Basic Concept
In order to continuously enhance corporate value, Tosoh strives to build an efficient organizational structure that can respond quickly to changes in the business environment and to conduct sound corporate management that is fair and highly transparent. While respecting the purpose and spirit of the Corporate Governance Code, we continuously seek the optimal form of corporate governance for Tosoh.
Corporate Structure (as of June 30, 2022)
Changes in Corporate Governance
Overview of Committees (as of June 30, 2022)
Committee
|
Composition
|
Frequency of meetings (actual results for FY2021)
|
Board of Directors
|
9 (4 of whom are external directors) Chaired by the President
|
Once or twice/month (16 times)
|
Audit and Supervisory Board
|
4 (3 of whom are external directors)
|
Once or twice/month (15 times)
|
Nomination and Compensation Advisory Committee
|
6 (4 of whom are external directors) Committee chaired by an external director
|
12 times
|
Management Committee
|
Executive officers at the managing director level and above Chaired by the President
|
Once/week in principle (30 times)
|
Board of Directors
As of June 30, 2022, Tosoh’s Board of Directors consists of nine directors, including four external directors, one of whom is female. In principle, the Board meets at least once a month. Based on laws and regulations, the Articles of Incorporation, and the Board of Directors Regulations, the Board of Directors makes decisions on business planning, strategy, and other important management matters. It also oversees the performance of duties by each director and executive officer. In addition, the board makes decisions concerning appointments, dismissals, and division of duties for executive officers.
Directors and Auditors (after June 24, 2022)
Name |
Position |
Mamoru Kuwada |
Representative Director and President |
Katsushi Tashiro |
Representative Director and Senior Executive Vice President |
Toru Adachi |
Director and Executive Vice President |
Satoru Yonezawa |
Director and Executive Vice President |
Toru Doi |
Director and Senior Vice President |
Tsutomu Abe |
External Director |
Keiichi Miura |
External Director |
Yoshihiro Hombo |
External Director |
Mariko Hidaka |
External Director |
Kouji Kawamoto |
Internal Auditor |
Makoto Okayama |
Internal Auditor |
Tetsuya Teramoto |
External Auditor |
Tsuneyasu Ozaki |
External Auditor |
Attendance at Board of Directors meetings (FY2022)
Name |
Position |
Attendance at board of directors meetings |
Mamoru Kuwada |
Representative Director and President |
100% (all 16 meetings) |
Katsushi Tashiro |
Representative Director and Senior Executive Vice President |
100% (all 16 meetings) |
Toru Adachi |
Director and Executive Vice President |
100% (all 16 meetings) |
Toru Doi* |
Director and Senior Vice President |
100% (all 13 meetings) |
Toshinori Yamamoto |
Director and Adviser |
100% (all 16 meetings) |
Tsutomu Abe |
External Director |
100% (all 16 meetings) |
Keiichi Miura |
External Director |
88% (14 of 16 meetings) |
Yoshihiro Hombo |
External Director |
94% (15 of 16 meetings) |
Mariko Hidaka |
External Director |
100% (all 16 meetings) |
*Appointed on June 25, 2021.
Analysis and Evaluation of the Effectiveness of the Board of Directors
To improve the effectiveness of the Board of Directors as a whole, Tosoh conducts an analysis and evaluation every year and discloses a summary of the results.
A summary of the analysis and evaluation results for fiscal 2022 is as follows.
1. Evaluation method
The evaluation is conducted by requesting all directors and auditors to complete a questionnaire and provide opinions. The questionnaire consists of eight categories, including a new category concerning the discussion and exchange of opinions at Board of Directors meetings. Other items include composition and operation of the Board of Directors, materials and information provided, monitoring and supervision, status of response to issues, others, and overall evaluation. The questionnaire comprises 20 questions, along with a five-point self-assessment system.
In addition, respondents can write their thoughts and opinions regarding the questions in the free opinion section. These, as well as suggestions for improvement, are reflected in future efforts to improve effectiveness.
