G:Compliance

Compliance organizational responsibilities

The president of Toyo Tire Corporation has made compliance the absolute highest priority within Group management, and we are dedicated to expanding and improving compliance systems.
We set up the Compliance Committee as one of the special committees under the jurisdiction of the Executive Committee to consult and investigate ways to promote compliance. The Chief Compliance Officer (CCO), compliance officers (CO), and compliance leaders (CL) play a key role in promoting compliance under our compliance officer system.
The Compliance Committee, chaired by the CCO appointed by the Board of Directors, meets quarterly in principle, and reports the results of its discussions twice a year to the Executive Committee, which is supervised by the Board of Directors.
The status of compliance promotion is also reported to the Board of Directors as necessary.
The CCO has the right to investigate, issue instructions and orders (including the suspension of operations and shipments), and make proposals regarding compliance-related issues for the Group as a whole, and COs have similar rights within their individual divisions.
CLs assist COs in promoting various activities in each workplace, and are expected to report any compliance concerns (including suspected issues) to their general manager and COs. When a concern is reported to a CO, an investigation is immediately launched and necessary action is taken, then a plan is developed to prevent reoccurrence. As a general rule, compliance concerns are disclosed within the company so that employees can be on the lookout for any similar issues, reconfirm legal regulations and company rules, and have a reference for how to respond if similar incidents do occur.
The Compliance Department provides support at all stages so that the system functions properly and effectively.
We will continue to regularly evaluate the effectiveness of our compliance initiatives and update them as necessary.

Preventing corrupt practices and bribery

The Group has established a Global Anti-corruption and Anti-bribery Policy, effective since 2019.
We have determined some anti-corruption items in our CSR Procurement Guidelines, and ask all suppliers to ensure compliance. The Compliance Committee, Compliance & Legal Division, Procurement Division and the general affairs departments at each site are responsible for appropriately implementing initiatives regarding the operation, internal and external permeation, and monitoring of the basic policy.

Global Anti-corruption and Anti-bribery policy

• *　Within Toyo Tire Corporation

Instilling the Group Charter of Corporate Behavior and Code of Conduct

We have established the Toyo Tire Group Charter of Corporate Behavior as a set of common principles for all Group companies that ensure our business activities are conducted in good faith, and the Toyo Tire Group Code of Conduct to help each executive and employee implement the Charter. The effectiveness of the Charter and the Code is regularly evaluated and verified, and any necessary revisions are resolved by the Board of Directors.
We have developed the Global Code of Conduct Handbook detailing the basic conduct that we expect from every Group executive and employee. The handbook has been translated into the local language of the countries and regions in which our bases are located in the effort to instill the principles of the Code into every Group employee and strengthen compliance.
In Japan, we conduct read-along training sessions every year for all executives and employees, including those of Group companies, using the Code of Conduct Handbook, a tool designed to instill the principles of the Code, and the Supplementary Reader that gives practical and specific examples relevant to front-line production and sales staff. Upon completing the training, each participant submits a written pledge to promote compliance.

• Toyo Tire Group Charter of Corporate Behavior
• Toyo Tire Group Code of Conduct
• Global Code of Conduct Handbook

Training in different regions

Our Group companies run their own training programs on themes that focus on the compliance risks that are relevant to their operations. For example, in 2024, our Malaysian subsidiary hosted a seminar on environmental and safety compliance delivered by the Malaysian Department of Environment, as well as holding a participatory, awareness-raising event for employees on compliance issues. A subsidiary in China held a compliance seminar, where a lawyer from outside the company was invited to talk about anti-corruption rules as well as good information management and company asset management practices. The subsidiary also conducted compliance tests based on the Code of Conduct Handbook.
A subsidiary in Mexico strives to strengthen compliance by establishing opportunities for monthly compliance training that touch on a wide variety of themes.

Conducting compliance awareness surveys

We conduct annual compliance awareness surveys to ascertain the degree of compliance-related awareness among employees and aid our future endeavors.

2024 compliance awareness survey result: 90% response rate (89% in 2023)

1. Implementing activities to promote compliance

   Made one or more attempts to raise compliance awareness over the past year: 95% (94% in 2023)

2. Degree of compliance awareness and understanding

   Understand what compliance means: 89% (89% in 2023)Toyo Tire compliance: Instead of simply adhering to laws and regulations, we must comply with laws, regulations and internal rules, and be guided in our actions by a keen sense of ethics.

