TOPPAN Group Anti-Corruption Policy
In accordance with the TOPPAN Group Conduct Guidelines (hereinafter, the “Conduct Guidelines”), TOPPAN has defined the following Anti-Corruption Policy with the aims of complying with laws and regulations prohibiting corruption in all of the countries and regions in which it conducts business, complying with the rules and guidelines, etc. of its Group companies, and acting in accordance with corporate ethics.
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1. Prohibition of corruption*
Based on the Conduct Guidelines, “Basic Principle 3: Complying with laws and company rules and conducting fair business operations,” Items “6. Prohibition of bribery and inappropriate entertainment practices,” “7. Prohibition of illegal political contributions or donations,” “10. Compliance with international rules and local laws in overseas business,” and “14. Prohibition of receipt or provision for personal gain or rebate,” etc., the TOPPAN Group complies with anti-corruption laws and regulations in Japan and abroad and acts in accordance with corporate ethics. Under no circumstances will it demand proceeds that can only be obtained through corruption or through comparable unfair means.
* “Corruption” refers to gifts, entertainment, political contributions, charitable contributions, sponsorships, rebates, kickbacks, etc. with the aim of reaping unjust profit.
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2. Relationships with business partners
The TOPPAN Group requests all business partners engaged in any way in the Group’s business, both in Japan and abroad, to fully understand the purpose of this Policy and cooperate by not seeking to benefit the Group through unjust means.
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3. Anti-corruption initiatives
(1) Management and monitoring structure
In the TOPPAN Group, the TOPPAN Holdings Inc. Legal Division has prepared internal regulations, etc. pertaining to anti-corruption as the Group division responsible for legal and regulatory compliance and corporate ethics, and conducts regular checks to confirm the compliance status and effectiveness of these and other regulations. Based on the results of these checks, necessary measures are taken, including reviewing and revising the internal regulations, etc. -
(2) Establishment of education, training, and a reporting & whistleblowing system
The TOPPAN Group conducts education and training essential to preventing corruption and implements measures such as enriching and expanding its internal whistleblowing system, including at overseas sites, striving to improve its compliance structure. -
(3) Responding to violations
In the event of a violation of anti-corruption laws, regulations, internal regulations, etc., by executives or employees (including part-time employees, etc.), the TOPPAN Group takes strict disciplinary action in accordance with its internal regulations.
Established on July 25, 2024
Hideharu Maro
Representative Director, President & CEO
TOPPAN Holdings Inc.