Established on June 2nd, 2000
Revised on July 1st, 2003
Revised on April 1st, 2006
Revised on November 1st, 2010
The Conduct Guidelines set out the basic concepts and guidelines for behavior that enable all who work at Toppan to act in accordance with a law-abiding spirit and corporate ethics. They are comprised of 65 clauses divided into two chapters.
Since the establishment of the Conduct Guidelines in June 2000, they have been revised twice, in July 2003 and in April 2006, in order to further enhance compliance management. With Toppan marking the 110th anniversary of its founding in 2010, the Conduct Guidelines have been extensively revised and positioned as guidelines shared by the entire group in order to enhance globalization and group management.
Today, to continue being a company that is trusted and respected broadly by society, fulfilling our social responsibilities as a corporation is of great importance. In order to do this, at the same time as pursuing our goals on the economic front, we believe it is essential to take a balanced approach with social and environmental initiatives, such as respect for human rights, contributions to society and culture, and environmental conservation. Through undertakings such as these, we must actively contribute to the realization of a fulfilling lifestyle.
The foundation of this corporate social responsibility is not only every employee's observance of laws, but also the carrying out of our operations in accordance with corporate ethics. In performing our work there is absolutely no room for violations of the law or corporate ethics. By each of us conducting our activity with high ethical standards, we will be able to secure society's trust and respect with regard to our business activities.
These Conduct Guidelines are rooted in our Corporate Philosophy and Corporate Creed and set out how we should conduct ourselves based on a law-abiding spirit and corporate ethics in all of our operations. We must all read the Conduct Guidelines thoroughly, understand them and act in accordance with them in our everyday work.
We will not act in a manner that violates laws, regulations or corporate ethics. We will clearly say "NO" to illegal or improper demands. We will comply with the Conduct Guidelines with firm intent and work together to build a company that is trusted and respected by society.
Chapter 1 defines the Basic Principles of the Toppan Group Conduct Guidelines. The Basic Principles represent the foundation for making decisions in business activities for all people working within the Toppan Group. We will consistently act with reference to these principles in both our business activities and private lives.
- Respecting basic human rights
Based on the concept of respect for people, we will act in a manner that fully exploits the individuality and abilities of each person. We will respect basic human rights, protect the dignity of the individual in every regard and will not discriminate in any way.
- Having high ethical standards and acting as a responsible member of society
We will fully consider the impacts that business activities have on society and always act with high ethical standards in order to be trusted and respected by society. Even in cases where legal issues do not arise, we will not act in a way that damages the Toppan brand, engage in activity that is contrary to social order and common sense, or support any such conduct.
We fully recognize that trust in the company is built up through the accumulation of the everyday activities of every employee and will also act with dignity and moderation in our private lives.
- Complying with laws and company rules and conducting fair business operations
We will act in compliance with international and domestic laws, bylaws, government notices, operational standards, industry standards and other rules in society that are applicable to business activities. In conducting business, we will also act in line with relevant company rules. Compliance with these rules is the minimum requirement in society. All employees will observe them and engage in operations that respect fair commercial practices.
- Avoiding all links with antisocial groups
We will not have any links whatsoever in any aspect of our business activities with any antisocial groups that pose a threat to social order and safety. In the case of an improper demand from such an antisocial group, we will cooperate with the relevant organizations and respond with a resolute stance.
- Striving to improve quality and providing creations that contribute to customer satisfaction
We will consider the products and services provided to customers to be creations and strive to ensure safety and improve quality based on the concept of Total Quality Assurance undertaken by the entire company including all employees, not just those in departments directly involved in manufacturing and quality.
Based on this concept, we will act with the satisfaction of the customer as the first priority and build strong relationships of trust with customers.
- Recognizing the importance of information related to business and managing it appropriately
We fully acknowledge the importance of all information related to business, including information on customers, confidential information and personal information, and will manage such information appropriately in line with rules so that accidents such as leaks and losses do not occur.
- Proactively undertaking conservation of the global environment
In our business activities we will protect the precious environment bequeathed to us by nature and use limited resources effectively.
