Compliance

Promoting Open and Fair Corporate Activity

Basic Concepts of Compliance

The Guiding Principles at Toyota state that Toyota will "honor the language and spirit of the law of every nation and undertake open and fair corporate activities to be a good corporate citizen of the world." It is in this process that Toyota seeks to maintain compliance. In accordance with the Basic Approach to Internal Controls, Toyota is promoting initiatives centered on the construction of framework such as that for adopting and implementing the Code of Conduct and human resource development through education and other means. Toyota has also established consultation hotlines so no issues are overlooked and detailed responses can be made.

Checking Activities to Enhance Compliance

In FY2008, Toyota started checking activities to enhance its compliance structure. In FY2009, it also started the checking of subsidiaries in addition to internal checking. In FY2010, we further enhanced our checklists and implemented additional strengthening of the structure. The results of the activities were reported to the CSR Committee, and Toyota continues to push ahead with improvements based on the results.

Education and Training to Ensure thorough Compliance

To ensure that awareness of compliance issues extends from senior managers to all other employees, Toyota conducts education and training programs for directors, newly-appointed departmental general managers and newly-recruited employees in addition to company-wide e-learning programs. It also conducts seminars on business compliance regarding topics such as copyright, security control and products liability law.

Major Educational Themes

• Contract
• Anti-Monopoly Act
• Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors / Act against Unjustifiable Premiums and Misleading Representations
• Companies Act / Regulation for Insider Trading
• Copyright
• Intellectual Property Rights
• Product Liability Act
• Personal Information Protection Law
• Information Security Management
• Anti-Bribery and Others

The Compliance Hotline

Toyota has established a number of hotlines for swift and appropriate resolution of issues related to compliance, gender harassment, working conditions, and mental and physical health. The Compliance Hotline in the chart below allows employees to have consultations concerning compliance-related issues and has been set up at an outside law firm (subcontractor). Upon request, the content of consultations is conveyed anonymously to a secretariat within Toyota and the details are investigated with scrupulous care to ensure that the identity of the employee having the consultation is not revealed. If the results of the investigation indicate a compliance-related issue, a response is immediately implemented.

Toyota Code of Conduct