The Company has outlined a Basic Policy, Guidelines, and a Corporate Code of Ethics. We conduct corporate activities in accordance with these policies and based on a strong ethical viewpoint while also complying with the relevant laws, rules, and regulations.
The Compliance Manual was prepared based on the Tokai Carbon Corporate Code of Ethics and our Ethical and Compliance Conduct Standards. The manual outlines the conduct standards that all officers and employees are required to maintain as they carry out their everyday duties, and is intended to help everyone in the Company understand compliance properly.
We have introduced an internal reporting system for receiving reports from employees who have found out about legal violations or fraud (or signs thereof), including any acts linked to corruption such as bribery etc. by executive officers or employees. We have established in-house contact points (Legal Affairs Department, Audit & Supervisory Board Member) and external contact points (legal advisors) to receive reports or requests for advice by phone, fax, email, letter, etc. Reports can also be made anonymously.
The Company’s Guidelines on Handing Internal Reports clearly states that, apart from cases when the system is deliberately misused, informants will not be dismissed or subjected to unfair treatment under this system.
Cases of corruption
In the FY2019, there was no exposure of corruption and no fines or surcharges paid. There was no disciplinary action made to employee due to the corruption.
Prevention of bribery and other corrupt behavior
Our Code of Ethics states that we will conduct business activities through fair competition and maintain sound and normal relations with politicians, government officials, suppliers, etc. It also states that we will comply with all laws and conduct business activities based on social norms and common sense. Because of this, we prohibit and strive to prevent acts of bribery or acts that could arouse suspicion of bribery, such as proposing or delivering benefits as compensation for others, and demanding or receiving benefits such as cash, excessive business entertainment, amusement or other services. We also prohibit corruption in the form of conspiracy to embezzle company funds or commit money laundering.
The prohibition of this kind of corruption and bribery is also specified in our procurement policy.
The Board of Directors oversees initiatives on compliance including the prevention of bribery and other corruption and receives reports from the Risk Management & Compliance Committee.
Tokai Carbon is raising awareness of the prevention of this kind of bribery and other corrupt behavior, familiarizing employees with our anti-corruption policy through training courses and in our in-house magazine so that all employees are able to avoid actions that could lead to corrupt behavior. Moreover, we have made no political contributions in fiscal 2019.
We continuously provide compliance training for executive officers, managers, new employees, etc. conducted by internal and external lecturers.
About 50 people attended lectures in 2017 on the subject of the Anti-Monopoly Act, about 45 people in 2018 on the subject of ESG, and about 50 people in 2019 on the issue of quality falsification. We are also striving to raise compliance awareness among executive officers and employees via the in-house distribution of a compliance message video and the publication of related articles in our in-house magazine.