G :Governance
Compliance
Compliance
Basic Stance Towards Compliance
Compliance System
Whistle-Blowing System
Review of FY 2023 Activities
Basic Stance Towards Compliance
In order to respond effectively to the increase in risk that has accompanied globalization, in July 2017 the Yokohama Rubber Group Competition Law Compliance Policy and Yokohama Rubber Group Anti-corruption Policy were approved by the Board of Directors and came into effect. By announcing these new policies both in Japan and overseas, and by formulating rules and guidelines that embody the policies in concrete form and familiarizing stakeholders with them, we aim to prevent violations of competition law and criminal offences involving bribery.
By integrating these policies with our Global Whistleblower System, adoption of which began in February 2018, and implementing them in our subsidiaries throughout the world, we believe we can raise the overall level of compliance in the Yokohama Rubber Group to an even higher level.
By integrating these policies with our Global Whistleblower System, adoption of which began in February 2018, and implementing them in our subsidiaries throughout the world, we believe we can raise the overall level of compliance in the Yokohama Rubber Group to an even higher level.
Compliance System
Yokohama Rubber has established a Compliance Committee chaired by the Director in charge of Compliance, as well as a Compliance Promotion Office as its implementation department. The Committee meets four times a year and continues to implement various measures related to compliance within our group. The Committee also reports its activities to the Board of Directors and Audit & Supervisory Committee. The corporate Philosophy and Action Guidelines of the Yokohama Rubber Group are made known and presented to Group companies, including overseas companies, to serve as the guidelines for the execution of duties by Directors and employees at each company. Every division in the Yokohama Rubber Group is assigned personnel who belong to the Corporate Compliance Department as well, to continue to share the progress of the activities in internal education and related information in the workplace. In our domestic and overseas group companies, we have appointed a compliance promotion manager to facilitate the development of the same level of activities in each company.
Whistle-Blowing System
The Corporate Compliance Hotline refers to the system of accepting even anonymous whistle-blowing in accordance with the Whistleblower Protection Act. The telephone number and email address are stated on the Corporate Compliance Card that is distributed to all domestic Yokohama Rubber Group’s employees. There are two hotlines, an internal hotline and an external hotline. As the external hotline has been established at an external law firm, independence has been secured for this hotline. Additionally, we have established an "Anything You Can Ask" consultation service, where any employee can anonymously ask questions about compliance. In fiscal year 2023, there were a total of 242 reports and consultations through both the hotline and "Anything You Can Ask."
Yokohama Rubber has introduced a "Global Whistleblower System" at its overseas subsidiaries that allows the Yokohama Rubber Compliance Department to directly identify any violations of competition laws, bribery-related activities, and violations by local subsidiary executives through an external contact point. In February 2018, adoption of the new System began in China at the company responsible for overall supervision of our China-based operations and at our tire sales company in China.
By 2022, the introduction of the system in China, the Philippines, Thailand, Vietnam, and North America has been completed with the exception of some offices.
Beginning in 2023, we will begin studying the introduction of the system at our production facilities in Indonesia.
We have begun implementing this initiative at our production facility in Indonesia, starting in November 2023.
In Europe, our European headquarters signed a contract with a company that provides a whistleblowing system, and it implemented a joint whistleblowing system that it uses along with its eight subsidiaries. In addition to serving as a whistleblowing system for these nine companies, including the controlling company, the system also functions as a global whistleblowing system in which the Corporate Compliance Dept. directly receives reports from local employees depending on the content of the report.
This system has been in operation since January 2021.
Yokohama Rubber has introduced a "Global Whistleblower System" at its overseas subsidiaries that allows the Yokohama Rubber Compliance Department to directly identify any violations of competition laws, bribery-related activities, and violations by local subsidiary executives through an external contact point. In February 2018, adoption of the new System began in China at the company responsible for overall supervision of our China-based operations and at our tire sales company in China.
By 2022, the introduction of the system in China, the Philippines, Thailand, Vietnam, and North America has been completed with the exception of some offices.
Beginning in 2023, we will begin studying the introduction of the system at our production facilities in Indonesia.
We have begun implementing this initiative at our production facility in Indonesia, starting in November 2023.
In Europe, our European headquarters signed a contract with a company that provides a whistleblowing system, and it implemented a joint whistleblowing system that it uses along with its eight subsidiaries. In addition to serving as a whistleblowing system for these nine companies, including the controlling company, the system also functions as a global whistleblowing system in which the Corporate Compliance Dept. directly receives reports from local employees depending on the content of the report.
This system has been in operation since January 2021.
Whistle-Blowing System (Flow chart)
In operating both our global and domestic internal reporting systems, we have established Yokohama Rubber Group Internal Reporting Rules and Global Internal Reporting Rules that include whistleblower protection provisions. These rules explicitly state that whistleblowers will not suffer any disadvantages for reporting violations.
Thorough enforcement of compliance through monthly reports
84 Compliance Promotion Managers have been assigned to Group companies in Japan and overseas. We respond appropriately in coordination with the Corporate Compliance Department to issues that occur in various situations including the workplace and external transactions.
