Legal compliance in business operations is an indispensable condition that every corporation must satisfy to fulfill its responsibilities to society. The TOPPAN Group firmly believes that every person working in the Group must fully recognize the importance of compliance, make proper judgments, and act with integrity under high ethical standards by respecting laws, regulations, in-house rules, social norms, and other standards of conduct.

Risks related to compliance increase as we globalize our business and intensify our operations beyond borders. In 2000 we established a set of Conduct Guidelines based on the Corporate Philosophy and Corporate Creed. The guidelines were, and continue to be, a collection of fundamental provisions that set out the basic concepts and behavioral norms for employees to follow in accordance with corporate ethics and 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 a comprehensive review conducted in 2020. The latest Basic Principles in the guidelines call upon Group employees “(to) achieve a sustainable society” and strive for “personnel diversity,” a “rewarding work environment,” and other sustainability requirements. The latest guidelines will guide accelerated efforts to address the material issues propounded in the TOPPAN SDGs STATEMENT, and observance of them will help shape a sustainable society.

The TOPPAN Group Conduct Guidelines have been formulated as a set of basic rules to be fully observed by employees to ensure legality of the execution of job duties. The Compliance Department set up under the Legal Division coordinates with the legal departments and other related sections of subsidiaries to secure legal compliance and establish corporate ethics throughout the Group. A Conduct Guidelines Promotion Leader (“Leader”) system supports guideline compliance at workplaces across TOPPAN Holdings Inc. and its subsidiaries. Leaders appointed under the system work to enforce guideline compliance in daily operations under the officer in charge of Conduct Guidelines Promotion.

Specifically, the officer in charge of Conduct Guidelines Promotion (officer in charge of the Legal Division) heads the Leader system and supervises the compliance promotion activities implemented across the Group. The Leaders appointed at workplaces arrange training programs at their sites and report locally arising questions and consultations to the officer in charge of Conduct Guidelines Promotion via administration offices.

Disciplinary provisions in our employment rules, meanwhile, stipulate disciplinary actions for serious violations of laws, regulations, the Conduct Guidelines, and other in-house rules. Our personnel performance evaluations and evaluations on individual wages, bonuses, and annual salary revisions also prioritize criteria focused on legal compliance, corporate ethics, environmental protection, and other responsible actions to better ensure that our obligations to society are optimally fulfilled.

We have been undertaking various anti-corruption initiatives in conformance with the anti-corruption principles set out by the United Nations Global Compact. The TOPPAN Group Conduct Guidelines affirm wide-ranging principles on corruption prevention, such as a “prohibition of bribery and inappropriate entertainment practices,” “prohibition of receipt or provision for personal gain or rebate,” “prohibition of illegal political contributions or donations,” and “prohibition of collusion and cartels.” The TOPPAN Group Anti-Corruption Policy formulated in July 2024 declares a number of anti-corruption resolutions and practices set under the Conduct Guidelines towards persons both inside and outside of the Group.

To combat bribery, an issue of particular concern, TOPPAN has established a set of anti-bribery rules and guidelines and built an anti-bribery framework led by the officer in charge of the Legal Division as the chief anti-bribery manager. For more intensive anti-bribery control, we have operated a system requiring pre-authorization for the offering of any form of entertainment or gift to a public official or the like. An FAQ describing specific cases of bribery has been issued to further heighten employee awareness and call strict attention to compliance-related issues. As a basic rule, employees are prohibited from making “small facilitation payments” (small payments to facilitate or expedite routine governmental services such as visa issuance or customs clearance) to public officials.

Illegal contributions and funding provision are also comprehensively prohibited throughout the Group. Any form of association or contact with anti-social forces, for example, is clearly prohibited in the TOPPAN Group Conduct Guidelines and the Guidelines on Dealing with Anti-social Forces. No cases of inappropriate entertainment or gifts to public officials or the like were reported in fiscal 2023.

In training sessions organized each year for candidates for overseas assignments, trainees learn reinforced strategies to combat bribery in the commercial and public sectors and become familiar with the pre-authorization system. Eighteen employees attended five sessions in Japan in fiscal 2023. Overseas affiliates have also been included in the scope of the anti-bribery rules to combat bribery around the world. A total of 22,947 employees took part in training sessions on the prevention of bribery and other types of unauthorized transaction in fiscal 2023.

Political Contributions and Other Expenditures

(million yen)

To observe major transaction-related laws and regulations, TOPPAN has been promoting compliance with the Subcontract Law of Japan and comprehensively preventing improper import and export transactions.

A total of 13,210 employees from the sales departments and conventionally targeted ordering departments were trained on compliance with the subcontract law in fiscal 2023, and another 10,186 employees took an e-learning course on export controls under the Foreign Exchange and Foreign Trade Act of Japan. Over the same period, two comprehensive audits were performed to assess compliance with the subcontract law in 80 departments and the observance of export controls in 34 departments.

The audits in fiscal 2023 confirmed conformance with these laws across the Group. No serious legal violations or cases of misconduct were identified, and no problems or incidents occurred in transactions with subcontractors or import or export transactions.