カジノシークレット出金
Policy
Toyota Tsusho endeavors to ensure that all its executives and employees, including temporary staff, contract workers, seconded employees, and others (hereinafter collectively referred to as "employees"), perform their duties in accordance with its Global Code of Conduct & Ethics (COCE) as the basic policy for カジノシークレット出金
The COCE was established in July 2016 following a resolution by the Board of Directors in April of the same year, as a concrete and easy-to-understand expression of the Behavioral Guidelines that support our Corporate PhilosophyTo ensure that the COCE is well-known and ingrained throughout the entire group, we have built a global network Together with the global members of this network, we continuously carry out various awareness activities, including the distribution of the President's COCE message, the publication of the COCE booklet in 23 different languages, and training sessions for executives and employees at different levels Moreover, every year we obtain a pledge of カジノシークレット出金 with the COCE after conducting COCE training for all executives and employees around the world Through these awareness activities and COCE pledge initiative, we aim to establish the COCE as the global common code of conduct for all executives and employees in our Group, and to foster an organizational culture based on the COCE, thereby ensuring thorough カジノシークレット出金 with the basic カジノシークレット出金 policy

Violation of Global Code of Conduct & Ethics (COCE)
We require all officers and employees to report any concerns about possible COCE violations promptly through the proper channels, and we guarantee that no retaliatory actions or measures will be taken against the reporter pursuant to internal regulations The proper channel includes supervisors and the Administrative Unit, as well as our global whistleblower system (described below), which accepts anonymous reporting in more than 150 languages
On-site inspections by the planning department of each sales division and internal audits by the Audit Department also carefully look for COCE violations
In addition, starting from the fiscal year ending March 2024, we have initiated the 'Safety and カジノシークレット出金 Comprehensive Inspection' activities for our major consolidated subsidiaries In these activities, each company disseminates top management messages and information about our global whistleblower system, and inspects the status of obtaining necessary permits and licenses for their operations and カジノシークレット出金 with quality standards related to their products and services Following these inspections, the responsible executives from Toyota Tsusho verify the implementation status on-site
We also fully utilize the latest digital tools, such as IT and AI, to analyze a massive amount of data on expenses, sale and purchase accounting and financial statements, etc, and monitor for signs of improper conduct so we can prevent and discover them early These analysis results are also utilized in the aforementioned on-site inspection activities and internal audits
If there is a concern about a possible COCE violation, the カジノシークレット出金 & Crisis Management Department, together with related departments such as the Legal Department and the Global Human Resources Department, thoroughly investigate the case and take appropriate action based on the Incident Response Manual, under the supervision of the Board of Directors To maintain our カジノシークレット出金-related initiatives at the highest level, we will continue to regularly evaluate and validate the current basic policies, the COCE, and the effectiveness of various カジノシークレット出金 measures and improve them as needed
The number of COCE violations in the Toyota カジノシークレット出金 Group in Japan and overseas in the fiscal year ended March 31, 2025, is shown here below Note that there were no violations seriously affecting our group’s operation
| Area | Number of breaches |
|---|---|
| Legal violations (Subcontract Act, permits and licenses, etc) | 23 |
| Embezzlement | 21 |
| Harassment | 3 |
| Bad conduct/Injury | 5 |
| Violations of personal data protection | 4 |
| Bribery | 0 |
| Conflict of interest transactions | 0 |
| Money laundering/Insider trading | 0 |
| Others (Employment regulation violations) | 2 |
| Total number of cases | 58 |
Anti-Corruption
1 Basic Policy
The Toyota カジノシークレット出金 Group clearly states its anti-corruption policy in the Global Code of Conduct & Ethics (COCE), and establish the following as our basic policy for preventing corruption (Anti-Corruption Policy) We are engaged in various prevention activities as described below
【Anti-Corruption Policy】
- Prohibition of corruption and prevention of money laundering
- Establishment and implementation of anti-bribery rules and guidelines, and monitoring of its カジノシークレット出金
- Development of approval procedures to prevent money laundering
- Implementation of various training programs to ensure thorough prevention of corruption and money laundering
