Fair Competition and Trading Practices

Supply Chain

Fair Trading Policy

Toshiba strives to build sound partnerships with suppliers through fair trading in compliance with procurement-related laws and regulations.

Suppliers play a pivotal role in Toshiba Group's ability to provide quality products to its customers. To enable the suppliers to thoroughly understand Toshiba Group's procurement policy and secure their cooperation in promotion of CSR, we prepared a document outlining Toshiba Group's CSR stance in procurement in light of the Toshiba Group Procurement Policy and distributed it to all suppliers worldwide in February 2005.

In May 2012, we also revised the Toshiba Group Procurement Policy to accord priority to suppliers that comply with laws and regulations as well as social norms when beginning new transactions or continuing existing ones. In addition, in reference to the UK Bribery Act, we added the prohibition of bribery to all interested parties as a requirement for suppliers and made an announcement to that effect to all suppliers in Japan and overseas.

• Toshiba Group Procurement Policy
• Toshiba Group Standards of Conduct Chapter 1 4. Procurement

Framework for Fair Trading Practices

Toshiba strives to build sound partnerships with suppliers through fair trading in compliance with procurement-related laws and regulations.

A dedicated CSR organization established in April 2007 within the Procurement Division is working to ensure fulfillment of CSR in Toshiba Group's procurement and on the part of suppliers.

It is essential to ensure that procurement complies with applicable laws and regulations worldwide. Toshiba Group has established a system for ensuring compliance concerning procurement, which is connected with the Toshiba Group Procurement Division.

Information related to compliance concerning procurement is thoroughly informed to Group-wide companies through this system.

Moreover, measures are thoroughly informed by means of Procurement Compliance Liaison Meetings, organized by the Procurement Division and attended by Compliance Managers and Compliance Coordinators.

Toshiba Group CSR Procurement Promotion Structure

Whistleblower system for suppliers and business partners

We have established a whistleblower system for business partners called Clean Partner Line. We notify our business partners of this system and request that they make use of it to report any issues regarding noncompliance and unfair trading practices that involve Toshiba Group employees to enable such concerns to be promptly resolved.

Checks and Audits of Fair Trading Practices (Thorough Compliance with the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors)

In Japan, we continued with audits against the Act against Delay in Payment of Subcontract Proceeds for the applicable group companies with regard to subcontracted transactions.

Regarding items requiring improvement as identified by the audits, follow-up is conducted in accordance with improvement plans to ensure thorough compliance.

Training to Ensure Fair Trading Practices

At Toshiba Group, various training programs on compliance in procurement are provided to ensure fair trading practices. For example, in FY2007, we conducted training for employees of group companies in Japan on relevant acts, such as the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors. We also provide compliance education for employees engaged in procurement at various phases of their careers. Furthermore, we foster auditors specialized in the Act to ensure fair transactions with subcontractors.

In addition, group companies in Japan conducts periodic training on the Subcontractor Act for employees engaged in procurement.

Cooperation with Suppliers

Toshiba Group establishes fruitful partnerships with suppliers based on mutual trust.

Suppliers are expected to ensure stable supply of environmentally conscious, excellent goods and services at appropriate prices. In addition, the activities listed below are vigorously promoted to strengthen “win-win” relationships advantageous to both Toshiba Group and suppliers.

1. Collaborative development of strategic components, utilizing suppliers' unique technologies
2. Collaborative projects for enhancement of the quality of goods and services and reduction of manufacturing costs, utilizing Toshiba Group's technological capabilities
3. Reduction of procurement costs of suppliers in collaboration with Toshiba Groups procurement operations

Free and Fair Competition in Accordance with Prevailing Regulations

Toshiba Group strives to ensure that its business activities are carried out in accordance with not only prevailing laws and regulations but also sound business customs and social norms. We provide guidelines on compliance with antitrust laws and other regulations and conduct business through free and fair competition based on these guidelines We regard information as important assets and use appropriate methods to manage confidential and personal information concerning third parties obtained through our business activities.