Compliance

Fundamental Philosophy

Tomoku and its Group companies are aware of their social responsibility and have established the Tomoku Group Code of Conduct to ensure sound and sustainable corporate activities.

All officers and employees of Tomoku and its Group companies are expected to not only comply with laws and corporate rules, but also act with a strong sense of ethics and responsibility in accordance with the Tomoku Group Code of Conduct.

Compliance Framework

At Tomoku, the President serves as the Chief Compliance Officer, leading the company’s compliance efforts. General Manager of the Legal & Compliance Office serves as the compliance supervisor who oversees the compliance efforts that we plan and advance. We also have a compliance manager in each department, office, and plant, who works collaboratively with the compliance supervisor as they engage in their activities.

Compliance Committee

The Compliance Committee serves as the body that oversees compliance across Tomoku and its Group companies. Chaired by the President, the Committee engages in its activities, with the Legal & Compliance Office as the secretariat.

The Committee pursues the establishment of a compliance-oriented corporate culture and ethics. It provides training to raise compliance awareness and manages each compliance-related case.

Our Compliance Efforts

Whistle-Blowing System

We have set up internal and external hotlines for whistleblowers in accordance with the Tomoku Whistleblowing Policy. The external hotline is at an independent third-party organization (law firm). With these hotlines in place, we seek to stay informed and resolve issues related to compliance. These hotlines are intended mostly for employees of Tomoku Co., Ltd. and treat the reports they receive as strictly confidential. The privacy of whistleblowers and any stakeholders is protected. We guarantee that employees will not receive unfair treatment on the grounds of contacting either of the hotlines or cooperating in fact-finding. If any retaliation is found, we will take strict and resolute disciplinary action against the perpetrator, regardless of what has been done and how. We also use compliance and sustainability training as a means of advancing employees’ understanding of our whistle-blowing system.

Grievance and Consultation Hotline

The Tomoku Group’s business activities are built on operations performed in compliance with laws and regulations. We also believe that it is vital to have a system for listening to all stakeholders to stay informed about potential or actual human rights risks and to effectively manage them.

If we discover any violation or potential violation of laws or rules, the Tomoku Group Code of Conduct (specifying zero tolerance for human rights violations and discrimination, the prevention of harassment, corporate activities with integrity and fairness, and the pursuit of safe, secure, and high-quality products and services, etc.), or ethics, by any Tomoku Group company or its officer or employee, we accept opinions from the Group’s employees (including part-timers and technical intern trainees*). We are also open to comments from external parties ranging from temporary employees and contract workers (including those who are foreign nationals), employees of our business partners, and the public. We have a dedicated contact channel shown as “Compliance Hotline” at the bottom of the Contact Us page on our website.

We have been using Ninja run by the third-party organization Caux Round Table Japan as the grievance hotline for technical intern trainees who work at Tomoku Co., Ltd. since 2022. We accept not only reports on human rights violations, but also a wide range of comments, including complaints and concerns.

About Compliance Hotline (in Japanese only)

Compliance Training

Tomoku provides a variety of compliance training tailored to each job level or department, among other measures, to raise employees’ compliance awareness. The Legal & Compliance Office leads training sessions on compliance fundamentals, the Tomoku Group Code of Conduct, and other compliance-related subjects, as well as regular training on related laws and regulations, thereby ensuring full compliance by all employees.

Our Group companies also provide compliance training as needed.