We will also proactively engage in business that shows consideration for the environment and contribute to the revitalization, maintenance and improvement of the global environment.
- Embracing change and taking on new challenges
We will accurately identify changes in the business environment and market and take the challenge of exploring new possibilities based on planning and development that is ahead of the times. We will create new demand and contribute to enabling the Toppan Group to enhance corporate value for the future and continue growing.
- Building trust from society through social contribution activities and appropriate disclosure of information
In aiming for a better society, we will engage in social contribution activities that make use of our management resources and strengths. We will also disclose information broadly sought by society in a timely and appropriate manner.
We will conduct ourselves with pride and responsibility as a leader in the information communication industry and build trust from society.
- Bringing together individual strengths to fully exploit the integrated strength of the group
We will work to enhance our own capabilities and strive to create a working environment that enables us to exploit those capabilities to the full. We will maximize integrated strength by combining individual strengths to build the strength of the company and enhancing collaboration between group companies.
Chapter 2 defines the specific conduct practices that we should undertake based on the Basic Principles provided in Chapter 1.
Basic Principle 1: Respecting basic human rights
- Recognizing the diverse values of individuals and respecting personal qualities and individuality
We place the concept of respect for human beings, whereby we respect each person as an individual, as the most fundamental value underpinning business activities and will act in every regard in a way that allows the capabilities of the individual to be displayed fully.
- Prohibition of discrimination of any kind
We will not engage in discrimination of any kind that violates basic human rights based on race, ethnicity, nationality, religion, gender, age, physical characteristics or any other reason. In the workplace we will treat people appropriately based on the performance of their work and strive to enable individuals to fully demonstrate their capabilities.
- Prohibition of sexual and power harassment
We will strive to prevent ill feeling among coworkers or degeneration of the work environment due to sexual harassment or power harassment. In cases where such problems do arise, we will strive to cooperate with relevant departments and resolve the issue promptly.
Basic Principle 2: Having high ethical standards and acting as a responsible member of society
In the conduct of business
- Acting with pride as a member of the Toppan Group
We will act with pride as members of the Toppan Group. We will recognize that in addition to the quality of products and services provided, we ourselves are representatives of Toppan and conduct ourselves in a manner that enables us to gain the trust and respect of society.
- Prohibition of tacit approval of illegal conduct and rule violations
If we become aware of conduct in business that violates rules that should be observed such as laws and conduct guidelines, we will not turn a blind eye but promptly report to superiors or relevant departments and work to rectify any issues.
- Respect for foreign cultures and customs
When business activities span into foreign countries, we will ascertain the local social conditions and give full consideration to local culture and customs. We will strive to gain the trust and respect of the local society and carry out business activities based on the foundation of a relationship of mutual trust.
In our private lives
- Prohibition of conduct that causes distress to other people
In our private lives we will not engage in conduct that causes distress to other people such as conduct that causes harm to others, deceives them or that is improper. Each person is to act with care and be fully aware that even conduct in our private lives can significantly damage the trust of the Toppan Group.
- Prohibition of drink-driving
We will under no circumstances engage in drink-driving, which is the cause of serious accidents. If we encounter a person who has consumed alcohol and is attempting to drive a vehicle, we will stop them. We will not encourage people who will be driving a vehicle to consume alcohol, nor will we offer a vehicle to someone who has consumed alcohol. We will not violate traffic rules in any way, including speed violations and ignoring traffic lights.
- Prohibition of the possession and use of illegal drugs
We will not possess or use any illegal drugs and will not be involved in anyway in their manufacture, trade and distribution. When traveling to foreign countries, we will conduct ourselves in accordance with domestic laws in this regard.
- Prohibition of gambling
We will not engage in gambling activity of any kind whether it be betting on golf, mahjong, sports matches or any other event regardless of the value of the bet. Each individual is to recognize that gambling is a crime and conduct themselves accordingly.