2. Summary of analysis and evaluation results
The overall result of the analysis and evaluation is that the Board of Directors as a whole is currently fulfilling its roles and responsibilities in an effective manner. The primary reasons the Board of Directors is evaluated as generally fulfilling its roles and responsibilities effectively are as follows:
(1) The composition of the Board of Directors has been strengthened, including expertise by increasing the number of external directors and diversity by appointing female directors
(2) Risk management, based on necessary and sufficient reporting and continued monitoring and supervision of business execution, has been appropriate
(3) Management of the Board of Directors, including the frequency of meetings, scope of agenda, deliberation time, volume of materials, timing of distribution, and related matters, has been optimal
In addition, the main question newly added to the questionnaire was whether discussions and exchanges of opinions on sustainability and the company’s business portfolio are effectively being conducted.
While the responses indicate that a certain amount of discussion is taking place concerning sustainability, there are also comments that call for further efforts for increase the depth of discussion on the business portfolio, which will be reflected in future meetings of the Board of Directors. Moreover, in light of changes in the environment surrounding companies and social demands on the Board of Directors, Tosoh asks respondents to write comments on themes that should be discussed at future Board of Directors meetings in the free opinion column, and these topics will be addressed in light of the most pressing issues.
Furthermore, in terms of operations, while it has been confirmed that the Board’s efforts to date have achieved a certain level of success, it has also been acknowledged that there is some room for improvement in the way information is provided to external directors, which will be reflected in future efforts.
Tosoh will continue to work tirelessly to implement initiatives based on the results of our analysis and evaluation so as to contribute to sustainable growth and the enhancement of corporate value.
Board of Auditors
The Board of Auditors consists of four auditors (as of June 30, 2022), including three external auditors who are familiar with corporate management or have considerable knowledge of legal, financial, and accounting matters. Each auditor attends meetings of the Board of Directors and other important meetings in accordance with the audit policy and allocation of duties determined by the Board of Auditors receives reports from directors and employees regarding the performance of their duties, requests explanations as necessary, inspects important approval documents, and examines the status of operations and assets at headquarters and principal industrial complexes.
With regard to subsidiaries, the company communicates and exchanges information with directors and auditors of subsidiaries and receives reports on their operations as necessary. In addition, the Board of Auditors has established a secretariat in order to strengthen the function of the auditors in the execution of their duties.
Attendance at Board of Auditors meetings (FY2022)
Name |
Position |
Attendance at Board of Auditors meetings |
Kouji Kawamoto |
Internal Auditor |
100% (all 15 meetings) |
Makoto Okayama* |
Internal Auditor |
100% (all 11 meetings) |
Tetsuya Teramoto |
External Auditor |
100% (all 15 meetings) |
Tsuneyasu Ozaki |
External Auditor |
93% (14 of 15 meetings) |
*Appointed on June 25, 2021
External Directors and Auditors
Tosoh appoints independent external officers with exceptional experience and insight to oversee corporate governance. These external officers monitor the execution of company business from a neutral and objective point of view. Tosoh has established its proprietary Criteria for the Independence of External Directors and Corporate Auditors, and refers to these criteria when determining whether independence is ensured. External officers attend meetings of the Board of Directors and other bodies and receive regular explanations and reports to carry out supervision and auditing.
Executive Officer System
Tosoh introduced the Executive Officer System with the aim of separating management decision-making from supervisory and executive functions, thereby accelerating and streamlining decision-making. Clarification of the roles and responsibilities of business execution has made possible a management structure that can respond to rapid changes in the business environment. As of June 30, 2022, there were 27 executive officers, five of whom were also serving as directors.
Nomination and Compensation Advisory Committee
To strengthen corporate governance, Tosoh established the Nomination and Compensation Advisory Committee in June 2019 as an advisory body to the Board of Directors. The committee serves to ensure fair and transparent procedures regarding the nomination and compensation of directors, auditors, and executive officers. As of June 30, 2022, the committee consists of six directors, including four external directors, and is chaired by an external director.
Items to be discussed are as follows.
1. Matters to be proposed at the General Meeting of Shareholders concerning nominations of candidates for directors and corporate auditors
2. Matters concerning the selection and dismissal of representative directors
3. Matters related to the selection and dismissal of executive directors
4. Matters concerning the selection and dismissal of managing directors
5. Matters concerning the appointment and dismissal of executive officers
6. Matters concerning the selection and dismissal of executive officers
7. Matters related to succession planning (including training) of the president and representative director
8. Matters related to remuneration for directors and executive officers
9. Other matters related to nomination and compensation
Activities of the Board of Directors and the Nomination and Compensation Advisory Committee
Activities in the process of determining the amount of compensation for directors and officers in fiscal 2022 included five meetings of the Board of Directors and six meetings of the Nominating and Compensation Advisory Committee. Revision of the amount of compensation, etc. for directors and allocation of restricted stock compensation are decided by the Board of Directors based on the report of the Nomination and Compensation Advisory Committee.
