- Spreading Awareness of the Charter of Corporate Behavior and Code of Conduct
- Compliance Promotion System
- Setting Compliance Rules at Each Group Company
- Enhancing Compliance Education/Training
- Compliance Promotion Month Activities
- Internal Reporting System
- Complying with Antimonopoly Laws
- Preventing Anti-bribery
- Respecting and Utilizing Intellectual Property
Spreading Awareness of the Charter of Corporate Behavior and Code of Conduct
The Toyo Tires Group compiled not only the “Toyo Tires Group Charter of Corporate Behavior” as corporate action principles applied uniformly across the Group in order faithfully conduct business activities but also the “Toyo Tires Group Code of Conduct” as rules of conduct for each director and employee to put the charter into practice. In FY 2016, we revised the “Code of Conduct Handbook”, a concrete manual on the code of conduct, and released the fourth edition, which includes items necessary for responding to the demands of a more diverse society. This was distributed to all directors and employees, including those at group companies in Japan, and understanding of various issues including the latest cases was deepened by having worksites read it through together. We have also created material in multiple languages, including English and Chinese, for overseas offices and will spread awareness of the material throughout the Group.
Code of Conduct Handbook (fourth edition) (from left, Japanese, English, and Chinese versions)
Compliance Promotion System
In addition to establishing the Compliance Committee, one of the special committees that debates and examines issues related to promoting compliance in the Group, we introduced a system of compliance officers in FY 2015 and are striving to promote compliance, mainly by the Chief Compliance Officer (CCO), Compliance Officers (CO), and Compliance Leaders (CL).
The CCO and COs have the authority to investigate, direct (including suspend business operations and shipping) and make compliance related proposals for the entire Group and their respective departments, respectively. We have also established a system in which the CCO reports to and consults with an external profession organization regarding compliance problems that occur. As assistants to COs, CLs are responsible for promoting various activities in the workplace. CLs are also required to report to their supervisors if they become aware of compliance problems and appropriately respond in accordance with the situation.
In FY 2017, we created a system that makes it possible to provide precise instructions by increasing the number of COs and gaining a more detailed understanding of the state of promoting compliance in their departments. Furthermore, we are working to invigorate activities, such as CLs taking the initiative to have discussions on compliance at the worksite, by providing CLs with training.
Compliance training at Headquarters
Compliance promotion system diagram
Setting Compliance Rules at Each Group Company
In February 2016, the company compiled compliance rules and clarified various points, including directors and employees’ responsibilities related to compliance and the reporting system in the case a compliance-related issue arises. Using this as a model, the main group companies both in Japan and overseas created their own compliance rules in October of the same year.
We will continue to thoroughly educate employees at the various Group companies about the compliance rules and take steps so that the compliance promotion system functions properly.
Enhancing Compliance Education/Training
To raise 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.
In addition, at production sites, effective educational activities appropriate for the site, such as incorporating compliance into the small-group activities that up until now targeted safety and quality, are undertaken.
Efforts are also being made to spread awareness of compliance among employees throughout the world by supplying group companies both in Japan and overseas with multi-lingual e-learning programs.
Small-group discussions at worksites (small-group activities)
Compliance Promotion Month Activities
Compliance lecture meeting
Since FY 2008, November has been designated “Compliance Promotion Month”, in which various awareness-raising activities are implemented throughout the entire group. In FY 2016, focus was placed on communication activities, such as management visiting worksites and holding discussions with employees, and a compliance awareness survey was conducted like was done in FY 2014.
The awareness survey targeted Group employees in Japan and ones assigned overseas, making it possible to make a fixed-point observation of changes since FY 2014. An analysis was conducted of employees’ awareness and evaluation of routine compliance efforts and activities during Compliance Promotion Month, and the results will be used when considering future efforts.
Main activities during the 2016 Compliance Promotion Month
- Have management visit and hold discussions at business sites and inform employees of compliance.
