Compliance

In order to conduct thorough compliance management, the Toho Titanium Group ensures that all employees are familiar with the Ethical Norms in business for Toho Titanium Group, which set forth 31 codes of conduct, and implements the following initiatives.

The Corporate Ethics Promotion Committee has been established and meets regularly to formulate basic policies for compliance activities, examine priority areas, and confirm/evaluate progress.

We conduct annual compliance inspection to raise each employee’s awareness of legal compliance and to build a more effective legal compliance system.
As laws change, we conduct periodic reviews of laws and regulations related to our business by the person in charge of the relevant department. In addition, we review the daily operations of each workplace objectively from the perspective of compliance, and all employees identify a wide range of concerns on a workplace-by-workplace basis. The department in charge of compliance, which is independent from the business divisions, consolidates and organizes these issues, and when improvements are necessary, it encourages the relevant department to make concrete improvements.

We have established and are operating a “Compliance Hotline” as a whistleblowing system for consultation related to corporate ethics, including prevention of all types of corruption such as fraud, harassment, violation of laws and regulations, corruption and bribery within the organization. The system has an internal contact point (department in charge of compliance) and an external contact point (attorney).

• This system is operated in accordance with whistle-blower protection regulations to prevent any disadvantage to the person who consults with or reports to our company. In particular, information regarding whistle-blowers is provided only to the staff in charge of the contact point to ensure the credibility of the system. (Except in cases where disclosure becomes compulsory in accordance with laws.)
• Independent routes from the management are also secured.
• We maintain the confidentiality of reporters and accept anonymous reports.
• We also respond to inquiries and contacts from all kinds of external parties, including business partners.
• For reports of compliance violations, we conduct fact-finding investigations and make a final determination as to whether or not a violation has occurred. As a result of investigations, corrective measures and recurrence prevention measures are taken for cases where non-compliance is found. In FY 2021, 13 cases were reported and 4 cases were found to be non-compliant.

For reports from outside the company, the following contact desk (internal contact point) will receive the report. If you wish to use an external contact point (attorney), please contact the internal contact point for the information of the external contact point.

Compliance Hotline Desk, Toho Titanium Group
Mailing address: Toho Titanium, JR Yokohama Tower 22nd Floor, 1-1-1 Minamisaiwai, Nishi-ku, Yokohama, Kanagawa 220-0005, Japan
Tel: +81 90 8100 1040 (normally 9:00 a.m. to 5:00 p.m. on business days)
Email: hotline@toho-titanium.co.jp

In order to raise each employee’s awareness of compliance and promote a correct understanding of related laws and regulations, as well as to ensure a thorough understanding of laws and regulations necessary for business operations, we conduct education by job level and education on specific laws and regulations, respectively. The compliance education by job level includes education for directors and managers, education for all employees, and education for new employees in a combination of group and discussion formats. For education on specific laws and regulations, we provide opportunities for more specialized education by appointing in-house or outside instructors.