About Toppan’s Conduct Guidelines
Toppan’s Conduct Guidelines set out the basic concepts and behavioral norms to enable everyone who works at Toppan to act in accordance with legal compliance and corporate ethics. They are comprised of a total of 71 clauses divided into two chapters.
The Conduct Guidelines were established in June 2000. They have subsequently been revised three times to further enhance compliance management. In 2010, when Toppan marked 110 years since its founding, the Conduct Guidelines were revised extensively and positioned as guidelines shared by the entire Group in order to drive globalization and Groupwide management. The most recent revision, in 2021, is conscious of the Sustainable Development Goals (SDGs), the focus of increasing interest throughout the world in recent years. The revised guidelines aim to accelerate efforts to address material issues identified in the TOPPAN SDGs STATEMENT and ensure that such efforts are supported by appropriate conduct in order to help shape a sustainable society.
Being a company trusted and respected by society
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 work on resolving social issues, such as health, food, education, environmental and climate changes, resources and gender equality. Through undertakings such as these, we must actively contribute to the realization of an interactive and 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 placing importance on corporate ethics. In performing our work there is absolutely no room for violations of laws 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 Toppan Group’s business activities.
These Conduct Guidelines are rooted in our Corporate Philosophy and Corporate Creed and set out our conduct models which allow Toppan to take a big leap as a social value creating company. We must all read these Conduct Guidelines thoroughly and act upon understanding and in accordance with 2 them so that we are trusted and respected by society and keep our status as a social value creating company.
Chapter 1 – Basic principles
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.
1. Respecting human rights
Based on the concept of respect for people, we will respect human rights, protect individual dignity in every regard and will not engage in discrimination in any way. We will promote initiatives while considering not to have a negative impact on human rights through our business operations and respond to any such impact when it occurs. We will also encourage any business partner who is directly related to our businesses, products or services to respect human rights if such person is involved in a negative impact on human rights.
2. 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.
3. 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.
4. Proactively undertaking preservation of the global environment to achieve a sustainable society
In our business activities, we will use limited resources effectively and promote efforts to contribute to the preservation of the global environment. We will also commit to reducing environmental burden in the entire supply chain inside and outside the company through eco-friendly products and services and strive to realize a sustainable society.
5. Striving to improve quality and providing dedicated products that contribute to customer satisfaction
Considering our products and services provided to our customers as dedicated products, we will strive to ensure safety and improve quality based on “Total Quality Assurance,” the concept to work on quality creation in all processes undertaken by the entire supply chain, not just those in departments directly involved in manufacturing and quality control. In addition, we will make efforts to improve, upgrade and develop our products and services by determining the needs of various customers so that we can gain credibility and provide customers with satisfaction.
6. Respecting personnel diversity and striving to create a rewarding work environment that is physically and mentally healthy
We will acknowledge and respect each other’s personal qualities and differences of values so that each of us utilizes and enhances our diverse abilities, and we will maximize the Group’s total power by gathering such individual powers. We will also work to secure work safety and maintain and promote physical and mental wellbeing as well as to strive to create a rewarding work environment that is mentally and physically healthy so as to continue fulfilling our abilities.
7. Embracing change and taking on new challenges
We will accurately identify changes in the business environment and markets, see such changes as our opportunities for growth and take the challenge of exploring new possibilities. We will find solutions to social issues through our business and continue to provide values that society requires.
8. Recognizing the importance of and properly managing business-related information and information process system
We fully acknowledge the importance and values of business-related information, such as confidential and personal information, information process system and network in general. We will take adequate security measures, in accordance with rules, against internal and external risks that may cause leak and failure and ensure proper management so as to provide new values to our customers.
9. Providing organizational risk management and control thoroughly against threats that have a serious impact on our corporate activities
Recognizing that we exercise our social responsibility against natural disasters such as earthquake, wind and rain damages and threats including infectious diseases, terrorism and cyberattack, we will have an emergency measure in place and provide organization risk management thoroughly. In addition, we will take a firm attitude toward anti-social forces and never have any involvement with such forces.