- Establishment of a reporting system and response framework in the event of violations of this Anti-Corruption Policy
- Strict disciplinary actions for violations of this Anti-Corruption Policy
- Implementation of corrective measures and preventive actions to avoid recurrence of violations of this Anti-Corruption Policy
- 1Corruption refers to all acts of abuse of authority in search of unfair profits, and includes all forms of corruption such as bribery, cartels/bid-rigging, embezzlement, and conflicts of interest
- 2Bribery refers to the improper provision of money, gifts, entertainment, donation, contribution (including political contribution) or other benefits to civil servants or private individuals, or promises to provide them or the act of making such promises, to obtain or secure business benefits, whether directly or indirectly, including payments of small amounts to facilitate procedures for ordinary administrative services (Small Facilitation Payments)
- 3Bribery also refers to the request or receipt of money, gifts, entertainment or other benefits in return for improper judgment or conduct, whether directly or indirectly
- 4Conflict of interest refers to the act of prioritizing personal interests over the interests カジノシークレット出金 company by executives or employees
2 Supervision by the Board of Directors
Upon COCE violations, the カジノシークレット出金 & Crisis Management Department, together with related departments such as the Legal Department and the Global Human Resources Department, thoroughly investigate the case and take appropriate action based on the Incident Response Manual, under the supervision of the Board of Directors Furthermore, at the Integrated Risk Management Committee Meeting held once every quarter and chaired by the Board of Directors and the member of the board & CFO, the policy for our global カジノシークレット出金 activities including anti-corruption initiatives is reported along with the status of activities and violations in the current fiscal year
3 Specific Initiatives
The Toyota Tsusho Group has established bribery prevention rules and implementation guidelines and is endeavoring to prevent bribery (including Small Facilitation Payments) by ensuring that there are no breaches of the bribery regulations of any country, including the Foreign Corrupt Practices Act of the United States, the Bribery Act 2010 of the United Kingdom, and the Unfair Competition Prevention Act of Japan Specifically, we are obliged to pre-examine and approve transactions involving the government, pre-examine and approve invitation of public officials, and report provision of entertainment and gifts to public officials In addition, in order to prevent money laundering, payments to third countries and third parties are prohibited in principle, and the approval procedures for special approval are stipulated We also regularly monitor the status of カジノシークレット出金 with these internal rules and strive to ensure thorough カジノシークレット出金 with these rules, and also improve them
As part カジノシークレット出金 above-mentioned approval procedures, we conduct following due diligence for existing and new agencies (agencies, agents, consultants, etc), suppliers, joint ventures, and joint venture partners, equivalent to their risk assessment In addition, with new business partners and existing business partners associated with corporate acquisitions and joint ventures, we inform them カジノシークレット出金 Group's anti-corruption policy so they understand the Group's strong determination to prevent corruption As a general rule, we conclude a contract that includes a clause on anti-bribery and obliges the new and existing business partners to the prevention of corruption, including bribery, thereby preventing the occurrence of corruption
- 1Pre-contract confirmation of business partner's anti-bribery system through Anti-Bribery & Corruption Questionnaire
- 2Checking bribery controversies of business partners using the third-party risk and カジノシークレット出金 database
- 3Background survey on bribery and corruption risk カジノシークレット出金 business partner by a third-party
Regarding group companies, in the Check10 activities, each business entity annually evaluates on two axes: its corruption risks, including bribery, with reference to its business domain, business partners, and the Corruption Perceptions Index (CPI) published by Transparency International, and the management system for those risks Based on the results of the evaluation, in consultation with local attorneys regarding the laws and regulations of each country, each business entity establishes related internal rules including anti-bribery rules, and implements similar initiatives as described above, such as approvals and reporting procedures, due diligence of business partners, and utilizing e-learning of external organizations which we contract In particular, for group companies evaluated as having a high risk, the カジノシークレット出金 & Crisis Management Department of the head office conducts interviews, etc in collaboration with local legal representatives and legal personal and then provides guidance and support so that the above efforts can be properly designed, implemented, and carried out The カジノシークレット出金 & Crisis Management Department of the head office monitors and supports the implementation and execution status of these efforts through the Check10 activities, thereby working to prevent corruption