Basic Principle 3: Complying with laws and company rules and conducting fair business operations
- Prohibition of collusion and cartels
We will carry out business activities in compliance with anti-monopoly laws. In dealings with public offices in particular, we will not be involved in collusion whereby items such as bidding prices, potential bidders and quantities are set, nor will we participate in cartels that obstruct fair and free competition between other companies with which we have a competitive relationship.
- Prohibition of improper conduct in dealings with business partner companies
In dealings with cooperating companies such as suppliers and cooperating factories, we will conduct fair business transactions on an equal footing. We will comply with laws relating to subcontracting transactions and act to ensure that transactions are fare. We will not use our position as ordering party to force other parties to buy goods or services or act in a way that gives preferential treatment to a certain party or parties.
- Prohibition of improper conduct against competitors
We will not engage in improper conduct towards companies with which we compete. We will not obtain information on competitors by improper means or make any libelous accusations that could hinder sales activities and we will engage in fair and open competition.
- Prohibition of false transactions
We will under no circumstances carry out false transactions or interventional transactions that have no substance. We will conduct business with a firm awareness that sales are limited to items realized through the actual sale of products or provision of services. We will also take great care to ensure that we do not become involved in any illicit trading such as circular (round-trip) transactions.
- Respecting business partners' standpoints and building appropriate relationships with customers
We will recognize all partners in business dealings as valuable business partners, give consideration to the other party's perspective and strive to build an appropriate business relationship that contributes to mutual growth.
- Prohibition of bribery and inappropriate entertainment practices
We will not engage in bribery such as extending gifts to or facilitating entertainment for public officials. We will not engage in any illegal bribery towards public officials of the state or public bodies, as wells as employees of public-interest corporations, corporate employees on a par with public officials and public officials of foreign countries. Business entertainment involving business partners in the private sector is to be conducted within the boundaries of societal common sense whether we are entertaining or being entertained.
- Prohibition of illegal political contributions or donations
We will not make illegal political contributions or donations. We will not make illegal political donations that violate political funding laws to political parties, individual politicians or political funding organizations under the pretext of donations, membership fees or parties.
- Prohibition of insider trading
Regardless of whether it pertains to the shares of our own company or of another company, we will not engage in insider trading that impairs the fairness of securities markets. We will handle undisclosed important internal information that could influence securities markets as insider information until it is properly disclosed and will not use it for illicit securities trading.
- Prohibition of illicit import and export transactions
In importing and exporting products and technology, we will comply with related laws and regulations. In particular, in the case of exports we will carefully check that products and technology are not used for weapons or exported to restricted regions and we will conduct business appropriately overseas.
- Prohibition of child labor and forced labor
In striving for the protection of children's rights and the promotion of welfare, we will comply with international agreements and domestic laws related to the prohibition of child labor. We will also not implement forced labor. We will demand the prohibition of child labor and forced labor from domestic and overseas companies that we deal or cooperate with and will not have any dealings with companies that engage in such activity.
- Compliance with international rules and local laws in overseas business
When conducting business overseas, we will comply with international treaties and the laws of each country or region. Naturally, we will not violate local laws intentionally and we will take the greatest care not to violate them due to negligence or oversight.
Compliance with company rules
- Maintaining discipline and order in the workplace
We will maintain discipline and order in the workplace and take care not to cause any obstruction to work. We will not conduct personal activities at the company such as bringing dangerous items to the workplace or engaging in solicitation that is not related to work.
- Prohibition of other work without the company's permission
We will not engage in other work without the permission of the company. While we are employees of the company, we will not engage in other work, even for a short period, and we will devote ourselves to our work.
- Prohibition of conduct that causes a conflict of interests with the company
In our relationship with the company, we will not act in a way that causes a conflict of interest between the company and ourselves. We will not be involved in any business that is in competition with the company without the company's permission.
- Prohibition of receipt or provision for personal gain or rebate
We will not use our position in business dealings or daily work to demand rewards including money and gifts or services such as meals and entertainment, nor will we press any party with such conditions tacitly for personal gain. We will not offer personal benefits or rebates that breach laws or are ethically questionable to other parties.