Total Executive Compensation in FY2022
Officer Classification
|
Total amount of remuneration and other compensation (millions of yen) |
Total amount of remuneration and other compensation by type (millions of yen) |
Number of eligible officers |
Basic compensation
|
Performance-based compensation
|
Non-monetary compensation
|
Directors (external directors in parentheses)
|
347 (48) |
232 (48) |
92 (-)
|
22 (-)
|
10 (4)
|
Auditors (external auditors in parentheses)
|
69 (39) |
69 (39) |
-
|
-
|
5 (3)
|
*The above figures include one director and one auditor who retired at the conclusion of the General Meeting of Shareholders held on June 25, 2021.
Management Committee
The Management Committee consists of seven directors and group heads (as of June 30, 2022) who also serve as executive officers, and meets once a week in principle. The Board of Directors deliberates in advance on matters to be discussed at its meetings and on important matters related to the overall management of the Group, and has established a system to facilitate appropriate and efficient management decision-making.
Company-Wide Committees
Tosoh has established various committees to ensure the effective functioning of corporate governance. In addition, they also make regular submissions and reports to the Board of Directors.
Committee
|
Details of deliberation
|
Frequency of meetings (actual results for FY2022) |
CSR Committee
|
Chaired by the president, the CSR Committee consists of members of the Management Committee, the head of the administrative division at headquarters, and chairpersons of company-wide committees, and is responsible for formulating CSR activity policies and managing progress on key CSR issues. |
2 times
|
Internal Control Committee
|
Chaired by an executive vice president of Tosoh Corporation, the Internal Control Committee works to respond to the internal control reporting system for financial reporting under the Financial Instruments and Exchange Act and the internal control system required by the Companies Act. In addition, the committee regularly evaluates and amends the status of the development and operation of internal controls. |
4 times
|
Compliance Committee
|
Chaired by an executive vice president of Tosoh Corporation, the Compliance Committee is responsible for establishing the compliance system, formulating various measures such as education, and operating the internal reporting system. The committee also periodically evaluates and amends the status of the compliance promotion plan and the operation of the internal reporting system.
|
2 times
|
RC Committee
|
Chaired by a senior vice president of Tosoh Corporation, the RC Committee works to establish a system for promoting RC and formulate RC annual policies. The committee also conducts RC audits on a regular basis to understand the activities of each division. |
1 time
|
Export Supervision Committee
|
Chaired by a senior managing director of Tosoh Corporation, the Export Supervision Committee is responsible for formulating various measures for compliance with the Foreign Exchange and Foreign Trade Act, the basic policy stipulated in security export control regulations. The head of the export department is assigned to also serve as the head of the operational business unit. |
1 time
|
Fair Trade Compliance Committee
|
Chaired by a senior managing director of Tosoh Corporation, the Fair Trade Compliance Committee is responsible for establishing internal regulations and manuals regarding compliance with the Antimonopoly Act and the Act Against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors, and formulating measures for implementation. The committee also reports and deliberates on specific cases related to compliance with the law and measures to deal with them. |
1 time
|
CO2 Reduction and Effective Use Promotion Committee
|
Chaired by the president of Tosoh Corporation, the CO2 Reduction and Effective Use Promotion Committee is responsible for planning and formulating policies on important issues related to CO2 reduction and effective use from the perspectives of both technology and cost. In addition, the committee regularly reports and deliberates on specific issues related to planning and measures to deal with them.
|
2 times
|
Message from External Directors
Tsutomu Abe
Providing Timely, Appropriate Management Advice as an External Director
I believe that both the management team and employees are extremely earnest and approach their work seriously. We have an appropriate number of board members and a good balance between internal and external directors, and the external directors come from broad-ranging backgrounds. I feel that their experience and knowledge are extremely helpful in the discussions at the board meetings. As an external director, I will continue to strive to deliver management advice that is timely and appropriate.
Anticipating Robust Discussion on Future Investment Plans
We believe that proper advice from a diverse group of external directors will be effective when management finds itself faced with challenging decisions in crucial situations, such as the direction and timing of future growth investments in the company. Since there were few acquisitions and other cases to deliberate in fiscal 2022, I look forward to lively discussions on a host of issues in fiscal 2023.
