Corporate Ethics and Compliance
Basic Concept
In order to implement our corporate philosophy, the Tsubaki Spirit, we believe it is vital that all executives and employees act in compliance with laws and regulations, ethics, and company rules. To that end, we have formulated the Corporate Work Ethics, which are a clearly defined set of ethical guidelines, and we are working to raise awareness and spread information on ethics through activities, training and other initiatives to strengthen ethics. The results of these activities are periodically reported to the Board of Directors.
Promoting Compliance
The Company promotes compliance through its “Corporate Ethics Awareness Month” program and other training.
Corporate Ethics Awareness Month
We have designated February of every year as our Corporate Ethics Awareness Month, in which Group companies in Japan and overseas take part. In the fiscal year ended March 31, 2022, the number of participating companies was limited by the COVID-19 pandemic to 32 of 51, as we responded to the conditions in other countries. Due to the circumstances, we carried out educational activities on ethics awareness centered on e-learning in Japan and remote learning overseas.
Number of Companies Participated in Corporate Ethics Awareness Month
| 2017 | 2018 | 2019 | 2020 | 2021 |
|---|---|---|---|---|
| 51 | 51 | 51 | 24 | 32 |
* Including participants in the e-Learning program in FY 2020
Compliance Training
The Company has set forth the Tsubaki Corporate Ethics Handbook which is now available in six languages. The Company holds systematic ethics training throughout the year. The Company keeps these trainings up-to-date by incorporating new issues which were identified, if any, in the Corporate Ethics Awareness Month.
Number of Participants in Compliance Training (Japan)
| 2017 | 2018 | 2019 | 2020 | 2021 |
|---|---|---|---|---|
| 622 | 749 | 1,855 | 3,064 | 3,529 |
* Including participants in the e-Learning program in FY 2020
Ethics Committee
The Ethics Committee promotes compliance through activities such as reviewing measures to prevent breaches of the Corporate Work Ethics from recurring and deciding on actions against those who breached said measures.
Establishment of a Consultation and Reporting Hotline
The Company (Japan) has a whistleblower system under the Corporate Ethics Helpline Rules. The ethics helpline provides two facets, a dedicated section within the Company and an outside legal counsel retained by the Company. Both of these accept anonymous reporting.
The ethics helpline addresses not only matters regarding breaches of laws and regulations and/or company rules but also concerns or worries of a personal nature if being asked for.