10. Striving to improve corporate value through social contribution activities and proper information disclosure/communication
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 and have a dialogue with a wide range of stakeholders. Through these activities, we will contribute to solving social issues and strive to improve our corporate value.
Chapter 2 – Specific Conduct Guidelines
Chapter 2 sets forth the specific conduct practices that we should undertake based on the Basic Principles provided in Chapter 1. In case of conflict, the national legislation will always prevail.
Basic Principle 1: Respecting human rights
1. Prohibition of discrimination on the basis of race, ethnic group, nationality, religion, sex, age, academic background, career, physical features, disability, sex orientation, gender identity, employment status, lifestyle, values, etc.
We will never engage in discrimination of any kind on the basis of race, ethnic group, nationality, religion, sex, age, academic background, career, physical features, disability, sex orientation, gender identity, employment status, lifestyle, values, etc. 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.
2. Prohibition of harassment of any kind
We will strive to prevent ill feeling among co-workers or degeneration of the work environment due to sexual harassment, power harassment, pregnancy discrimination (paternity leave harassment), harassment concerning sex orientation and gender identity, etc. In cases where such problems do arise, we will strive to cooperate with relevant departments and resolve such issues promptly.
3. Prohibition of child labor or forced labor
We will strive to ensure children’s rights, promote children’s welfare and act in compliance with international agreements and domestic laws and regulations concerning prohibition of child labor. Also, we will never take part in forced labor. Further, we will ask our international and domestic clients and partners to prohibit child or forced labor, and we will never carry out business with companies that are involved in such conduct.
Basic Principle 2: Having high ethical standards and acting as a responsible member of society
1. Acting with pride as a member of 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. We will also act to enhance the corporate value and company ranking of the entire group.
2. Prohibition of tacit approval of illegal conduct and rule violations
When 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.
3. 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.
4. 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.
5. Understanding the characteristics of social media and using it with self-awareness and responsibility as a working professional
We will acknowledge that, when using social media, information once posted on the network, whether for business purpose or personal use, is spread and may not be completely deleted regardless of efforts to do so and that any statement we made personally may impair the trust of the company. For this reason, we will use social media with self-awareness and responsibility as a working professional. When using social media, we will never write any comment that may lead to confidential information, personal data or defamation of our customers.
6. Following traffic rules and striving to drive safe
We will under no circumstances engage in drink-driving which is a cause of serious accidents. If we encounter a person who has consumed alcohol and is attempting to drive a vehicle, we will not fail to 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. Also, we will not violate traffic rules in any way, including speed violations and ignoring traffic lights.
7. Prohibition of possession and use of illegal drugs
We will not possess or use any illegal drugs and will not be involved in any way in their manufacture, trade and distribution. Even when we visit foreign countries for travel or other reasons, we will conduct ourselves in accordance with domestic laws in this regard.
Basic Principle 3: Complying with laws and company rules and conducting fair business operations
1. 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.
2. 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 fair. We will not use our position as ordering party to force other parties to buy goods or services, require inappropriate entertaining, gifts or money or act in a way that gives preferential treatment to a certain party or parties.
3. 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.
4. Prohibition of improper transactions
We will under no circumstances carry out false transactions, interventional transactions or round-trip transactions that have no substance. We will conduct business with a firm awareness that sales are only be achieved through the actual sale of products or provision of services. We will also take great care so as not to be involved in such improper transactions.
5. Procurement with responsibility for enhancing corporate value of both Toppan Group and our customers
Aiming to improve corporate value of both Toppan Group and our customers, we will strive to fulfill our social responsibilities, such as legal compliance, implementation of information security measures and consideration to environment and human rights, in cooperation with our customers, as the entire supply chain. For this, we will procure based on our basic procurement policy and evaluate and select suppliers fairly in accordance with our CSR procurement standards.
6. 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 well 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.
7. 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.
8. 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.
9. 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 diverted to weapons or exported to restricted regions and we will take appropriate procedures.
10. 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＞
11. 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.
12. Prohibition of other work without the company’s permission We will not engage in other work without the permission of the company. When you do a second or side work, you are required to choose a second or side work of which job requirements, working hours, etc. are adequate in light of the company rules. In addition, we will not cause troubles to the company by leaking the company’s business secret outside the company and pay attention not to damage our health due to overwork or not to affect our main job.
