Corporate Ethics and Compliance
The Teijin Group considers compliance to be essential for creating a sound corporate culture. With this in mind, the Group is committed to ensuring that its officers and employees always act responsibly with high ethics.
Compliance and Risk Management (CRM) Promotion System
We hold meetings of the Group CSR Committee, which is chaired by the Chief Social Responsibility Officer and has the general managers of each business unit as its members, as a forum for deliberation and sharing information on compliance and risk management policies, measures, and activities within the group.
In addition, the Group Compliance Subcommittee, which is chaired by the general managers of CSR and Compliance Department and has the general manager of departments responsible for compliance in each business group or unit as its members, is established. The Subcommittee deliberates and shares information on specific measures and activities in accordance with the policies of the Chief Social Responsibility Officer and disseminates that information to each business division.
Compliance and Risk Management Promotion Managers (CRM Promotion Managers) are appointed at each worksite and promote the implementation of activities.
In addition, we hold the global CSR meeting, which has compliance personnel at main overseas group companies as its members. In FY2021, the meeting was postponed due to effects of the COVID-19 pandemic.
The Teijin Group is expanding into a diverse range of businesses, and as it continues to do so, it will need to address the increasing social demands and self-regulation. To this end, we are committed to reviewing and further strengthening our compliance promotion system in the new Medium-Term Management Plan scheduled to commence in 2023.
Positioning of compliance and risk management
PDCA cycle of compliance and risk management activities
Corporate Ethics and Compliance Activities
Promoting compliance is essential for creating a sound corporate culture. With this in mind, we carry out educational programs not only on internal rules and laws relevant to our business but also on various aspects of corporate ethics.
We also operate a counseling and reporting system (hotline) that is designed to facilitate self-resolution of internal legal and ethical problems.
Spreading Awareness about the Code of Conduct
The Teijin Group has established the Code of Conduct as its approach to realize the Group's corporate philosophy and ensures that all officers and employees of the Group are fully acquainted with it. When they join the company, employees pledge to comply with the employment rules and other regulations, including the Code of Conduct, and to work sincerely.
The Teijin Group Code of Conduct comprises the five following elements, which are derived from the letters of T/E/I/J/IN.
Respect diversity: Together
Emphasize the environment, safety, and health: ESH
Value good faith: Integrity
Recognize one another and create vitality: Joy at work
Aim for innovation: INnovation
In FY2021, we created videos with subtitles in the local languages of all regions and countries in which the Teijin Group operates, to deepen understanding of the Code of Conduct in the context of more specific behavior, and disseminated them to all Group companies.
The videos are animations featuring five characters using the five colors of the Code of Conduct conceptual diagram, and presents the story of learning about the Code of Conduct through behaviors in various situations at the workplace.
In FY2021, we made four videos on "Information Security (Protection of Information)", "Accurate Recording and Fair Information Disclosure and Dialogue", "Conflict of Interest", and "Compliance with Competition Laws". Further, by the end of FY2022, we plan to release educational videos on ten key points selected from the "Corporate Ethics Handbook", both within and outside the company.
Tax policy of the Teijin Group
In order to comply with laws and regulations regarding the tax practices of the countries, regions and multilaterals in which the Teijin Group operate, we have established a tax policy as a basic standard for taxation in April, 2022. By paying taxes appropriately in accordance with this policy, we aim to perform our social responsibilities and become a corporate group that can gain the understanding and sympathy of society at large while at the same time striving to increase our corporate value.
Workshops for all employees during the Corporate Ethics Month
The Teijin Group has designated October every year as the Corporate Ethics Month when training is conducted targeting all executives and employees (including contract/temporary employees), and posters are also put on display.
In FY2021, we continued utilizing online workshops in response to the COVID-19 pandemic. For the workshop, we used the Teijin Group Corporate Ethics Handbook available worldwide in the languages of all regions and countries where we conduct business.
We displayed posters with "Be Unique, but Work as One" as the 2021 slogan and encouraged employees to act in accordance with the Code of Conduct. With regard to languages, the posters were prepared in 16 languages--Japanese, English, Chinese (simplified and traditional), Korean, Thai, German, Dutch, Vietnamese, Spanish (European and Latin American), French, Burmese, Portuguese (European), Czech, and Hungarian--of all regions and countries where the Teijin Group conducts business.
Implementation of the corporate ethics awareness survey
In November 2021, we conducted the Employee Awareness Survey Questionnaire using a global survey platform to determine the extent to which the Teijin Group officers and employees all over the world are acquainted with the Code of Conduct and to what extent it is connected to their behavior.
This questionnaire included a survey of awareness of our corporate philosophy, Code of Conduct, awareness of ethics, and CSR thinking. Further, questions to confirm participation in and level of satisfaction with training for all employees during the Corporate Ethics Month were also included, and each item was evaluated on a five-point scale.
The results of the survey in FY2021 showed that the percentage of respondents who gave a high rating of five or four for awareness of corporate ethics (level of awareness of corporate ethics) was 77%, the participation rate of corporate ethics workshop for all employees during the Corporate Ethics Month was 92% (97% in Japan and 78% overseas), and the percentage of employees who were satisfied with the training (rating of five or four) was 70% (satisfaction).