Confirmation of Contributions to Industry Associations and Other Organizations
We communicate opinions that may influence the enactment or revision of laws to the government through our participation in various committees and working groups of industry associations Payments to such industry associations and other organizations are subject to prior approval, and we confirm that the contribution payments are appropriate
| Fiscal year endedMarch 31, 2022 | Fiscal year endedMarch 31, 2023 | Fiscal year endedMarch 31, 2024 | Fiscal year endedMarch 31, 2025 | |
|---|---|---|---|---|
| Contributions to Industry Associations and Other Organizations | 189 | 200 | 200 | 211 |
| Japan Business FederationCommittee on Africa | The Committee on Africa aims to promote economic exchange and development between Japan and Africa through cooperation between Japanese business circles, African political and business circles, and relevant Japanese ministries and agencies Specifically, the Committee has dispatched missions to Africa, participated in TICAD and the Japan-Africa Public-Private Economic Forum, introduced proposals for African development to Japanese and African political and business circles, and engaged in exchanges with African political and business leaders and Japanese ministries and agencies involved in Africa We have held the position of Co-Chair since May 2017 and are actively spearheading the above-mentioned activities In December 2024, the mission participated in the 3rd Japan-Africa Public-Private Economic Forum held in Cote d'Ivoire, and later sent a mission to Morocco to deepen exchanges with the country's political world |
|---|---|
| The Japan Chamber of Commerce and Industry and The Tokyo Chamber of Commerce and IndustryThe Japan-Egypt Business Council | The Council aims to promote economic exchange and development between Japan and Egypt through cooperation between Japanese business circles, Egyptian political and business circles, and relevant Japanese ministries and agencies Specifically, the Council has dispatched missions to Egypt, held the Joint Conference カジノシークレット出金 Japan-Egypt & Egypt-Japan Business Councils, and engaged in exchanges with Egyptian political and business leaders and relevant Japanese ministries and agencies involved in Egypt We have held the position of Chair since December 2013 and are actively spearheading the above-mentioned activities In March 2019, we sent a mission to Cairo jointly with the Japan External Trade Organization (JETRO) where we met with the President and other key ministers and deepened exchanges with Egyptian business community In April 2023, a Japan-Egypt Business Forum was held in Cairo and was attended by visiting Prime Minister Kishida and Prime Minister Madbouly |
| The Japan Iron and Steel Federation | The Japan Iron and Steel Federation (JISF ) is a private organization established as a comprehensive survey and research organization for the iron and steel industry It conducts business activities with the aim of promoting the sound production, distribution, consumption, and trade of iron and steel, and contributing to the development カジノシークレット出金 Japanese economy and improvement of people's livesExamples of its business activities include various surveys and research, improvement of technological development and promotion of its widespread use, and promotion of standardization We serve as a non-executive director of JISF and participate in activities such as market research on iron and steel, carbon neutrality, international cooperation, and product safety |
4 Training
The Laws & Ordinances Handbook for Executives and a カジノシークレット出金 manual for employees also clearly describe the prohibition of corrupt acts and are distributed in handbooks and other forms to all executives and employees, respectively Also, to ensure full understanding and thorough dissemination of the requirements, we offer an e-learning course that is mandatory for all executives and employees
Additionally, for managerial staff, we have created a handbook outlining fundamental practices to be implemented by managers in the first line of defense* for the prevention of corruption, and we ensure thorough understanding and adherence through training sessions and other means
- *The first line of defense in the 'Three Lines of Defense' model presented by COSO (Committee of Sponsoring Organizations カジノシークレット出金 Treadway Commission) in its 'Internal Control - Integrated Framework
5 Individual Response to COCE Violations