Cultivating Human Resources to Support the Tosoh of Tomorrow
Tosoh’s efforts in recent years have positioned it well in terms of assembling the people, goods, and capital necessary for the company’s sustainable growth. The key to maintaining and developing this posture is the training of the next generation of personnel. In addition to workplace training for employees, we also need people who can adopt a macro view. It may be necessary to cultivate executives through cross-divisional personnel exchanges.
Tsutomu Abe
External Director
Yoshihiro Hombo
Achieving Safe, Stable Operations
In discussing various projects, we were particularly impressed by the higher-than-expected budgeted costs for facility maintenance from the complexes. This indicates to us that the concept of safe, stable operation, which positions safety as the highest priority in all aspects of operations, is firmly in place at our workplaces and complexes. I feel once again that the fact that Tosoh achieved record profits amidst an unstable social climate indicates that its commitment to prioritizing safety contributed greatly to its business performance.
Focusing on the Core of the Discussion
I believe that the most important aspect of sustainable growth is to respond to the world's needs with a market-oriented approach. I am also making this statement based on my past involvement in petrochemical-related business at a general trading company. Moreover, we are always conscious of the essence of each topic addressed in our board discussions. For example, when an agenda includes a proposed measure from one of the divisions, we believe it is necessary to confirm the analysis of the reasoning behind the proposed measure.
Importance of Emphasis on Further Consolidation
With regard to governance issues, although Tosoh is a diversified chemical company doing business on a global scale, I feel that there is a strong tendency to emphasize non-consolidated management as a metric. It will have to be accomplished in phases, but we do recognize the need for a focus on consolidation.
Yoshihiro Hombo
External Director
Keiichi Miura
Commodity Business Requires Balance Between Quality and Price and the Environment
Now that we have a stronger foundation for management, we believe that the environment is perfect for accelerating one of our strengths, the dual management strategy, one of our strengths. Until now, investment in the Commodity business has centered on measures to cope with aging facilities. Going forward, however, we must invest in environmental measures such as the reduction of CO₂ emissions. From a long-term perspective, we will systematically make investment decisions to establish a production system that can balance quality and price with environmental considerations.
Accelerate R&D, Invest Strategically in Specialty Business
Faster R&D and aggressive investment will be key in expanding the Specialty business. We are engaged in a number of fascinating R&D themes. Drawing on my own experience, I intend to make recommendations from the perspective of timing of going to market, intellectual property rights, and investment risk.
Reviewing Materialities in Light of Changes in Society
In fiscal 2022, we reviewed the company’s materialities (key issues and KPIs). All issues nominated were of high importance, but the Board of Directors identified nine particular issues based on the opinions of various stakeholders as well as the medium-term business plan that is currently in effect. We will continue to closely monitor efforts to achieve the KPIs established.
Keiichi Miura
External Director
Mariko Hidaka
Agenda Items Require Proper Preparation in Advance
As required, the annual schedule and agenda items are prepared and reviewed in advance, and are deliberated and reported on thoroughly. Materials are shared in advance on the day of the meeting and separate briefings are provided by the division senior general managers. Fiscal 2022 marked the start of my second year in office, and I am confident that I made further progress in understanding the issues and agenda items. Meanwhile, as my understanding of the issues progresses, the difficulties become clearer, and I become even more aware of the importance of examining proposals in advance.
Deepening Diversity and Inclusion
We have seen a steady increase in the number of women employed by Tosoh, and I suggested that it would be important to expand the number of females in sales and other positions. Furthermore, we are hiring more women in technical roles at Nanyo and Yokkaichi, and we feel that opportunities for diversity in human resources are increasing. In addition, we are amending our rules in line with revisions to laws and regulations regarding the prevention of various types of harassment. I believe it is necessary to enact sufficient measures at each workplace and, depending on the circumstances, to implement severe penalties to prevent recurrence of such harassment.
Importance of Strengthening Group Governance Going Forward
With 49 domestic and 46 overseas consolidated subsidiaries, I am concerned about whether governance has sufficiently pervaded the entire Group. I am not aware of any immediate risks, but I am naturally concerned about the pandemic, which has limited face-to-face interaction. I think it would be useful to ramp up information sharing and risk management within the Group, and also to exercise closer control over companies where required.
