Basic Approach

Legal compliance in business operations is an indispensable prerequisite for every corporation to fulfill its responsibilities to society.

Toppan established the Conduct Guidelines as a set of compliance standards in June 2000, the centennial of Toppan Printing Co., Ltd. These guidelines set forth standards for Toppan personnel’s behavior based on the Corporate Philosophy and principles of legal compliance.

In November 2010 Toppan completely revised the guidelines into the Toppan Group Conduct Guidelines, a set of common principles that all Group companies around the world are required to observe for the assurance of strict compliance. These Group-wide guidelines are reviewed every year to adjust to changes in business environments, social conditions, and other circumstances relevant to the Group. Any revision of the guidelines is subject to a resolution by the Board of Directors of Toppan Inc.

Promotion Framework

■ Compliance Promotion Structure

Toppan believes that the strict observance of the Conduct Guidelines directly links to legal compliance. The Group has been operating a Conduct Guidelines Promotion Leader system to ensure full observance of the guidelines in daily operations. The Conduct Guidelines Promotion Leaders at workplaces initiate guideline compliance activities under the Director in charge of Conduct Guidelines Promotion.

■ Compliance Training

Toppan organizes group training for Conduct Guidelines Promotion Leaders (“Leaders”) every year. The Group devises ways to enhance the effectiveness of training sessions through activities such as group discussions using case methods describing actual incidents.

Toppan gives every Group employee in Japan a Conduct Guidelines Casebook, a Q&A style casebook describing situations that can arise in daily work. The casebook is used in various guideline promotion activities. The Leaders, for example, use it to disseminate the guidelines at their workplaces. The Group also posts regular Conduct Guideline Notifications on themes relevant to the guidelines in order to heighten employee awareness and call attention to compliance-related issues. Toppan has been holding seminars, producing posters, and implementing other compliance promotion activities to ensure strict compliance among Group employees.

■ Anti-Corruption Initiatives

Toppan conforms to the anti-corruption principle set out by the United Nations Global Compact. The Conduct Guidelines, a code to be observed by all Toppan employees, include wide-ranging policies on corruption prevention, such as the prohibition of collusion, illicit transactions, and other corrupt practices. Every Group employee is kept fully informed of the guidelines through regular activities led by Conduct Guidelines Promotion Leaders who have received relevant training. The Conduct Guidelines Casebook distributed to all Group employees enhances awareness of anti-corruption issues through various case studies of corrupt practices. Messages from the President & Representative Director to the entire workforce also address the issues of strict compliance and the prevention of corruption.

In terms of bribery prevention, in fiscal 2016 the Group formulated an anti-corruption framework led by the Director in charge of Legal Affairs as the chief anti-bribery manager. A set of anti-bribery rules was also established in the same year to ensure strict anti-bribery practices. Toppan distributed an FAQ on bribery in fiscal 2018.

For more intensive anti-bribery control in line with the anti-bribery rules and guidelines (established in fiscal 2016 and fiscal 2017; partially reviewed in fiscal 2018), Toppan has tightened the Group’s internal procedures for applying for authorization to offer entertainment or gifts to public officials and the like. Employees across the Group were interviewed by personnel in charge of legal affairs in fiscal 2019 to verify the application procedures at their divisions. No cases of inappropriate entertainment or gifts were identified.

■ Training for Compliance with Transaction-related Laws and Regulations

To enforce compliance with major transaction-related laws and regulations in Japan, the Toppan Group has been comprehensively preventing improper import and export transactions and ensuring compliance with the Subcontract Law. Toppan conducts regular training and audits on compliance with the subcontract law for the departments and Group companies engaging in subcontracting transactions. The Group also continues to hold training sessions and carry out audits focused on export controls under the Foreign Exchange and Foreign Trade Act.

Toppan fully informs every business partner of the Toppan Group CSR Procurement Guidelines as principles to be observed in transaction with the Group, regardless of the level of risks. The guidelines are issued to all suppliers, including subcontractors and intermediaries, to familiarize them with the terms of legal compliance, fair business activities, anti-corruption measures, and other CSR-related issues. Toppan holds seminars to train suppliers on the guidelines and conducts questionnaires to monitor the status of their observance.

■ Training to Prevent Infringements of Intellectual Property

When a person at Toppan discovers a legal violation or improper conduct somewhere in the Group, he or she is to report it to his/her superior for deliberation as a basic rule. If his/her superior fails to resolve the problem, the person is encouraged to call the Toppan Group Helpline, the Group’s internal reporting system. The helpline is open for use by all officers and employees (including dispatched staff and part-time workers) at Group companies (excluding listed corporations). This system allows the Group to ensure strict compliance with the Toppan Group Conduct Guidelines by promptly identifying and properly dealing with legal violations and improper acts.

In November 2019 the Toppan Group revised the rules on internal reporting by adding a clause stipulating the establishment of three portals to receive reports: a “corporate portal” and “audit & supervisory board member portal” operated in-house, and an “external portal” operated by legal consultants. The three portals were opened for use on April 1, 2020.

  • When a person at Toppan discovers a legal violation or improper conduct somewhere in the Group, he or she is to report it to his/her superior for deliberation as a basic rule. If his/her superior fails to resolve the problem, the person is encouraged to call the Toppan Group Helpline, the Group’s internal reporting system. The helpline is open for use by all officers and employees (including dispatched staff and part-time workers) at Group companies (excluding listed corporations). This system allows the Group to ensure strict compliance with the Toppan Group Conduct Guidelines by promptly identifying and properly dealing with legal violations and improper acts.

    In November 2019 the Toppan Group revised the rules on internal reporting by adding a clause stipulating the establishment of three portals to receive reports: a “corporate portal” and “audit & supervisory board member portal” operated in-house, and an “external portal” operated by legal consultants. The three portals were opened for use on April 1, 2020.

  • * The Compliance Committee discusses and formulates measures, etc. to handle issues reported to the external portal.

■ Compliance in fiscal 2019

Toppan was not involved in any serious incidents or violations of laws or regulations in the course of business in fiscal 2018.

Main Activities and Relevant Information