13. 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. In the event that conflict of interest may occur or has occurred, we faithfully report such fact to our superiors or relevant departments to avoid such conflict of interest.
14. 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.
15. 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 the company rules. We will take great care not to cause problems to the customer such as loss, damage or leakage of assets that are entrusted to us.
16. Appropriate management and use of the company’s 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.
17. Prohibition of prejudicial treatment of persons who have reported problems or cooperated in investigation 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. Also, we will not treat any person unfavorably on the ground that such person has cooperated in investigation of which origin is such issue raised.
We will not allow discrimination or any retaliatory action against such persons.
18. 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.
19. 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 facts. 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: Proactively undertaking preservation of the global environment to achieve a sustainable society
1. Making efforts to reduce greenhouse gas emission to establish a low-carbon society
We will make efforts to introduce, maintain, monitor and improve efficiency of facilities to use energy without waste. In addition to CO2, we will also strive to ensure leakage prevention, collection and detoxification of fluorocarbons and contribute to prevent global warming.
2. Making efforts to use resources for zero emission to create a recycle-based society
We will make efforts to ensure sorting of emission from our business activities and promote to achieve zero emission. We will also work on eco-conscious design to utilize resources effectively and make efforts to provide products and services in consideration of waste of input resources and recyclability at the time of disposal.
3. Making efforts to take environmental risk measures
We will monitor the usage of chemical substances used in our products and ensure safety of workplace environment and products. We will also manage chemical substances used, such as chemicals, solvents and ink, to prevent occurrence of leakage, etc.
4. Making efforts to preserve biodiversity
We will actively work on sustainable use of natural resources, such as use of certified forest resources or thinned wood.
We will also make efforts to preserve local biodiversity through environment preservation activities in and outside the workplace.
Basic Principle 5: Striving to improve quality and providing dedicated products that contribute to customer satisfaction
1. Striving to improve quality in every process
Recognizing the products and services that we provide to customers as dedicated products, we 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 such as sales, planning, research & development and personnel. We will also promote establishment of mutual cooperation and trust relationship with our clients and strive to improve quality throughout our supply chain.
2. 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. If a problem arises with a product or service that we have provided to a customer, we will respond promptly, appropriately and with sincerity.
3. Providing products and services that are satisfied by our customers
We will always put ourselves in our customers’ position, understand their needs and establish a strong relationship with them through provision of products and services that are satisfied with them. We will also provide customers with information on the details and handling of our products and services in a proper and easy-to-understand manner. Further, we will listen to customers’ opinions sincerely to improve our products and services and make refinement and development so as to provide a wider range of customers with our products and services.
4. Promoting development of products and services by incorporating a standpoint of universal design
We will contribute to achieve a diversity-friendly, inclusive society through initiatives of universal design as a company that widely influences our daily lives. Through dialogues with various people, we will promote development of products and services that can be used by as many people as possible, regardless of age or disability.
5. Respecting intellectual property rights of others
We will respect others’ intellectual property rights and any other rights that are provided for in duly concluded contracts and will not infringe such rights. We will also consult with the intellectual property department before developing, manufacturing and selling new products, services and technology to confirm if there are any intellectual property rights of others that are questionable.
Basic Principal 6: Respecting personnel diversity and striving to create a rewarding work environment that is physically and mentally healthy
1. Promoting diversity and inclusion
Based on the philosophy of “respect for the individual,” that is to respect each of us as an individual, we will mutually recognize and respect diversity, such as race, ethnic group, nationality, religion, sex, age, academic background, career, physical features, disability, sex orientation, gender identify, employment status, lifestyle and values and also promote “diversity and inclusion” that convert such changes into driving force for innovation. Further, we will promote a satisfying working environment that enables each of us to fully leverage our skills and achieve sustainable growth of the organization and individuals.
2. Striving to create a positive and vigorous workplace
We will create a positive and vigorous workplace.
We will value communication and team work, increase work awareness mutually and cooperate to achieve organizational goals.