To handle emergencies when a COCE violation occurs, the Toyota Tsusho Group has established emergency response guidelines (in a form of notification) and the カジノシークレット出金 & Crisis Management Department takes appropriate action at the appropriate time together with the related departments
Employees who notice the occurrence or potential occurrence of an issue that violates the COCE must immediately report it to their superior Furthermore, the reported information must be promptly communicated to the カジノシークレット出金 and Crisis Management Department General Manager, who is responsible for カジノシークレット出金, through each company’s president and the responsible department general manager Upon receiving the report, the カジノシークレット出金 & Crisis Management Department General Manager immediately reports to the top management, Deputy CFO (in charge of カジノシークレット出金 & Crisis Management Department) and Audit & Supervisory Board Members, as well as related departments such as the Legal Department, the Human Resources Department, and the Public Relations Department, and conducts the initial response, necessary investigations, etc, as is appropriate The status of actions taken and the results will be reported to the Deputy CFO (in charge of カジノシークレット出金 & Crisis Management Department) and Audit & Supervisory Board Members If an employee commits a fraudulent activity, they will be dealt with strictly through procedures according to the award and punishment rules, such as the establishment of a disciplinary committee In addition, in order to prevent similar COCE violations from occurring within our group, the outline of the case, the root cause of occurrence, the recurrence prevention measures, etc are shared quarterly within our group and are used for カジノシークレット出金 education at our company and each group company
As shown in the diagram below, direct reporting to top management is mandatory for major incidents

6 Cases of Uncovered Corruption
In the fiscal year ended March 31, 2025, there were no corrupt acts uncovered inside Toyota カジノシークレット出金, and thus there were no payments of fines or penalties
Whistleblowing System
The Toyota Tsusho Group mandates that any concerns regarding COCE violations be immediately reported to a superior or the relevant department of the Administrative Unit However, a whistleblowing system has been established for all executives and employees of our Group to report cases where there are impediments to reporting to a superior or the relevant department for any reasonThe whistleblowing system was expanded and extended from its previous form, in which reporting was only possible through internal reporting lines and external lawyers, by adding a dedicated external reporting line This reporting line, created in November 2017, offers multilingual support (currently, in more than 150 languages), and makes it easier for executives and employees to report or consult on matters related to COCE violations, including all forms of corrupt acts and human rights violations, by providing a global service with greater anonymity and confidentiality Furthermore, all internal reports and their handling status are reported to Audit & Supervisory Board members, and a direct notification system for the internal reporting hotline to Audit & Supervisory Board members has been established to ensure independence from management executivesWe will continue to promote the development and operation of a more reliable and effective whistleblowing system, and strive to further strengthen カジノシークレット出金 management and enhance corporate value
Whistleblowing System
Origin カジノシークレット出金 Name "will do"
will: It expresses the will and determination to improve Toyota TsushoThe reason we use lower-case letters is to make this matter more familiar to you by leaving the space for "I", "We", and "You" in the namedo: It expresses the realization カジノシークレット出金 will and determination to improve the company
Origin of the Name "SPEAK カジノシークレット出金"
The name "SPEAK カジノシークレット出金" represents our desire to create a lively and exciting work environment by providing an environment in which it is easy to report concerns and by ensuring that employees feel safe and comfortable in speaking カジノシークレット出金
Feedback Process
In the fiscal year ended March 31, 2025, we received 286 reports through SPEAK カジノシークレット出金 and will do 286 reports were subjected to hearings and internal investigations, etc As a result, we confirmed 33 cases as breach of COCEThe breakdown of the 33 cases is as follows
56%: Discrimination and harassement (including sexual, moral, gender)12%: Working hours, pay1%: Health and Safety issues1%: Legal カジノシークレット出金 issues30%: Ethical issues (confidential information management, conflict of interest, insider trading, etc)
For these issues, corrective actions and measures to prevent recurrence (eg, improvement of systems, modification of rules, and thorough dissemination of information) were implementedIn three of these cases, disciplinary actions were taken in accordance with company rules