- Appropriate management of assets entrusted to the company by customers
In all departments we will manage assets such as manuscripts and data entrusted to us by customers appropriately and in line with company rules. We will take great care not to cause problems for the customer such as loss, damage or leakage of assets that are entrusted to us.
- Appropriate management and use of company assets
We will manage the company's tangible and intangible assets appropriately and not cause damage to the company. We will not mix private and public affairs such as by using company equipment or machinery for personal purposes unrelated to our work. We will not dispose of company assets or remove them from company premises without following the correct procedures for doing so.
- Prohibition of prejudicial treatment of persons that have reported problems via the appropriate procedure
In cases where an issue regarding conduct that violates laws or company rules has been raised in good faith following the appropriate procedure, we will protect the privacy of the individual that has raised the issue and will not treat them unfairly. We will not allow discrimination or any retaliatory action against such a person.
- Fulfilling duties with integrity
We will correctly recognize our roles and fulfill our job responsibilities with integrity based on those roles. We will not act irresponsibly by failing to perform the work that has been given to us or neglecting our duties without a legitimate reason.
- Reporting promptly and appropriately
In cases where it is necessary to report to superiors or related parties, we will report promptly and appropriately. In order to do this, we will always accurately record the requests and inquiries of customers based on fact. Even if the facts present a situation that is disadvantageous to us, we will under no circumstances intentionally make false reports or conceal the truth.
Basic Principle 4: Avoiding all links with antisocial groups
- Prohibition of any dealings with antisocial groups
Regardless of name or characteristics, we will not conduct any transactions at all, including normal business transactions, with individuals or groups (antisocial groups) that attempt to benefit unjustly by using means such as violence, abuse of power or deceit.
- Prohibition of involvement in antisocial activities
We will under no circumstances participate in antisocial activities. Both in business and outside of business, we will not support, cooperate with, consent to or participate in any other way with groups that engage in antisocial activities such as violence or organized destruction, or with organizations that infringe human rights or engage in inhumane acts.
- Prohibition of provision of unjust benefits
We will not provide benefits to any individual or group that engages in antisocial activities. We will not associate with such individuals or groups under any circumstances and will not engage in any other activity that provides them with benefits such as the provision of money and goods or the purchase of items such as books and informational publications. In our relations with shareholders, we will not extend benefits such as information that could be advantageous to specific shareholders or engage in any act that is detrimental to society or other shareholders.
Basic Principle 5: Striving to improve quality and providing creations that contribute to customer satisfaction
- Making our best efforts for the customer and building a relationship of trust
We will put customers first, make every effort to respond to their requests and build a strong relationship of trust with them. We will always put ourselves in the position of the customer, listen to the customer's opinions sincerely and respond to them with integrity. If a problem arises with a product or service that we have provided to a customer, we will respond promptly, appropriately and with sincerity.
- Striving to improve quality in every process
We will recognize the products and services that we provide to customers as creations and will all strive to improve quality based on the concept of Total Quality Assurance where we pursue quality in all processes including not only departments directly involved in manufacturing and quality control, but also departments handling functions such as sales, planning, research & development and administration.
All employees are to take great care to ensure that they do not produce defective products in their own areas of responsibility or pass on defective products to the next process.
- Fully ensuring the safety and security of products and services
We will fully ensure the safety of products and services in providing them to customers. We will also always take the perspective of the user in developing products and services that can be used assuredly.
- Prohibition of the infringement of the intellectual property rights of others
We will strive not to infringe the intellectual property rights of others or rights stipulated in duly concluded contracts, and will act so as not to cause problems for customers.
Basic Principle 6: Recognizing the importance of information related to business and managing it appropriately
- Protecting information regarding customers
We will not disclose information pertaining to customers to other parties without the prior permission of the customer. We will manage customer information obtained during the course of business as confidential information in line with the company's rules on information security.
- Protecting the company's confidential information
We will not disclose or provide the company's confidential information to parties outside the company without following the proper procedures. We will also protect the company's confidential information in our private lives and act in full awareness of our obligation of confidentiality after leaving the company.
