Contents

Introduction

Management

Social (S)Environment (E)Governance (G)Recognition / Assurance

Corporate Governance | Risk Management | BCP / BCM | Strict Compliance | Information Security | Tax Governance

Strict Compliance
Basic Approach
Approach

Legal compliance in business operations is an indispensable

help shape a sustainable society.

the legality of the execution of job duties. The ComplianceDepartment set up under the Legal Division coordinates withMore details on the TOPPAN Group Conduct Guidelines
https://www.holdings.toppan.com/en/group/conduct-guidelines.html

the legal departments and other related sections of oursubsidiaries to secure legal compliance and establish corporate

condition that every corporation must satisfy to fulfill its

ethics across the Group. A Conduct Guidelines Promotion

responsibilities to society. The TOPPAN Group firmly believes

Leader (“Leader”) system supports guideline compliance inthat every person working in the Group must fully recognize theimportance of compliance, make proper judgments, and act with

Compliance Promotion Structure

integrity under high ethical standards by respecting laws,

Promotion framework

regulations, in-house rules, social norms, and other standards ofThe TOPPAN Group Conduct Guidelines have been formed as aconduct.

set of basic rules to be fully observed by employees to ensure

workplaces in the Group. Leaders appointed under the system
work to enforce guideline compliance in daily operations under
the Director in charge of Conduct Guidelines Promotion.
Specifically, the Director in charge of Conduct Guidelines
Promotion (Executive Vice President & Representative Director)

Risks related to compliance increase as we globalize ourbusiness and intensify our operations beyond borders.
In 2000 we established a set of Conduct Guidelines based

Structure to Promote the Conduct Guidelines

on the Corporate Philosophy and Corporate Creed. The

President & Representative Director

guidelines were, and continue to be, a collection of fundamental

Director in charge of Conduct Guidelines Promotion

provisions that set out the basic concepts and behavioral norms
for employees to follow in accordance with corporate ethics andCompliance Department, Legal Division

the principles of legal compliance. Ten years later, in response
to shifts in business environments and social conditions, we
completely revised the guidelines into the TOPPAN Group
Conduct Guidelines, a set of principles that all Group companies
around the world are required to observe. A second full-fledged
revision of the guidelines took place in April 2021, based on acomprehensive review conducted in 2020. The latest Basic
Principles in the guidelines call upon Group employees “(to)achieve a sustainable society” and strive for “personneldiversity,” a “rewarding work environment,” and othersustainability requirements. The latest guidelines will guide

Business Divisions

Head Oﬃce Divisions

Division heads

Conduct Guidelines
Promotion Supervisor
Head of Legal Division

Conduct Guidelines Promotion Supervisors
Person in charge of management: Business Strategy Department GM
Person in charge of education: General Aﬀairs Department GM
Conduct Guidelines
Promotion Leaders in sales
and planning departments

Conduct Guidelines Promotion
Leaders in administrative
departments

Conduct Guidelines Promotion
Leaders in manufacturing
departments

Conduct Guidelines
Promotion Leaders

Supervisors in each department

Supervisors in each department

Supervisors or educational
leaders in each department

Supervisors in each department

accelerated efforts to address the material issues propounded inEmployees

the TOPPAN SDGs STATEMENT , and observance of them will

144

Employees

Sustainability Report 2023

ContentsIntroduction

Management

Social (S)Environment (E)Governance (G)Recognition / Assurance

Corporate Governance | Risk Management | BCP / BCM | Strict Compliance | Information Security | Tax Governance● Cases involving anti-collusion measures

heads the Leader system and supervises compliance promotion

enhance the effectiveness of training sessions through activities

activities. The Leaders appointed at workplaces arrange training

such as group discussions using case methods describing actual

Added bid-rigging cases to present key points on proper

programs at their sites and report locally arising questions andincidents. Thirty-eight online training sessions for 1,150 Leadersbidding, as we are winning more contracts for public work

consultations to the Director in charge of Conduct Guidelines

were held across the Group in Japan in fiscal 2022.
Employees who wish to get a better understanding of thePromotion via administration offices.

projects.
● Cases involving sustainable procurement

Conduct Guidelines can read through the Conduct Guidelines

Added cases involving sustainable procurement focused on

meanwhile, stipulate disciplinary actions for serious violations

Casebook , which is especially useful for employees who havetransactions with suppliers and subcontractors, as societyof laws, regulations, the Conduct Guidelines, and other in-house

doubts or wish to receive guidance on handling daily operations.

requires us to fulfill our corporate responsibilities throughout

rules. Our personnel performance evaluations and evaluations

We reviewed and revised the Casebook on April 1, 2022.

the entire supply chain.