3. Degree of embedding of compliance

   Remain conscious of compliance when conducting own work activities: 95% (94% in 2023)

Comments from survey manager

2024 was a year in which a spate of corporate scandals came to light in Japan, underscoring the need for robust governance, but our survey shows that, among our employees, the awareness, understanding and consideration of compliance issues have remained high. While the survey results indicate that many of our workplaces are engaged in solid programs of activities to promote compliance in spite of the cascade of changes in the business environment, the findings also highlighted areas where further improvements would be required. We will develop a plan of action to address those areas. In addition, we will continue working with each workplace to review their program of compliance activities in order to embed the compliance mindset deeper into our workforce.

Whistle-blowing system

The Toyo Tire Group has been operating a whistleblowing system since 2006. We have set up whistleblowing hotlines within and outside the Company through which our Group employees can report or consult directly on compliance matters and other concerns that they fear could develop into a crisis event. This system enables us to respond to reported cases in accordance with the Whistleblower Protection Act. The hotlines can be accessed through multiple channels and accept anonymous reports as well as reports from former employees, suppliers and customers so that the information needed to address the issues is more likely to reach the governance bodies. In fiscal 2024, the hotlines received 24 reports and consultations. While relatively many of them tend to be about internal rules, all are investigated swiftly and, where necessary, actions are taken to remedy the issue or prevent recurrence.
To detect and solve harassment incidents at an early stage, we have also set up harassment hotlines for employees and assigned counselors at each of our business sites in Japan. Their contact details are posted on noticeboards and rest areas in company premises, and the counselors are given relevant training to ensure they can handle matters reported to them appropriately. In addition, we conduct training sessions for employees as well as managers and supervisors from time to time to promote awareness and provide correct information on how to prevent harassment. In fiscal 2024, the harassment hotlines received 17 reports, and all have been dealt with and investigated in accordance with the defined process for handling harassment cases.
We have also set up a customer service center and web-based inquiry form for consumers, local communities, and other members of the general public.

Awareness of the reporting hotlines in Japan

Preventing anti-competitive conduct

The Toyo Tire Group is building compliance frameworks and systems and promoting education and awareness-building activities to ensure thorough compliance with competition laws and regulations in individual countries. Specifically, we oblige our executives and employees in charge of sales to submit prior applications, follow-up reports and exclusion applications relating to any contact with competitors based on the Cartel Prevention Rules, as well as a written pledge regarding the upholding of antimonopoly laws. We also pursue various initiatives to ensure compliance with laws and regulations, such as establishing a Consultation Desk for Compliance with the Antimonopoly Act, getting the Audit Department to check the status of compliance with the Cartel Prevention Rules, and conducting training (including e-learning) for related parties.

Anti-corruption initiatives

The Group strives to ensure fairness and transparency as the foundation for conducting sound business activities.
We know that discovering any corrupt practices or bribery would risk not only potentially huge fines or the detention of involved parties, but also significant damage to our corporate value through the termination of transactions or the imposition of social sanctions. We work hard to prevent any such acts as part of our corporate social responsibility.
As part of our efforts, we have established the Global Anti-corruption and Anti-bribery Policy along with our Anti-bribery Rules and are promoting ongoing activities to ensure these rules are instilled and properly operated in our business activities. In 2024, we conducted e-learning on anti-bribery themes for employees working for Group companies in Japan (who have a PC account).
The 2024 Corruption Perceptions Index (CPI) researched and published by the international NGOs Transparency International assesses the risk of corrupt practices in markets where the Group has business sites. We believe we must pay particular attention to our business activities in countries where the CPI is assessed to be lower than 50.
To prevent the corrupt practice of insider trading before it happens, we also conducted anti-insider trading e-learning for management-level employees (assistant managers and above) at Group companies in Japan.

• 腐敗行為・贈収賄行為の防止に関するグローバル方針（2019年1月）
• Global Anti-corruption and Anti-bribery policy
• 全球反腐败和反贿赂政策

Cases of corruption violations

In 2024, there were no cases of fines, penalties, or other legal punishments resulting from corruption.
Neither were there any cases of employees being dismissed due to breaching our internal rules on corruption.

Compliance violations

There were no criminal accusations of corruption in any incidents related to compliance in 2024.

Legal compliance in the environmental and socioeconomic fields

There were no sanctions imposed on the Group in 2024 for environmental or socioeconomic violations.

Violations Relating to the Health and Safety Impact of Products and Services

We remain committed to ensuring that the frauds we and our affiliates committed in the past will never be repeated, and are implementing preventative measures against recurrence. As of the end of December 2024, we had started changing the seismic isolation rubber in all of the 154 target buildings. We will continue the rubber replacement program, prioritizing safety during the work above all else.
There were no violations relating to the health and safety impact of products and services in 2024.
Click here for more information on the progress of our efforts to prevent a reoccurrence of this issue.