Each compliance officer sends a monthly report to the Corporate Compliance Department as part of efforts to enable an advance understanding of issues.
Each compliance officer sends a monthly report to the Corporate Compliance Department as part of efforts to enable an advance understanding of issues.
Manager of the regional headquarters in China
Manager of Japanese tire distributors
Manager of Japanese industrial product distributors
Being able to appropriately monitor the state of compliance at overseas subsidiaries is an important issue. By making effective use of the periodic reporting system that is already being implemented, and of the global whistle-blowing system that we have begun to adopt, we are approaching the stage where we will be able to effectively monitor compliance issues at each overseas business location.
Compliance Audit
We conduct an annual operational audit by our Audit Office. This audit covers 11 areas, ranging from accounting to safety, environment, industrial waste management, and our code of conduct and compliance. We use audit procedures based on our rules and guidelines to ensure that operations are conducted in accordance with these standards. We then issue recommendations and suggestions for improvement, aiming to prevent irregularities and errors. In fiscal year 2023, we conducted audits at 20 locations and issued 495 recommendations and suggestions.
Review of FY 2023 Activities
Education and Awareness Raising Activities
Using internal compliance issues as themes, we offer both general compliance materials that we would like all employees to know about, as well as contents for specific departments and positions, with teaching methods that include the distribution of educational materials, group learning at work, and group education.
In 2023, we continued our education programs on harassment and quality misconduct, and also expanded them to include topics such as personal information protection, paid leave, and workplace accidents.
In 2023, we continued our education programs on harassment and quality misconduct, and also expanded them to include topics such as personal information protection, paid leave, and workplace accidents.
Workplace Learning in 2023 | |
---|---|
January | Personal Information Protection |
February | There are cases where we may not be able to respond to reports. |
March | Difficulty Taking Paid Leave |
April | Adhering to Operational Guidelines |
May | Instances Where Harassment Was Not Addressed |
June | Taking Confidential Business Information |
July | Driving Under the Influence of Alcohol |
August | Regarding Workplace Accidents |
September | Regarding Stamps and Signatures |
October | Appearance |
November | Preventing Quality-Related Misconduct |
December | Establishment of a Reporting Hotline and Request for Cooperation |
Anti-Corruption Initiatives
The Yokohama Rubber Group Code of Conduct declares the following;
We will not only comply with laws and regulations but also with social norms.
We will not engage in any act that violates competition laws, bribery, or any act that deviates from the law or business practices.
We will maintain sound relationships with political and administrative entities, both inside and outside the country, and will not engage in bribery.
We do not entertain, give gifts or give money to our business partners for the purpose of gaining unfair advantage.
It refers to actions against business partners as well as public officials.
The Anti-Bribery Policy also prohibits the act of bribery for the following "officers and employees of a private company subject to commercial bribery, and any other person who may be a guest of any bribery offense".
Furthermore, regarding the approval procedures for delicate transactions (gifts, entertainment, etc.), we are processing these in accordance with the "Points to Note When Disbursing Funds, etc." and "Points to Note When Receiving Funds, etc." sections of this policy. We are working to ensure compliance through awareness and education of Yokohama Rubber Group members, and through the CSR Procurement Guidelines for third-party suppliers.
The global whistleblower system is designed to provide an external point of contact to prevent "bribery" as well as "competition law violations" from occurring as quickly as possible.
To ensure the effectiveness of the system, we are making every effort to educate all employees at planned subsidiaries overseas prior to implementation.
Furthermore, regarding the approval procedures for delicate transactions (gifts, entertainment, etc.), we are processing these in accordance with the "Points to Note When Disbursing Funds, etc." and "Points to Note When Receiving Funds, etc." sections of this policy. We are working to ensure compliance through awareness and education of Yokohama Rubber Group members, and through the CSR Procurement Guidelines for third-party suppliers.
The global whistleblower system is designed to provide an external point of contact to prevent "bribery" as well as "competition law violations" from occurring as quickly as possible.
To ensure the effectiveness of the system, we are making every effort to educate all employees at planned subsidiaries overseas prior to implementation.
Educational achievements (FY 2023)
(Unit: persons)
Training opportunities | Persons |
---|---|
Antitrust Law Training (Cartel Prevention) | 2,718 |
Antitrust Law Training (Abuse of a Dominant Position) | 3,399 |
Pre-Departure Training for Overseas Assignments | 23 |
Pre-Departure Training for Overseas Branch Managers | 5 |
Newly Appointed Manager Training | 21 |
Grand total | 6,166 |
Privacy policy for employees
We strictly manage employees’ personal information by obtaining prior consent by quoting the purpose of its usage. We understand the importance of employees’ personal information and ensure its proper treatment; we also let our employees know, through our internal intranet, that we continue to take measures to protect their personal information.
Measures against violations
- No sanctions against violations of the Anti-Monopoly Act have been imposed on our company.
- No sanctions against fraudulent accounting practice, discrimination or misconduct in the workplace have been imposed on our company.
- No sanctions against violations of environmental regulations have been imposed on our company.
- No complaints have been lodged over loss of customers’ data.