Disciplinary provisions in our employment rules,

for bonuses and annual salary revisions also weight criteria

The latest casebook responds to shifts in social conditions,● Cases involving quality

focused on legal compliance, corporate ethics, andlegislative amendments, and other circumstances surrounding

Added cases involving falsified quality results linked toenvironmental protection, to better ensure that our social

the Group by consolidating and modifying cases presented inproducts and services, as conspicuous instances are emerging.

obligations are optimally fulfilled.

the earlier edition while adding new cases associated with

Clearly indicated that falsified quality results can incite claims

emerging risks in general or in our recent business operations.
The Compliance Department in the Legal Division, meanwhile,

Conduct Guidelines Promotion Leadersof contract violation and damage our social credibility.
● Cases involving diversity & inclusion

posts monthly Conduct Guideline Notifications on topics

Added cases that deepen employee understanding of diversity

Seven hundred and seventeen Leaders were newly deployed

relevant to the guidelines at workplaces to ensure strictand inclusion in the workplace in accordance with “promoting

across the Group in fiscal 2022, including 124 women (17.3% ofcompliance under the Leaders. We have also been holding

diversity and inclusion,” a basic principle added to ourthe Leaders). A cumulative total of 12,562 employees haveseminars, producing posters, and implementing otherworked as Leaders since the system was launched in fiscal 2004.
No. of Newly
Deployed
Leaders

No. of Female
Leaders
Deployed(percentage)

Cumulative
Total No. ofLeaders

Fiscal 2019

68887（12.6%）

10,420Fiscal 2020

712

98（13.8%）

11,132

Fiscal 2021

713

115 (16.1%)

11,845

Fiscal 2022

717

124 (17.3%)

12,562compliance promotion activities to secure full observance of theguidelines among Group employees.
We have applied the TOPPAN Group Conduct Guidelines

Training, education

Group training sessions for Conduct Guidelines Promotion

Substantially revised the existing cases involving intellectual
property in order to cover trademark rights, design rights, andto overseas subsidiaries and held briefing sessions tothe steps we are taking to file more patent applications fordisseminate the guidelines and promote strict compliancetechnologies and business models with a view to “securingglobally.

and using intellectual property” as stated in the Conduct
Guidelines.

Main Revisions in the Conduct Guidelines Casebook● Cases involving human rights

Compliance Training

Conduct Guidelines in the 2021 revisions.
● Cases involving intellectual property rights● Cases involving BCP
Added cases involving earthquake preparations and actions to
be taken when a quake strikes, in order to minimize damage

Added human rights cases to alert employees to potential

to our business activities in the event of an earthquake

problems involving privacy invasion (one of the six forms ofstriking directly beneath the Tokyo metropolitan area or“abuse of authority” designated by the Japanese Ministry ofoccurring on the Nankai Trough, an ocean-floor trench off theHealth, Labour and Welfare), child labor, forced labor, andcoast spreading from Shizuoka to Kyushu, Japan.

other global human-rights abuses.

● Cases involving cyber security
Called attention to the risk of business email compromise

Leaders (“Leaders”) are organized every year. We devise ways to145

Sustainability Report 2023

Contents

Introduction

Management

Social (S)Environment (E)Governance (G)Recognition / Assurance

Corporate Governance | Risk Management | BCP / BCM | Strict Compliance | Information Security | Tax Governance(BEC) and required employees to use a “suspicious-emailfacilitation payments” (payments to facilitate or expedite routine

report form” on our internal website to report fraudulent

governmental services such as visa issuance or customs

email messages as soon as they are detected. These
safeguards have high priority, as a surge of BEC incidents andIllegal contributions and funding provision are also
comprehensively prohibited throughout the Group. Any form ofconsiderable damage.

association or contact with anti-social forces, for example, isclearly prohibited in the TOPPAN Group Conduct Guidelines

We have not been involved in any serious incidents or violationsof laws or regulations in the course of business in fiscal 2022.

(million yen)

Fiscal
2019

Fiscal
2020

Fiscal2021

Fiscal2022

0000

Expenditures for politicalactivities and payments topolitical groups

7.9

7.7

7.6

7.8

Expenditures to industry
groups and others

21.3

21.5

21.9

22.0

0000

29.2

29.2

29.5

29.9

clearance) to public officials.

other cyber-attacks against corporations have been causing

Compliance in Fiscal 2022

Political Contributions and Other Expenditures

and the Guidelines on Dealing with Anti-social Forces. No casesof inappropriate entertainment or gifts to public officials or thelike were identified in fiscal 2022.
In training sessions organized each year for candidates for

Lobbying activities

Other (expenditures related
to proposed voting legislationand national referendums)

overseas assignments, trainees learn reinforced strategies toAnti-Corruption Initiatives
PolicyActivity results, performance data

Total

combat bribery in the commercial and public sectors andbecome familiar with the pre-authorization system. Twenty-six
employees attended six sessions in Japan in fiscal 2022.
We have also been formulating anti-bribery rules forTraining for Compliance withTransaction-related Legislation

We have been undertaking various anti-corruption initiatives inoverseas affiliates across the Group. Rules of this type wereconformance with the anti-corruption principles set out by theestablished at Group affiliates in Shanghai, China in fiscal 2021.

