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At Toshiba, we strive to ensure compliance with laws and regulations, social norms and ethics, and internal rules throughout its worldwide operations. According top priority to human life and safety and to compliance in everything we do underpins our commitment to promoting business activities through fair competition and serving the interests of customers to the best of our ability.
Toshiba Group Compliance Policy
- We place the highest priority on complying with laws and regulations, being sensitive to social standards and behaving ethically in all of our business activities.
- We enforce the Toshiba Group Standards of Conduct Groupwide to stress the importance of compliance.
- We strive to raise awareness of compliance through continuous education and audits, ensuring that compliance becomes a part of our corporate culture.
At Toshiba, we strive to ensure compliance with laws and regulations, social norms and ethics, and internal rules throughout its worldwide operations. According top priority to human life and safety and to compliance in everything we do underpins our commitment to promoting business activities through fair competition and serving the interests of customers to the best of our ability.
We consider thorough adherence to the Toshiba Group Standards of Conduct (SOC) - standards that provide us with guidance in our business activities - to be the foundation of compliance. We are inculcating the SOC, also ensuring that our subsidiaries worldwide adopt it thoroughly.
Every year, priority themes on compliance are set in light of business circumstances and promoted. By implementing a Plan-Do-Check-Action (PDCA) cycle of self-assessment, not only at each in-house company but also at group companies worldwide, we are stepping up our efforts to ensure compliance.
Since fiscal 2008, we have established new guidelines and implemented a stricter mechanism for ensuring compliance for our priority issues, such as compliance with antitrust laws and with rules and regulations related to respective businesses, prevention of bribery, etc. In particular, we formulated a new guideline for compliance with antitrust laws and prevention of bribery, adopted by our subsidiaries worldwide. Our other efforts to ensure thorough compliance include conducting comprehensive education programs according to characteristic needs of different countries.
Any violation of compliance is handled conscientiously, including appropriate and timely disclosure as well as the imposition of disciplinary sanctions on the offenders.
Toshiba's Risk-Compliance Committee, chaired by the CRO*, and acting in cooperation with the divisions concerned, determines and implements measures to deal with major risks, avert the emergence of new risks, and prevent recurrence. In-house companies and group companies worldwide have implemented similar risk compliance management structures.
* CRO: Chief Risk-Compliance Management Officer
Risk Management and Compliance Management Structure  |
With cases of noncompliance in the past, such as the New Tokyo International Airport Authority incident, we have been making efforts to ensure compliance with laws and regulations related to fair competition in public procurement.
In 2008, a cease and desist order was imposed upon eight manufacturers of heavy electrical equipment, excluding Toshiba, by the Japan Fair Trade Commission in accordance with the Antimonopoly Act on charges that nine manufacturers, including Toshiba, had been involved in a bidrigging case for electric equipment construction in relation to sewage disposal facilities ordered by Sapporo City by fiscal 2005. Toshiba's involvement was also confirmed and as a result, Toshiba was ordered to suspend part of its business in April 2009, according to the Construction Industry Law. Learning from this incident, we will further strive to adopt more rigorous measures to conform to laws and regulations and confirm that we do not accept illegal orders, in order to regain our trust. It is again a matter of profound regret to us that we received a serious warning from authorities due to non-compliance with the High-Pressure Gas Safety Law that occurred at our business site, Yokkaichi Operations (Japan).
In the wake of this incident, the headquarters and business sites immediately responded by investigating thoroughly into the matter, following which we adopted compliance measures to prevent the recurrence of such problem.
In January 2000, Toshiba introduced a whistleblower system, namely, "Risk Hotline." Using this system, employees can report their concerns or seek advice via the intranet or phone so that internal risk information is directly obtained in advance and any breach of compliance is prevented at an early stage. Furthermore, group companies worldwide have also introduced such systems.
In April 2006, Toshiba introduced "Clean Partner Line," a whistleblower system for suppliers and other business partners to enable them to report their issues concerning Toshiba. This is also adopted by group companies in Japan.
Toshiba's Whistleblower System  |
The Legal Affairs Division periodically communicates with the Corporate Audit Division in order to confirm the state of implementation with respect to the various compliance measures. Based on the actual state of implementation, steps are taken to enhance the effectiveness of management audits and the audit results are reflected in compliance measures.
Every year Toshiba conducts an intranet-based employee survey on the Toshiba Group Standards of Conduct (SOC). The results are used in formulating measures for raising awareness on compliance. According to the results of the fiscal 2008 survey, 97.1% (97.3% for fiscal 2007) of respondents replied that they comply with or generally abide by the SOC. While the survey results indicate that overall employee awareness on compliance is high, we will continue to implement further measures to maintain this level.
Booklets on Toshiba Group Standards of Conduct in various languages 
Inviting attorneys to conduct lectures Education on the Toshiba Group Standards of Conduct plays a pivotal role in ensuring compliance. Apart from providing new employees, managers, etc. with education appropriate to their responsibilities, we hold seminars for directors and executive officers, with lawyers and other specialists invited as speakers. Also, we provide e-learning for all employees on a continuous basis. |
The Toshiba Group Standards of Conduct stipulates that Toshiba Group shall not provide inappropriate benefits or favors to any politician or political organization.
In the case of offering political contribution, procedures in accordance with internal rules are followed as well as compliance with the Political Funds Control Law in case of Japan is strictly ensured.
Failure to respond appropriately to large-scale disasters, such as earthquakes, typhoons, floods, etc. could result in the long-term closure of operations, triggering significant financial losses and having a major impact on stakeholders.
In addition to measures to ensure the safety of employees and their families, support recovery of devastated areas, and maintain business sites and factories in the event of natural or other disasters, Toshiba established a Business Continuity Plan (BCP) in fiscal 2006 covering those businesses that have large social and economic impacts in order to minimize any interruption in the supply of products and services. Ever since, we have been continually updating the BCP. In order to manage risks, we are working to develop safety measures to deal with influenza pandemic, update BCP and reinforce our management.
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