Promoting Compliance

Spreading Awareness of the Charter of Corporate Behavior and Code of Conduct

TOYO TIRE compiled not only the “Toyo Tire Group Charter of Corporate Behavior” as corporate action principles applied uniformly across the Group in order faithfully conduct business activities but also the “Toyo Tire Group Code of Conduct” for each director and employee to put the charter into practice.The Charter of Corporate Behavior and the Code of Conduct are reviewed as appropriate. If revisions are required, they are resolved by the Board of Directors.
Taking into the consideration differences in laws, regulations, and customs between countries and regions, each subsidiary outside Japan have created independent codes of conduct using the code of conduct as action guidelines.
We have newly created and distributed the “Code of Conduct Handbook: Global Version.” This handbook translated into 9 languages: Japanese, English, Russian, German, Italian, Chinese, Thai, Malaysian, and Portuguese, and defines the basic actions that every Director and employee of the Group should take. We are working to spread the code of conduct throughout the Group and reinforce compliance.
In Japan, reading aloud the Code of Conduct Handbook and the Supplementary Reader that explains specific cases relevant to production sites and sales sites are done by all corporate officers and employees, including those at Group companies, and after completing the training, participants submit a pledge that states they will promote compliance.
The Group companies outside Japan have established their own code of conduct that reflects the differences in laws and customs of each country and local community, based on the Toyo Tire Group Code of Conduct, and are working on fostering compliance awareness.

[Example training sessions in each region]
China: Once a year, our affiliates in China give training to all of their employees on a topic that addresses their respective compliance risks. After the sessions are over, a questionnaire survey is sent to the trainees to check their level of understanding.
For example, in fiscal 2020, TOYO TIRE (SHANGHAI) CO., LTD. organized a legal affairs / compliance seminar, which focused on topics such as standard practices to follow when signing a contract and falsified adjustments, and the Code of Conduct Handbook reading/announcement session.
Europe: With the shift to working from home due to the COVID-19 pandemic, the Toyo Tire Europe GmbH (TTE) Group organized e-learning sessions on cyber security for all of its 126 employees in fiscal 2020. Our Europe R&D Center, on the other hand, is drawing the attention of its members to compliance in R&D activities by encouraging its members to take advantage of both external and internal safety management training opportunities.

Results of the FY2020 Compliance Survey *Response rate 81.6% [88.2% in FY 2019]

  1. Conducting compliance promotion activities
  • Conducted at least one activity to raise compliance awareness within the last year, 95% (97% in FY 2019)
  1. Awareness and understanding of compliance

Know the meaning of compliance, 88% (88% in FY 2019)

  • * TOYO TIRE’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.
  1. Making compliance part of the corporate character

Conscious of compliance when conducting your work, 94% (93% in FY 2019)


In fiscal 2020, despite concerns over disturbances caused by the COVID-19 pandemic, I am delighted to say that the level of our employees' compliance awareness stayed high throughout. That said, some replies indicated a decline in communication at workplaces and not a few respondents said that they often feel stressed, anxious, and bothered by the situation they are in, which I gather is attributable to the consequences of the pandemic. As we expect COVID-19 to affect our lifestyles for some time to come, we need to develop some form of mitigating measures. With these findings in mind, we will involve each workplace in planning activities so that we can develop a deeper level of compliance awareness.

Ryo Imada
Compliance Dept.,
Compliance & Legal Division,
Toyo Tire Corp.

Internal Reporting System

The Toyo Tire Group has maintained an internal reporting system since 2006. In Japan, we have established internal and external hotlines employees and business partners can use. Reports can also be made anonymously.
Overseas, we are establishing such hotlines at each site to ensure fairness and transparency, which are essential for sound business activities.

Awareness of domestic hotline consultation service in Japan

Awareness of domestic hotline consultation service in Japan

Preventing Anti-Competitive Behavior

We are moving forward with the building of a compliance system, conducting educational activities, etc., in order to thoroughly comply 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, a post-meeting report of request for exemption, 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 audits of the compliance status with Cartel Prevention Rules, and providing training, including e-learning, to related parties.


The Toyo Tire Group strives to ensure fairness and transparency in all its business activities. Having established the Global Anti-Corruption and Anti-Bribery Policy and Anti-Bribery Rules, we are making constant efforts to ensure that these policies and rules are applied appropriately to our business. In fiscal 2020, we organized e-learning sessions on the prevention of bribery for employees from the corporate and R&D divisions and back-office operations at production sites.
With the recognition that, if acts of corruption and/or bribery are discovered, there is a risk of not only a large financial penalty and detention of the perpetrators concerned, but also a risk of serious damage being done to our corporate value by business suspension and social punishment, we will work to prevent such misconduct as part of our corporate social responsibilities.
The risk of corruption in countries and regions in which the Group has business sites is evaluated using the fiscal 2017 Corruption Perceptions Index (CPI) surveyed and published by the international NGO, Transparency International. We believe caution be required in particular for business activities in countries with a CPI of less than 40.
We are conducting educational activities at a time when regulations related to corrupt acts, particularly bribery, are being reinforced around the world.

Status of Legal Compliance in the Environment, Social, and Economic Fields

In FY2020, there were no cases of serious penalties or sanctions other than penalties within the Toyo Tire Group due to violations in the environmental or social and economic fields.

Incidents of Non-compliance concerning the Health and Safety Impacts of Products and Services

We are working to prevent the recurrence of past misconduct caused by the Company and its affiliate companies. As of December 31, 2020, regarding the replacement status for seismic isolation rubber for construction, out of a total of 154 applicable buildings, work had begun in 147, and out of these, the replacement of nonconforming products has been completed in 145 buildings.
In FY 2020, there were no incidents of non-compliance concerning the safety and health impact of products and services.