United Nations Global Compact. The TOPPAN Group Conduct

Briefing sessions were held for Shanghai-based employees inTo observe major transaction-related laws and regulations, we

Guidelines affirm wide-ranging principles on corruption

fiscal 2022.

have been promoting compliance with the Subcontract Law ofprevention, such as the “prohibition of bribery and inappropriate

We continue to win more contracts with national and local

PolicyTraining, education

Japan and comprehensively preventing improper import andentertainment practices,” “prohibition of receipt or provision forgovernments. To ensure proper compliance and conduct, we

personal gain or rebate,” “prohibition of illegal political

held a series of training sessions on antimonopoly legislation incontributions or donations,” and “prohibition of collusion andfiscal 2022. A total of 1,597 persons, primarily from related

that customarily conduct transactions with subcontractors werecartels.”companies, attended the sessions.

trained on compliance with the subcontract law, and 10,336

export transactions.
In fiscal 2022, a total of 2,644 employees from departmentsTo better combat bribery, we established a set of anti-employees took an e-learning course on export controls underbribery rules and guidelines in March 2017 and formulated an

the Foreign Exchange and Foreign Trade Act of Japan. We alsoanti-bribery framework led by the Director in charge of theaudited compliance with the subcontract law in 62 departments

Legal Division as the chief anti-bribery manager. For more

and the observance of export controls in 35 departments.

intensive anti-bribery control, we launched a system requiring

The audits in fiscal 2022 confirmed conformance with thesepre-authorization for the offering of any entertainment or gifts tolaws across the Group. No serious legal violations or cases ofa public official or the like. An FAQ describing specific cases of

misconduct were identified, and no problems or incidents

bribery was issued in April 2018 to further heighten employee

occurred in transactions with subcontractors or import or export

awareness and call strict attention to compliance-related issues.

transactions.

As a basic rule, employees are prohibited from making “small146

Sustainability Report 2023

Contents

IntroductionManagement

Social (S)Environment (E)Governance (G)Recognition / Assurance

Corporate Governance | Risk Management | BCP / BCM | Strict Compliance | Information Security | Tax GovernanceInternal Reporting System
SystemActivity results, performance data

Number of Internal Reports
The TOPPAN Group Helpline was used in 17 cases in fiscal

When a person discovers a legal violation or improper conduct

2022. No serious legal violations or cases of misconduct were

somewhere in the Group, the person is to report it to theirreported. Twelve of the helpline reports were on harassment. Insuperior for deliberation as a basic rule. If the problem is not

the remaining five cases, the reporting contact called for

resolved by their own department, the person is encouraged toimprovements in work processing. Every case was properly

call the TOPPAN Group Helpline, our internal reporting system.

handled and followed up with necessary countermeasures toThe helpline is open for use by all officers and employees

prevent recurrence.

(including dispatched staff and part-time workers) at Group
companies (excluding listed corporations). This system allows
us to ensure strict compliance with the TOPPAN Group Conduct
Guidelines by promptly identifying and properly dealing withlegal violations and misconduct.
We revised the rules on reporting in November 2019 toencourage Group personnel to call the helpline by lowering thethreshold for use. The revised rules stipulate the establishmentof three portals to receive reports: a “corporate portal” and “audit& supervisory board member portal” operated in-house, and an“external portal” operated by legal consultants. The receiver has
thus been changed from the President & Representative Directoror Senior Audit & Supervisory Board Member to the threeportals that have been in operation since April 1, 2020. The
President & Representative Director currently serves as thechief manager of the helpline.
Our internal website, meanwhile, posts topics on the intent
of the reporting system, system outlines, and precautions
regarding calls placed to the helpline, along with other helpline
information. We also hold rank-based training, training for new
employees, and other types of training to inform Group
personnel about the system.
Reporting rules were further revised in May 2022 to ensure

TOPPAN Group Helpline
Reporting contact

When the problem
remains unresolved

Any Group oﬃcer or employee
Reporting andconsultation

Superior
Internal reporting(an email or sealed document sent in thename of the person reporting as a basicrule; anonymous reporting is available
through the external portal)

Three portals to receive reports
Corporate portal

Compliance Committee

Audit & supervisoryboard member portal

Senior Audit & Supervisory
Board Member

External portal*

Legal consultants
Instructions

Reporting

Department responsiblefor investigation and countermeasurescompliance with the amended Whistleblower Protection Act
enacted in Japan in June 2022.

Reporting on
progress andresults, follow-up
communication(as of October 1, 2023)*The Compliance Committee investigates issues reported to the external
portal and considers and formulates measures, etc. to handle them.

147

Sustainability Report 2023