Compliance

Our Approach to Compliance

TOYO Corporation Group positions compliance as the foundation of trust among all stakeholders and an essential basis for its business operations to achieve sustainable growth. All executives and employees are expected to comply with applicable laws and regulations and act with integrity and fairness, guided by high ethical standards.

Under this principle, the Group has established the TOYO Corporation Group Code of Ethics and Legal Compliance and the TOYO Corporation Compliance Guideline to clearly define our conduct standards and values. These guidelines support the thorough promotion of compliance across the entire Group.

TOYO Corporation Group Code of Ethics and Legal Compliance

1. Respect for human rights and build a good workplace environment

We promote initiatives that respect human rights and diversity and have zero tolerance for any form of discrimination or harassment.
We comply with labor, employment, and occupational health and safety laws, and continuously strive to foster a good and safe workplace environment.

2. Integrity and fair business practices

We prohibit private monopolization, unfair trade restrictions, and other inappropriate business practices, maintaining mutually beneficial relationships with business partners through fair competition.
We ensure the highest levels of quality and safety in the products and services we provide.
We prohibit bribery, corruption, and excessive entertainment or gifts, and maintain appropriate relationships with business partners.
We commit to accurate accounting records and financial reporting.
We respect confidential information and intellectual property rights of others and do not engage in improper acquisition or use.
We do not engage in insider trading based on non-public material information.
We avoid conflicts of interest and do not act to pursue personal gain that conflicts with the Company’s interests.

3. Security trade control

We comply with laws and regulations concerning export control in Japan.
We pay careful attention to laws and regulations related to export control in each country and respond as necessary.

4. Elimination of relationships with antisocial forces

We eliminate any tiles with antisocial or illegal groups and do not engage in any conduct that would benefit such entities.

5. Proper management of company assets and information

We prohibit improper use of company assets, both tangible and intangible, such as products, equipment, software, and intellectual property, and ensure their appropriate management and use.
We respect the privacy of our business partners and employees, and we do our best to protect and manage personal information and other information assets properly.

6. Social contribution and environmental conservation

As members of the local community, we endeavor to contribute to society and strive for harmony and development in the community.
We remain committed to preserving the global environment and endeavor to utilize resources efficiently and responsibly to minimize environmental impact.

TOYO Corporation Compliance Guideline

Compliance Governance Framework

TOYO Corporation Group has established the Risk and Compliance Committee, chaired by the executive officer responsible for risk management. The Committee regularly reviews the status of compliance risks, countermeasures, and overall progress across the organization. It also conducts risk assessments across the Group and, for significant risks, establishes risk management frameworks, monitors management status, and supports and promotes risk management activities.

The designated departments for each risk category report the status of risks, countermeasures, and implementation progress to the Committee. If any issues arise, an emergency meeting is convened to deliberate on fact-finding, root cause analysis, corrective actions, and preventive measures to prevent recurrence.

The Committee also submits an annual report to the Board of Directors on compliance initiatives, violations, and action plans.

Prohibition of bribery, excessive entertainment, and gifts

The TOYO Corporation Compliance Guideline sets forth rules to prohibit and prevent bribery, excessive entertainment, corruption, and any conduct that may be perceived as such, in accordance with domestic and international laws and regulations. The Guideline is published on our website and distributed to all employees to ensure thorough understanding and adherence throughout the organization.

Status for Fiscal Year Ending September 2025

Political contributions: None
Number of disciplinary actions taken against employees due to non-compliance with anti-corruption rules: None
Fines for corruption or costs of settlement: None

Compliance training

To foster and reinforce compliance awareness within the Group, we provide compliance training four times a year to all employees, including temporary staff.
Training topics include business ethics, including anti-corruption, whistleblowing, data protection laws, harassment prevention, and more—ensuring conduct that complies with the law and upholds high ethical standards.

Whistleblowing system

TOYO Corporation Group has established a "Compliance Reporting Hotline" that allows all Group employees to identify and mitigate compliance risks in business activities at an early stage or prevent them from occurring. A third-party organization operates this reporting and consultation hotline and can be accessed in multiple ways, including through a website, email, and written correspondence. Support is available in Japanese, English, and Chinese.

The personal information of whistleblowers will not be disclosed to any department other than the one responsible for investigation and response, unless the whistleblower provides consent. The details of the report will only be shared with those relevant to the investigation and response. They will not be disclosed without a legitimate reason, such as compliance with laws and regulations. If the investigation confirms a violation of rules, regulations, or internal policies, the department in charge will collaborate with relevant departments to take corrective action and prevent recurrence.

Furthermore, our internal whistleblowing regulations strictly prohibit any unfavorable treatment of whistleblowers based on their reports or consultations, and we are committed to thoroughly protecting whistleblowers.

Security trade control

To contribute to international peace and security, prevent the proliferation of weapons of mass destruction, and avoid excessive accumulation of conventional weapons, TOYO Corporation Group complies with Japan’s Foreign Exchange and Foreign Trade Act (“FEFTA”) and other relevant export regulations. This includes the export of regulated goods and technologies, the re-export of imported goods, and the provision of technologies to third countries.

To ensure appropriate implementation, we have established the Security Trade Control Committee, chaired by the executive officer responsible for security trade control, with the President & CEO serving as the highest responsible party.