and to consider the ideal state of compliance in Toyo Tire Japan Co., Ltd. through group discussions and other activities. In March 2016, a compliance slogan contest was launched to solicit slogan ideas.

We will continue group-wide efforts to enhance compliance education and awareness-raising activities.

Implementation of Compliance Promotion Month

Since fiscal 2008, November has been designated as Compliance Promotion Month, in which various awareness-raising activities are implemented in the entire group.

Activities undertaken in fiscal 2015 include read-out sessions in which employees jointly read out the Toyo Tires Group Code of Conduct Handbook, acquisition of written covenants, and posting of awareness-raising posters.

Workplace-based group discussions are also held to identify immediate compliance risks and prevent compliance violations.

In the future, we will continue to implement the Compliance Promotion Month programs to provide an opportunity for all Group members to recognize anew the importance of compliance.

Workplace discussion at the Fundamental Technology CenterWorkplace discussion at the Fundamental Technology Center

Poster for Compliance Promotion MonthPoster for Compliance Promotion Month

Internal reporting system

With the aim of proactive prevention and early detection of compliance violations, we have been operating an internal reporting system since fiscal 2006. Reporting Hot Lines have been established both inside and outside the company, to enable not only our employees but also our business partners to report compliance incidents or concerns. Anonymous reports are also accepted.

Thanks to our efforts to promote the use of the internal reporting system through distribution of portable cards and putting up posters, the number of incidents reported has been on the rise in recent years. In fiscal 2015, a total of 28 whistleblowing reports were received, all of which were handled appropriately.

Flow of internal reporting

Flow of Internal Reporting

Respecting and utilizing intellectual property

The Intellectual Property Department is responsible for the protection and management of intellectual property.

We respect the intellectual property rights of others by conducting thorough prior-art searches. Also, by applying for and obtaining patents for newly developed technologies, we protect our own proprietary technologies and design, which we actively incorporate into our products and seek to raise brand value.

We also educate our employees to fully understand the importance of intellectual property rights, through the following training programs by hierarchical level and job type.

Training programs

Job level/Occupation Contents
New employee training Types of intellectual property, importance of protecting the company’s proprietary technologies, etc.
Technical staff training For junior-, middle- and leader-level technical staff; Importance of using patents and design rights, etc.
Sales staff training Importance of trademark rights and brand protection, etc.
Seminars for executives Recent trends, etc.

Violation of United States Antitrust Laws

In November 2013, Toyo Tires & Rubber Co., Ltd. entered into a plea agreement with the United States Department of Justice, agreeing to pay a fine of US$120 million based on charges that it had violated U.S. Antitrust Laws in connection with sales of automotive anti-vibration rubber products and constant-velocity-joint boot products.

As part of recurrence prevention measures, we established the “Guideline on Compliance with the Competition Law” as of January 1, 2014, and set up an internal reporting desk dedicated to antitrust-related matters, “Antitrust Law Hot Line.”

We also provide antitrust compliance training for sales personnel both in Japan and overseas, and acquire written covenants regarding compliance with antitrust laws from them each year. In fiscal 2015, self-inspections and special audits were conducted in the relevant departments to confirm the compliance status of the Guideline.

We will continue education/awareness-raising activities and monitoring to prevent recurrence of antitrust violations.

Fraudulent acquisition of fireproofing certification for some of our rigid polyurethane thermal insulation panels

In November 2007, fraudulent acquisition of fireproofing certification was discovered for some of our rigid polyurethane thermal insulation panels.

As of the end of June 2016, 97.5% of the replacement work (158 objects of all 162 objects) was completed. We will continue efforts to complete replacement work as soon as possible.

ACTION FOR CSR