Compliance

Compliance Structure

Compliance Efforts

Our company has defined the "TPR Group Compliance Basic Rules" and "TPR Compliance Rules", and, based on what has been defined, we promote the maintenance and improvement of group-wide compliance structures.

Every employee follows the "TPR Group Compliance Basic Rules" below in executing their day-to-day business activities.

TPR Group Compliance Basic Attitude

TPR Group and TPR Group companies share that practicing good faith business activities is vital to answering the reliance that stakeholders including customers, shareholders, employees, suppliers and regional societies place in us.

Also, every individual TPR and TPR Group employee confirms that compliance is an important corporate foundation, similar to quality, environment, safety and disaster prevention, and will practice legal compliance etc. with high ethics including Social good, and will work to perform good faith and healthy corporate activities.

1. Good faith behavior
2. Ensuring healthiness and transparency of management
3. Business relationships based on fair and free competition
4. Creating a safe and comfortable workplace
5. Contributing to society

Structure

Based on the rules above, with the Chairman and CEO as the overall responsible person, a "Compliance Committee" made up of Management Meeting members is put in place. With that, each General Manager promotes the maintenance and improvement of compliance structures as the person responsible for promotion.

As the operation secretariat, a Group Governance Oversight Department is set up, with scope over all domestic and overseas group companies to prevent in advance unauthorized actions across all work, such as improper accounting processes, to establish a mechanism for early detection of unauthorized actions, aiming to enhance group Governance. Also, as a mandatory curriculum for employee education, the importance of compliance has been included.

Meeting forum

Compliance Committee

• Twice per year. (First half year, second half year)
• The main agenda is compliance-related activity results reporting, activity plan discussion and review of compliance matters, etc.
• At the meetings below, the top management message for compliance activity promotion is disseminated, the policy/plan discussed at the Compliance Committee, and the dissemination and circulation of compliance activities is carried out.
  ・Company-Wide Management Meeting (global based)
  ・Company-Wide Compliance Meeting (scope is Domestic Locations)
• Also, at the Board Meeting, the Compliance Committee's activity status report and internal whistleblower status reports are given.

Internal Whistleblower Scheme

In response to code violations, unauthorized actions and harassment actions, we have set up Group-wide common internal whistleblower contact points that our company's Board Members and employees can use. 3 contact points are available, the "Compliance Committee", "Auditors" and "External Lawyer", and multiple ways to contact them are available: "telephone", "email", "post" or "letter". It is also widely known that whistleblowers are protected.　Internal whistleblower reports are regularly reported to the Board Meeting, and the initiative is monitored.

Internal whistleblower reports are regularly reported to the Board Meeting, and the initiative is monitored.

Education and compliance awareness improvement

As well as the compliance activity promotion message from the Chairman and CEO being disseminated at the Company-Wide Management Meeting, at the start of year speech and at other times, the top management message on compliance promotion is given.

Starting with new employees and mid-career new employees, new managers, those assigned overseas, Board Members, those in official positions etc. will regularly or on an ad hoc basis undergo training. The training leverages E-Learning and other methods to be effectively implemented, and the degree of understanding is ascertained and analyzed, for incorporation into measures.

The Group Governance Oversight Department carries out the following to improve compliance awareness.

• Monitoring of compliance information at each location, also sharing information between locations with the person in charge of compliance and the leader of the location
• Based on each month's compliance information, summarizes the background and perspectives, creates training documents and deploys them to all locations
• Based on contact reports with other companies in the same industry, monitoring against Competition Law