Violation of Global Code of Conduct & Ethics (COCE)

Violation of Global Code of Conduct & Ethics (COCE)

We require all officers and employees to report any concerns about possible COCE violations promptly through the proper channels, and we guarantee that no retaliatory actions or measures will be taken against the reporter pursuant to internal regulations. The proper channel includes supervisors and the Administrative Unit, as well as our global whistleblower system (described below), which accepts anonymous reporting in more than 150 languages.

On-site inspections by the planning department of each sales division and internal audits by the Audit Department also carefully look for COCE violations.

In addition, starting from the fiscal year ending March 2024, we have initiated the 'Safety and Compliance Comprehensive Inspection' activities for our major consolidated subsidiaries. In these activities, each company disseminates top management messages and information about our global whistleblower system, and inspects the status of obtaining necessary permits and licenses for their operations and compliance with quality standards related to their products and services. Following these inspections, the responsible executives from Toyota Tsusho verify the implementation status on-site.

We also fully utilize the latest digital tools, such as IT and AI, to analyze a massive amount of data on expenses, sale and purchase accounting and financial statements, etc., and monitor for signs of improper conduct so we can prevent and discover them early. These analysis results are also utilized in the aforementioned on-site inspection activities and internal audits.

If there is a concern about a possible COCE violation, the Compliance & Crisis Management Department, together with related departments such as the Legal Department and the Global Human Resources Department, thoroughly investigate the case and take appropriate action based on the Incident Response Manual, under the supervision of the Board of Directors. To maintain our compliance-related initiatives at the highest level, we will continue to regularly evaluate and validate the current basic policies, the COCE, and the effectiveness of various compliance measures and improve them as needed.

The number of COCE violations in the Toyota Tsusho Group in Japan and overseas in the fiscal year ended March 31, 2024, is shown here below. Note that there were no violations seriously affecting our group’s operation.