Mariko Hidaka
External Director
Strengthening of Compliance
Key performance indicators (KPIs) |
FY2022 Targets |
FY2022 Results |
Appraisal |
1. Reduce number of serious legal violations |
Zero |
Zero |
Achieved |
2. Continue legal compliance and corporate ethics education activities |
Further disseminate the Group's Code of Conduct and compliance awareness through company-wide education and training at each complex, and conduct training, questionnaires, guidance, and audits. |
Achieved |
Basic Concept
The basic policy of the Tosoh Group is to ensure compliance, pursue profits through fair competition, and continue to be a useful entity for society at large. The basis of the Group's compliance activities is for all employees and each and every officer to practice compliance sincerely, fairly, and ethically.
Tosoh Group Code of Conduct
The Tosoh Group Code of Conduct prohibits all forms of corruption, respects human rights, and describes how to deal with important matters that must be observed in conducting business activities. Based on the acknowledgment by top management that compliance is the foundation of the Tosoh Group's management and should take precedence over all other interests, all employees and officers of the Tosoh Group are obliged to comply with the Tosoh Group Code of Conduct.
The Tosoh Group Code of Conduct was revised in October 2018 to include additional CSR initiatives. In addition to the Japanese, English, Chinese, and Korean versions, the Tosoh Group Code of Conduct has been translated into the languages of the respective regions in which the Group's overseas businesses are located. Pamphlets explaining the Tosoh Group Code of Conduct are distributed to all employees and officers of domestic Group companies.
Tosoh Group Code of Conduct Items
I. Ensuring a Comfortable Workplace Where Every Group Member Can Fully Display His/Her Ability
1. Compliance with Laws, Regulations, and Norms in Society
2. Ensure Safe and Stable Operations
3. Compliance with Rules of Employment
4. Human Rights Protection and Discrimination Prevention and Respect for Diversity
5. Harassment Prevention
6. Healthy Workplace
7. Personal Information Protection
8. Proper Use of Corporate Assets
9. Proper Use of Information Technology Systems
II. Meeting the Trust of Customers and Business Partners, Meeting Shareholders’ Expectations
10. Bribery and Corruption Prevention
11. Prohibition of Inappropriate Gift Exchanges and Entertainment
12. Security Export Control
13. Compliance with Import and Export Laws and Regulations
14. Compliance with Competition Laws and Regulations
15. Fair Procurement Practices
16. Product and Service Quality and Safety Control
17. No Relations with Antisocial Forces
18. Compliance with Noncompetition Laws
19. Financial Integrity, Records Management, and Timely Disclosure
20. Intellectual Property Rights Policy
21. Confidential Information Management and Control
22. Prohibition of Insider Dealings
23. Political Donation Control
III. Contributing to the Development of a Sustainable Society
24. Environmental Conservation and Protection
25. Stewardship of Social Responsibility
Compliance Promotion System
Tosoh believes that practicing compliance, which means following the established rules, not only protects employees from accidents and other disasters, but also strengthens the management structure of the entire Tosoh Group. To this end, the company has established a promotion system to ensure that employees are aware of the importance of compliance and are able to practice it. The Compliance Committee reports the content of its deliberations to the Board of Directors.
Compliance Committee
The Committee is chaired by an officer appointed by the president with the heads of relevant divisions among its members, and meets twice a year. The Committee formulates and implements compliance and other training plans; investigates, grasps, evaluates, and inspects the status of compliance promotion; and plans and drafts various measures to promote compliance. The decisions made by the Compliance Committee are reported to the Board of Directors, which oversees and directs compliance activities, including the prevention of bribery and corruption.
Compliance Committee Promotion Team
The company submits its opinions to the Compliance Committee and promotes compliance activities in accordance with the Committee's direction. To ensure thorough compliance throughout the Tosoh Group, we hold group meetings once a year with domestic Group companies (held online in fiscal 2022) to confirm the status of compliance-related activities and provide information to support the promotion of compliance. Moreover, the company serves as a contact point for compliance and harassment consultation, and investigates and responds to matters that require consultation.
Complex Compliance Committees
Planning, formulating, and implementing various compliance promotion measures at each complex.
Division Heads
A responsible person has been appointed in each division to promote compliance.
Tosoh conducts compliance training and other activities within departments in accordance with the Committee’s direction to ensure that each employee is in compliance.