3. Striving to create a safe and clean workplace
We all will voluntarily work to make our working environment safe and clean at all times. To prevent industrial accidents, we will always organize and clean our workplace and pay attention with each other. Further, in case of disasters such as earthquake, wind and rain damages and fire, we will follow the company’s instructions and act properly and promptly.
4. Striving to maintain and promote physical and mental health
Based on the idea that physical and mental health is the basis of development of a corporation, we will strive to maintain and promote physical and mental health. We will also participate in health maintenance and promotion programs provided by the company or health insurance association with our family members so that we can work longer and healthy.
5. Maximizing total power by mutual cooperation among Group companies
We will respect the position of each Toppan Group company, and each Group company will increase its competitiveness in its unique field. We will strengthen mutual support and collaboration to maximize total power of the entire Toppan Group.
Basic Principle 7: Embracing change and taking on new challenges
1. Creating new market by making proposals that embrace change to customers
We will accurately identify changes in the business environment and markets and make proposals that are ahead of the times to customers. We will think from others’ prospective, determine customers’ issues through communication, exchange information and have discussions actively within the company and utilize our resources effectively to create new markets.
2. 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 dedicated products that meet the needs of customers. We will also recognize the impact our developed technology has on society and utilize such technology correctly.
3. 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.
4. 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.
5. 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 8: Recognizing the importance of and properly managing business-related information and information process system
1. 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. We will also collect and use data under appropriate rules to provide new values.
2. 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.
3. 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.
4. Striving for appropriate management of information and records
We will appropriately manage information and records that are essential for the company’s business activities such as contracts, operating licenses, registration certificates and the minutes of important meetings as well as records and data from research and development activities such as experiment data and analysis data by taking appropriate security measures against internal and external risks that cause leakage, etc.
5. Striving for appropriate management of information processing system and network
Recognizing that all corporate activities and social life are connected to network, we will properly manage systems and networks that are used for information processing throughout their lifecycles from the introduction, operation, update to disposal.
Basic Principle 9: Providing organizational risk management and control thoroughly against threats that have a serious impact on our corporate activities
1. Simulating emergency and taking precautions
We will simulate emergency cases and take precautions so that we can take appropriate measures promptly. We will also actively participate in practice and training and confirm our and the department’s roles and response procedures. We will identify possible risks and make efforts to reduce each risk. In case such risk becomes obvious, we will follow given policy and procedures and act properly.
2. Acting properly at the time of disaster
In case of occurrence of natural disasters or infectious diseases, we will place top priority on the safety of us, our co-workers and families and act accordingly. Based on our Business Continuity Plan (BCP), we will cooperate with group companies, partner companies and clients for business continuity or speedy restoration of business. In addition, we will promote sustainable working practices through the use of telework, etc.
3. Striving to secure cyber security
We will acknowledge that cyberattacks have become a threat that has a serious impact not only on Toppan Group business activities but also our social life and strive to secure cyber security. We will make efforts to prevent and detect changing threat and make rapid initial response and report to emergency contact if any cyberattack, such as virus infection, is found to minimize the damage.
4. 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.
We will under no circumstances participate in antisocial activities. We will not engage in any other activity that provides individuals and groups that are engaged in antisocial activities with benefits such as the provision of money and goods or the purchase of items such as books and informational publications.
Basic Principle 10: Striving to improve corporate value through social contribution activities and proper information disclosure/communication
1. 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.
2. Passing on of skills and contributing to popularization and promotion of cultures and sports
Considering our skills nurtured in the business activities as assets of the company as well as the industry and society, we will refine the skills passed down to us by our predecessors and pass those skills on to future generations. We will contribute to popularization and promotion of cultures, arts and sports through business activities. In addition, we will engage in dialogue with wider society, work on education, health and social welfare and contribute to resolving social issues. Further, we will support organizations and individuals who are engaged in such activities.
3. Disclosing information and having dialogues properly to establish a trust relationship
We will disclose information sought by society in a timely and appropriate manner and enhance the transparency of business activities. We will also have dialogues with a wide range of stakeholders surrounding Toppan Group and establish a trust relationship.