- Appropriate handling of personal information
We will thoroughly protect customers' personal information (name, address, age etc.). We will only handle personal information within the scope specified by the customer and will not use or provide it for any other purpose. In order to prevent risks such as loss, leakage or unauthorized access, we will implement thorough management of all personal information including information on employees.
- Striving for the appropriate management of information and records
We will store and manage important documents and data appropriately. We will appropriately manage information and records that are essential for the company's business activities such as contracts, operating licensees, registration certificates and the minutes of important meetings.
Basic Principle 7: Proactively undertaking conservation of the global environment
- Striving to reduce the environmental burden of business activities
In our business activities we will strive to reduce environmental burden by promoting eco-protection activities such as the effective use and saving of resources and the separation, appropriate processing and recycling of waste. In addition to initiatives as a company, we will also proactively take measures as an individual where possible in our daily work such as setting the temperature of air conditioning equipment.
- Promoting businesses with consideration for the environment
In order to create a better global environment, we will proactively advance eco-creative activities such as the planning, research, development and sales promotion of environmentally friendly products. We will contribute broadly to the conservation of the global environment through the products and services that we provide.
Basic Principle 8: Embracing change and taking on new challenges
- Making proposals that embrace change to customers
We will accurately identify changes in the environment and markets and make proposals that are ahead of the times to customers. We will strive to be the first port of call for customers by thinking from the other person's perspective, communicating with the customer, and making beneficial proposals that contribute to resolving their challenges.
- Advancing technical development that meets the needs of customers
While identifying technology trends that preempt changes in the market, we will proactively engage in technological development to enable us to provide attractive creations that meet the needs of customers.
- Having an awareness of problems and striving to improve the status quo
We will not be bound by traditional methods but will proactively make improvements by approaching our work with a problem-solving mindset. This will enable each of us to grow, enhance the quality of our work and earn further trust from customers.
- Striving to enhance one's knowledge, skills and techniques
We will work to refine and improve the knowledge, skills and techniques that are related to our work. In our everyday work, we will improve our individual capabilities, teach each other, and share knowledge, skills and techniques.
- Securing and using intellectual property
We will proactively secure and use inventions, creations, technologies, business models and other items that arise in our sales, research & development and production activities as intellectual property rights. We will also share accumulated experience and know-how as valuable assets.
Basic Principle 9: Building trust from society through social contribution activities and appropriate disclosure of information
- Proactively participating in the company's activities to contribute to society and local communities
As corporate citizens, we will fully recognize the importance of activities undertaken by the company to contribute to society and local communities, and will also proactively participate and cooperate as individuals.
- Contributing to the development and passing on of skills and culture
We will consider the skills acquired in business activities to be assets of the company, industry and society, refine the skills passed down to us by our predecessors and pass those skills on to future generations. We will also contribute to the development and passing down of culture through our business activities.
- Disclosing information appropriately and enhancing the transparency of business activities
We will disclose information sought by society in a timely and appropriate manner and enhance the transparency of business activities. We will fulfill our responsibility of accountability to all stakeholders and conduct ourselves in a manner which enables us to earn the trust and respect of society through constantly being mindful of communication with society.
Basic Principle 10: Bringing together individual strengths to fully exploit the integrated strength of the group
- Striving to create a lively and vibrant workplace
We will create a lively and vibrant workplace. We will place importance on communication and teamwork, work together to enhance our attitudes to work and cooperate to achieve the goals of the organization.
- Striving to create a safe and clean workplace
We will all be proactive in ensuring that the working environment is safe and clean. In order to prevent labor accidents, we will always keep the workplace clean, organized and tidy, and take care together. In the event of an accident, we will act appropriately and promptly based on the company's instructions.
- Taking pride in the Toppan Brand and striving to cultivate it
We will take pride in being a member of the Toppan Group and provide creations that satisfy customers throughout the world. The Toppan Group will work together to cultivate the Toppan brand and enhance the corporate value and character of the group as a whole.
- Group companies working together to maximize integrated strength
We will respect the standpoints of each Toppan Group company, enhance their competitiveness in their unique fields, strengthen mutual support and cooperation, and maximize the integrated strength of the Toppan Group as a whole.