- Conduct compliance awareness survey.
- Hold and record compliance lectures by outside attorneys (at the Headquarters) and spread information by providing offices with DVDs of the lectures.
- Have Group employees develop compliance slogans and hang posters with the slogan.
- Read through the “Code of Conduct Handbook” in groups and have employees submit pledges.
Results of the FY2016 Compliance Survey (response rate 90.4% [90.9% for 2014])
- Conducting compliance promotion activities
Conducted at least one activity to raise compliance awareness within the last year, 88.2% (85.2% in FY 2014)
- Awareness and understanding of compliance
Know the meaning of compliance, 83.2% (74.3% in FY 2014)
* Toyo Tires Group’s compliance: We shall comply with laws and internal rules in all aspects of our business activities and shall conduct ourselves according to the highest ethical standards.
- Making compliance part of the corporate character
Conscious of compliance when conducting your work, 92.0% (87.1% in FY 2014)
Comment Compared to when the FY 2014 survey was conducted, there was greater awareness of compliance within the company, but there were differences in the responses provided by management and employees to the various questions, and I think that a future issue is eliminating those differences. When revising the content of future training and updating the “Code of Conduct Handbook”, the goal will be to raise compliance awareness among all employees, which would include steps such as using easier-to-understand wording. Hiroshi Tanaka, Compliance Dept., Compliance & Legal Division
Compared to when the FY 2014 survey was conducted, there was greater awareness of compliance within the company, but there were differences in the responses provided by management and employees to the various questions, and I think that a future issue is eliminating those differences. When revising the content of future training and updating the “Code of Conduct Handbook”, the goal will be to raise compliance awareness among all employees, which would include steps such as using easier-to-understand wording.
Hiroshi Tanaka, Compliance Dept., Compliance & Legal Division
Internal Reporting System
We have been operating an internal reporting system since FY 2006. Under the system of compliance officers introduced in FY 2015, employees who become aware of a compliance issue must report it to their superior, a Compliance Leader, or Compliance Officer, and if they cannot do so, it is recommended that they use the internal reporting system. These two systems are useful for preventing and quickly detecting compliance-related violations. “Reporting Hotlines” 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.
As a result of calls to promote the use of the “Reporting Hotlines” system by distributing cards and hanging posters, there has been an upward trend in the number of reports in recent years, and all have been appropriately handled.
Internal Reporting flow
Complying with Antimonopoly Laws
Having learned its lesson from violating U.S. antitrust law in 2013, the Company is moving forward with various efforts, including building a compliance system for the Group and conducting educational activities, to ensure compliance with competition related laws and ordinances in all countries. As for concrete measures, sales staff are required to submit a prior request to meet with competitors or an examination request in case of the regular meetings with the related parties including competitors and a post-meeting report, and a pledge to adhere to antimonopoly laws in line with the “Cartel Prevention Rules”. In addition, we are actively working to comply with laws and ordinances, and these efforts include establishing an Antimonopoly Law Compliance Hotline, having the Audit Department conduct cartel audits, and providing training, including e-learning, to related parties.
“Anti-bribery Regulation” explanatory meeting
In recent years, regulations prohibiting anti-bribery have grown stricter throughout the world. In order to prevent participation in corrupt practices of public officials and private companies in some countries, the Company conducts educational activities targeting Group employees both in Japan and overseas. In FY 2016, in Japan, Malaysia, Thailand, and China, attorneys from local law offices were invited to serve as instructors for anti-bribery seminars.
As the global expansion of the company accelerates, we will strengthen our educational activities that target employees so that the Group does not become involved in corruption.
Respecting and Utilizing Intellectual Property
The Intellectual Property Dept. is responsible for protecting and managing intellectual property.
We conduct thorough prior searches during the development state and respect the intellectual property rights of others. Also, by applying for and obtaining patents for newly developed technologies through the invention reward system, 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 grade-specific and work-specific training.