Legal compliance in business operations is an indispensable prerequisite for every corporation to fulfill its responsibilities to society.
Toppan established the Conduct Guidelines as a set of compliance standards in June 2000, the centennial of Toppan Printing Co., Ltd. These guidelines set forth standards for Toppan personnel’s behavior based on the Corporate Philosophy and principles of legal compliance.
In November 2010 Toppan completely revised the guidelines into the Toppan Group Conduct Guidelines, a set of common principles that all Group companies around the world are required to observe for the assurance of strict compliance. These Group-wide guidelines are reviewed every year to adjust to changes in business environments, social conditions, and other circumstances relevant to the Group. Any revision of the guidelines is subject to a resolution by the Board of Directors of Toppan Printing Co., Ltd.
■ Compliance Promotion Structure
Toppan believes that the strict observance of the Conduct Guidelines directly links to legal compliance. The Group has been operating a Conduct Guidelines Promotion Leader system to ensure full observance of the guidelines in daily operations. The Conduct Guidelines Promotion Leaders at workplaces initiate guideline compliance activities under the Director in charge of Conduct Guidelines Promotion.
■ Compliance Training
Toppan organizes group training for Conduct Guidelines Promotion Leaders every year. The Group devises ways to enhance the effectiveness of training sessions through activities such as group discussions using case methods describing actual incidents.
Toppan gives every employee in Japan a Conduct Guidelines Casebook, a Q&A style casebook describing situations that can arise in daily work. The casebook is used in various guideline promotion activities. The Leaders, for example, use it to disseminate the guidelines at their workplaces. The Group also posts regular Conduct Guideline Notifications on themes relevant to the guidelines in order to heighten employee awareness and call attention to compliance-related issues. Toppan has been holding seminars, producing posters, and implementing other compliance promotion activities to ensure strict compliance among Group employees.
■ Anti-Corruption Initiatives
Toppan conforms to the anti-corruption principle set out by the United Nations Global Compact. The Conduct Guidelines, a code to be observed by all Toppan employees, include wide-ranging policies on corruption prevention, including the prohibition of collusion, illicit transactions, and other corrupt practices. All employees are kept fully informed of the Conduct Guidelines through regular activities led by Conduct Guidelines Promotion Leaders, who have received relevant training. The Conduct Guidelines Casebook distributed to all employees enhances awareness through case studies of corrupt conduct. Messages from executives to the entire workforce also address the issues of strict compliance and the prevention of corruption. In terms of bribery prevention, in fiscal 2016 the Group formulated an anti-corruption framework led by the Director in charge of Legal Affairs as the chief anti-bribery manager. A set of anti-bribery rules was also established in the same year to ensure strict anti-bribery practices.
For more intensive anti-bribery control, Toppan has tightened the procedures that employees use to request entertainment for and gift-giving to public officials and the like in line with the anti-bribery rules and guidelines. In fiscal 2017 Toppan conducted e-learning-based programs and provided Group employees with a Q&A style casebook describing specific examples.
■ Training for Compliance with Transaction-related Laws and Regulations
To enforce compliance with major transaction-related laws and regulations in Japan, the Toppan Group has been comprehensively preventing improper import and export transactions and ensuring compliance with the Subcontract Law. Toppan conducts regular training and audits on compliance with the subcontract law for departments and Group companies that engage in subcontracting transactions. The Group also continues holding training sessions and carrying out audits focused on export controls under the Foreign Exchange and Foreign Trade Act.
Regardless of level of risk, Toppan bases its transactions on the observance of standards related to such issues as legal and regulatory compliance, fair operating practices, and bribery prevention, as stipulated in the Toppan Group CSR Procurement Guidelines, which apply to all suppliers, subcontractors, and intermediaries. To provide training on the Guidelines and monitor the status of their observance, Toppan fully informs suppliers and subcontractors of them, holds briefings, and conducts questionnaires.
■ Training to Prevent Infringements of Intellectual Property
Protection and management of intellectual property is a crucial issue for Toppan, a group of companies operating in the three fields of Information & Communication, Living & Industry, and Electronics. The Group devotes strict attention to measures to prevent the infringement of copyrights, trademarks, and other intellectual property rights of other parties while obtaining patents for its own technologies and business models.
Apart from in-house special training, Toppan holds regular training sessions for employees of the Toppan Group and its business partners. Participants in these sessions acquire basic legal knowledge on intellectual property rights by reviewing case histories in design work and other operations involving intellectual property issues within the Group.
■ Internal Reporting System
When an employee discovers a legal violation or improper conduct somewhere in the Toppan Group, he or she is to report it to his/her superior for deliberation as a basic rule. If the employee’s superior fails to resolve the problem, the employee is encouraged to call the Toppan Group Helpline, the Group’s internal reporting system. The helpline is open for use by all Group employees, including dispatched staff and part-time workers. This system allows the Group to ensure strict compliance with the Toppan Group Conduct Guidelines by promptly identifying legal violations and improper acts and properly dealing with them.
■ Compliance in fiscal 2017
Toppan was not involved in any serious incidents or violations of laws or regulations in the course of business in fiscal 2017.