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Toshiba strives to ensure compliance with laws and regulations, social norms and ethics, and internal rules throughout its worldwide operations. Indeed, accordance of the top priority to human life and safety and to compliance in everything we do underpins our commitment to promoting business activities through fair competition and serving the interests of customers to the best of our ability.
Toshiba Group Compliance Policy
- We place the highest priority on complying with laws and regulations, being sensitive to social standards and behaving ethically in all of our business activities.
- We enforce the Toshiba Group Standards of Conduct Groupwide to stress the importance of compliance.
- We strive to raise awareness of compliance through continuous education and audits, ensuring that compliance becomes a part of our corporate culture.
Toshiba is striving to ensure compliance with laws and regulations, social norms and ethics, and internal rules throughout its worldwide operations. Indeed, accordance of the top priority to human life and safety and to compliance in everything we do underpins our commitment to promoting business activities through fair competition and serving the interests of customers to the best of our ability.
We consider thorough adherence to the Toshiba Group Standards of Conduct (SOC) - a statement of principles informed by the Basic Commitment of the Toshiba Group - to be the foundation of compliance. All our subsidiaries have adopted the SOC and we are inculcating the same throughout Toshiba Group worldwide.
Every year, priority themes on compliance are set in light of business circumstances and promoted. By implementing a Plan-Do-Check-Action (PDCA) cycle of self-assessment, not only at Toshiba but also at group companies worldwide, we are stepping up our efforts to ensure compliance.
In fiscal 2007, setting compliance with antitrust legislation worldwide and prevention of bribery overseas as priority themes, we established new guidelines and implemented a stricter mechanism for ensuring compliance, including education, monitoring and mechanisms designed to preclude violations.
Toshiba's Risk-Compliance Committee chaired by the Chief Risk-Compliance Management Officer (CRO), acting in cooperation with the divisions concerned, determines and implements measures to deal with major risks, avert emergence of new risks, and prevent recurrence. In-house companies and group companies worldwide have put in place similar risk compliance management structures.
Risk Management and Compliance Structure  |
Any violation of compliance is handled conscientiously, including appropriate and timely disclosure as well as the imposition of disciplinary sanctions on the offenders.
It is a matter of profound regret to us that one of our group companies which violated the Antimonopoly Act in the course of bidding for medical systems was imposed upon a cease and desist order by the Japan Fair Trade Commission. We are resolved to prevent recurrence through strict enforcement of the above-mentioned compliance measures.
In January 2000, Toshiba introduced a Whistleblower system, namely, “Risk Hotline”. Using the system, employees can report their concerns or seek advice via the intranet or by phone so that internal risk information is directly obtained in advance and any breach of compliance is either prevented or nipped in the bud.
In accordance with the Toshiba Group Standards of Conduct, which requires Group-wide companies to establish in-house information reporting systems, group companies around the world have also introduced such systems.
Due care is exercised so that Whistleblowers do not suffer any disadvantage.
Toshiba's Whistleblower System  |
The Legal Affairs Division exchanges information with the Corporate Audit Division regularly in order to clarify the state of implementation with respect to the various compliance measures. Based on the actual situation, steps are taken to enhance the effectiveness of management audits and the audit results are reflected in compliance measures.
Every year Toshiba conducts an intranet-based employee survey on the Toshiba Group Standards of Conduct (SOC). The results are used in formulating measures for raising awareness on compliance. According to the results of the fiscal 2007 survey, 97.3% (97.1% for fiscal 2006) of respondents replied that they comply with the SOC. While the survey results indicate employee awareness on compliance as trending upward, we will continue to implement measures to reinforce this positive trend.
Booklets on Toshiba Group Standards of Conduct in various languages 
Education on ethics for engineers Education on the Toshiba Group Standards of Conduct plays a pivotal role in ensuring compliance. Apart from providing new employees, managers, etc. with education appropriate to their responsibilities, we hold seminars for directors and executive officers, with lawyers and other specialists invited as speakers. Also, we provide e-learning for all employees on a continuous basis. In fiscal 2007, initiatives to strengthen compliance education included the publication of booklets on SOC designed to enhance the awareness of employees of subsidiaries overseas. Also, we created new educational materials with easy-to-understand case studies on compliance appropriate for different work positions. We introduced ethical education for engineers in fiscal 2006 to raise engineers' awareness of the central importance of fairness and integrity in their work. In fiscal 2007, engineers overseas received this education, and e-learning was provided to engineers at group companies in Japan. |
The Toshiba Group Standards of Conduct stipulates that Toshiba Group shall not provide inappropriate benefits or favors to any politician or political organization.
In the case of offering political contribution, procedures in accordance with internal rules are followed as well as compliance with the Political Funds Control Law in case of Japan is strictly ensured.
Failure to respond appropriately to large-scale disasters, such as earthquakes, typhoons, floods, etc., could result in long-term closure of operations, resulting in a great financial loss and a large impact on stakeholders.
In addition to measures to ensure the safety of employees and their families, support recovery of devastated areas, and maintain business sites and factories in the event of natural or other disasters, Toshiba established a Business Continuity Plan (BCP) in fiscal 2006 covering those businesses that have large social and economic impacts in order to minimize any interruption in the supply of products and services. We are continually updating the BCP and intend to expand its scope geographically and also in terms of products and services. The risk of outbreak of new types of influenza is also reflected in the BCP.
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