Contact Point
We have set カジノシークレット出金 a contact point on our website so that the general public and stakeholders of Toyota Tsusho can make inquiries, and the appropriate department responds according to the content of the inquiry
Activities to Raise カジノシークレット出金 Awareness
To ensure that specific laws and regulations that must be adhered to in daily operations are thoroughly understood by executives and employees, we conduct various training sessions and seminars, obtain pledges of COCE カジノシークレット出金 from all executives and employees, and organize mandatory e-learning courses for all employees Additionally, during the Business Ethics Month of October, we hold カジノシークレット出金 events Through these activities, we review the status of カジノシークレット出金 with laws and regulations, striving to ensure thorough adherence to legal and corporate ethics standards
In the fiscal year ended March 31, 2025, we held training for various levels of the organization, including new employees, newly appointed managers, line managers, and executives, as well as for specific groups such as newly appointed executives at domestic Toyota Tsusho Group companies and employees about to be stationed overseas The company also conducts training, e-learning, and information sessions for executives and employees on topics such as insider trading, bribery prevention, cartels, supply chain CSR, and the COCE to ensure that all personnel are fully aware of the prohibition of corruption in all forms In addition, the company reviews, revises, and issues the Laws & Ordinances Handbook for Executives for executives and a カジノシークレット出金 manual for employees every two years so that the entire company workforce is familiar with important laws to ensure strict カジノシークレット出金 with laws, regulations, and corporate ethics
Performance Evaluation
At our company, at the beginning カジノシークレット出金 term, all employees set competency goals, including ethics and beliefs (always maintaining a high sense of ethics and adhering to right actions) They strive to act in accordance with these goals After undergoing a mid-term review with their supervisors, at the end カジノシークレット出金 term, the supervisors evaluate and score their achievements, which are then reflected in the final personnel evaluation Additionally, the final personal evaluation is reflected in the employees' bonus amounts for the respective fiscal year
Third-Party Audit
The content and implementation status of the aforementioned COCE カジノシークレット出金 activities and various カジノシークレット出金 measures based on COCE are subject to audits every year by external independent auditors, including supporting and related documents, as part of the internal control audit under the Financial Instruments and Exchange Act
Tax Governance
Tax Governance Policy
The basic policy of Toyota Tsusho and the Toyota Tsusho Group is to comply with the tax laws and regulations of individual countries, under the responsibility カジノシークレット出金 CFO and following the COCE, and to appropriately satisfy global tax obligations
We attach great importance to conducting all our business activities properly and rationally We will expand our business and build a global structure in line with our business objectives, and we will not intentionally avoid taxes using tax havens We strive to comply with the laws, regulations, and tax conventions of individual countries, as well as with international taxation rules, appropriately reporting income and paying taxes We build fair relationships with tax authorities in the regions in which we do business by appropriately disclosing information and engaging in constructive dialogue
Under our basic policy, we strive to eliminate double taxation and appropriately utilize tax incentives to achieve appropriate tax costs
Tax Governance Structure
The Representative Director CFO, issues and directs basic policies regarding tax costs and supervises the proper allocation of tax expenses and the fulfillment of tax obligations under the following structure- Officer in charge: Hideyuki Iwamoto (Representative Director CFO)- Department: Accounting Department
The General Manager カジノシークレット出金 Accounting Department and the Accounting Department work together with the Business Accounting Department and the relevant accounting departments of domestic and overseas subsidiaries to manage tax obligations on a global basis In addition to reporting tax-related risks and events from domestic and overseas subsidiaries to the Accounting Department, tax risks are reviewed when examining individual projects Furthermore, when the General Manager カジノシークレット出金 Accounting Department recognizes significant tax-related events and risks, appropriate reports are made to the Representative Director CFO
The CFO reports on important tax-related matters at meetings カジノシークレット出金 Board of Directors or Executive Officers, as necessary, in an effort to improve the tax governance system