Going forward, we will continue to analyze survey results, consider measures to raise employees' awareness of corporate ethics, and confirm these through questionnaires.
Five-point evaluation scale of awareness of corporate ethics (comprehensive evaluation)
Five-point evaluation of the level of satisfaction with workshops for all employees during the Corporate Ethics Month
Group-wide application of corporate ethics and compliance
1. Level-based workshop training
Every year, as part of level-based workshop training for employees at group companies in Japan, the CSR and Compliance Department conducts training on the reasons why companies undertake corporate ethics and compliance activities and the roles of employees. In FY2020, and subsequently in FY2021 as well, the training was conducted by having participants watch a pre-recorded video in response to the COVID-19 pandemic, and 220 employees participated.
Also, we plan to temporarily suspend overseas corporate ethics and compliance workshops for newly appointed managers, and restructure it.
2. Rotational training
We have been conducting on-site corporate ethics training whereby members of the CSR and Compliance Department visit sites of each business and affiliate company since FY 2016. In FY2020, and subsequently in 2021 as well, due to the effects of the COVID-19 pandemic the number of training opportunities decreased, and a total of four training sessions with 127 participants were held.
This training uses case studies from both inside and outside of the Teijin Group and aims to create an awareness that corporate ethics and compliance issues can affect anyone, anytime. Moreover, by creating a curriculum to suit the needs of each business/affiliate company, this training is proving to be even more effective.
3. Training for promotion-managers
In the past, this training was held by the CSR and Compliance Department at the Tokyo and Osaka head offices, but in FY2020, and subsequently in 2021 as well, group training was postponed due to effects of the COVID-19 pandemic, so training materials were distributed and the promotion managers conducted independent study. The training materials covered CSR procurement, prevention of bribery, and spreading the Code of Conduct.
4. Workplace training/education
The Teijin Group always post educational materials and case studies on its intranet so that promotion managers can conduct training on corporate ethics, compliance, and other topics as needed at each workplace in Japan and overseas and supports environments that facilitate independent training and study by employees.
Counseling and reporting center operations
The Teijin Group has created counseling and reporting system as a means for officers and employees as well as business partners to report directly on violations, suspicious conduct, and other issues at Teijin and its subsidiaries.
The Teijin Group launched a counseling and reporting system in 1999 for all group employees. Currently, this service is available to anyone working in Japan for an organization of the Teijin Group. A reporting/consultation website page for outside suppliers has been available since 2006. In addition to this, every year since FY2013, during Corporate Ethics Month in October, we directly distribute to employees envelopes for the “Corporate Ethics Opinion Box” to all employees at group companies in Japan.
Employees who work for group companies are able to use the Corporate Ethics Opinion Box, direct reporting, and other means among the group’s counseling and reporting system. In North America, Teijin Holdings USA, Inc., and in China, Teijin (China) Investment Co., Ltd. each established counseling and reporting center, and Teijin Frontier Co., Ltd., INFOCOM Corporation, and Teijin Aramind B.V. established counseling and reporting center and accept counseling and reports from officers and employees of these companies and their affiliated companies.
In March 2019, we also established a new global hotline that enables all officers and employees of overseas group companies to directly report to the Teijin Group headquarters hotline in their local languages.
The Rules for the Teijin Group’s Whistle-Blowing were newly established in 2019 to set for the operational responsibilities, authority, and procedures regarding these Teijin Group counseling and reporting systems. In addition, we have introduced an internal leniency program that allows the Chief Social Responsibility Officer to issue an opinion on reduction of or exemption from disciplinary measures imposed on a person who reports improper conduct according to the circumstances.
Reports and consultations which could possibly become major risk issues are reported to and handled properly by top management. While protecting privacy, the content and responses to all issues raised by employees via consultations/reports are disclosed to employees every six months on the intranet for the purposes of raising employees' awareness and as a preventative measure.
Continued Operation and Strengthening of the Security Export Control System
For the Teijin Group, whose business is expanding globally, compliance with laws and a fully functioning security export control system are vitally important. In light of this, we have established the Group Security Export Control Regulations governing the corresponding Security Export Control Regulations and Detailed Implementation Rules, which apply to each group company that conducts exports. We implement this via a dual-level control system, placing specialist back-office staff at the head office and business groups to ensure a highly reliable level of security export control.
The laws that must be complied with in security export control are frequently amended, so an important factor in training activities is to ensure high levels of awareness and thoroughness in regard to the latest information. In this regard, we conduct regular training and promote skills development of employees by encouraging them to sit external practical skills certification exams.
In FY2021 as well, we have continued working on maintaining and enhancing our internal management system in response to changes in the environment. In order to improve business transparency and effectiveness of operations, we have implemented a security export control system, and have revised the Security Export Control Regulations, among other things, in response to revisions to laws and regulations related to the Foreign Exchange and Foreign Trade Act, for the purpose of clarifying deemed export control.