Compliance and Harassment Consultation Desk
To prevent or quickly correct compliance violations, the company has established the Compliance and Harassment Consultation Desk for the purpose of swiftly recognizing and responding to actual or potential violations. Tosoh has established three consultation desks: internal, external, and an auditor's desk. Directors and employees of Tosoh and its domestic and overseas Group companies, temporary employees, and employees of partner companies may choose to submit reports or request consultations to any of these desks.
Consultations are accepted regarding general corrupt practices such as violations of laws and regulations, harassment, human rights violations, and bribery. The company confirms the facts, investigates, and takes action, whether the consultation initiated under a real or an anonymous name. For guidance and supervision, the details of each consultation are reported to the auditor. Those eligible to use the consultation service are given a Consultation Desk Pocket Card to make it more convenient to avail themselves of the service at any time.
The company has established internal rules for the protection of the consultants in investigating and responding to consultation matters, and takes all necessary precautions. Moreover, it has set up a contact point on our website for inquiries that can be consulted from outside the company. Furthermore, consultation services have been established at Group companies in Japan and abroad, creating a Group-wide system that facilitates consultation.
Compliance and Harassment Consultation Service Operation Standards (excerpt)
- The name of the consultant and other personally identifiable information shall not be provided to anyone other than the person in charge of reception and investigation at the Consultation Desk and other related parties—including those involved in the investigation—except when necessary for the investigation or response, or when there is a legitimate reason, such as when required by law.
- Consultants will not be subject to dismissal, disciplinary action, recommendation for resignation, refusal to renew, de facto harassment, or any other disadvantageous treatment as a result of their having submitted a report in line with applicable rules.
- Upon confirmation that a consultant has been treated unfavorably, the company takes appropriate remedial and restorative measures.
Compliance and Harassment Consultation Desk: Number of Consultations
|
FY2020 |
FY2021 |
FY2022 |
Consultations |
22 |
10 |
15 |
Overseas* |
3 |
1 |
2 |
*Number of reports and consultations from overseas Group companies
In fiscal 2022, the company received 15 consultations (two reports from overseas), but none of the cases were serious enough to affect the company’s business activities. In terms of content, many consultations were related to alleged incidents of harassment. In each case, consultants take necessary actions such as collecting facts and cautioning parties involved, and then following up with them to clarify the situation.
Compliance and Harassment Consultation Desk System Chart
Compliance Survey
Tosoh conducts a compliance survey annually to ascertain the status of compliance activities and the extent of understanding of the compliance system and consultation services. The company aims to leverage the survey results to further heighten employees' awareness of compliance and promotion of activities, and link this to compliance education and the planning of various related measures.
In fiscal 2022, Tosoh distributed a survey to all its employees in Japan. Some were distributed with an answer sheet to improve efficiency, and the response rate was 90.5%.
Compliance Education
Ensure Employee Awareness of Harassment Prevention
In fiscal 2022, a publication on harassment case studies introducing examples of violations was prepared jointly with Human Resources and distributed to all employees working at Tosoh in Japan as well as to employees of domestic Group companies to raise awareness of legal compliance.
Compliance Training
Training is conducted annually for new employees and employees at all levels—including new employees—on matters related to compliance and the prevention of bribery and corruption. The content of the program is oriented toward heightening awareness by featuring easy-to-understand case studies to enable employees to feel more comfortable with the program. In addition, Tosoh conducts annual compliance training at each workplace to instill awareness and ensure rules are being complied with.
Furthermore, even during the pandemic, the company uses the intranet and e-learning to share information with Group companies and promote Group-wide compliance education.
Legal Briefings
The Antimonopoly Act, the Act Against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors, the Unfair Competition Prevention Act, the Foreign Exchange and Foreign Trade Act (Security Export Control), the prohibition of bribery in various countries, and other important laws and regulations are outlined and explained to employees at all levels and to employees, including those of domestic Group companies, even during the pandemic.
Moreover, the company provides education for employees posted overseas, including points to bear in mind regarding local laws and regulations. The company also continues to educate employees through e-learning and other means on important laws and regulations, as well as by disseminating information via the company intranet.
Internal Audit
The Audit Office is dedicated to conducting internal audits of operations and other activities to improve and strengthen internal controls at Tosoh and its Group companies. It also conducts internal compliance audits to evaluate the promotion systems and operational status of Tosoh and its Group companies. Audit results are reported to the president and corporate auditors as appropriate.