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Ethics and compliance

CFAO is a responsible group, committed to strong principles of integrity, respect and transparency in its relationships with employees, customers and partners.

Global Code of Conduct and Ethics

The CFAO Group conducts its business in accordance with strong principles of integrity, transparency, responsibility, and compliance, in the service of building trust with its stakeholders.

The Group applies the Code of Conduct and Ethics (COCE), which is shared across the entire Toyota Tsusho Corporation Group. The COCE constitutes the common foundation of our values and principles of conduct, and applies to all Group activities, in all countries and across all business lines.

Based on 10 fundamental principles aligned with international standards, the COCE provides a shared framework to guide day-to-day professional decisions and behaviors.

The ten principles of the COCE

  1. We apply the Anzen (Safety first) principle to ensure a safe and healthy working environment.
  2. We comply with all applicable laws and regulations, particularly in the areas of anti-corruption, competition, and business conduct.
  3. We ensure the reliability and accuracy of financial information.
  4. We are responsible for complying with internal rules and Group policies.
  5. We act with integrity, honesty, and transparency, and build trust-based relationships with our stakeholders.
  6. We contribute to the sustainable development of society.
  7. We promote environmentally responsible activities.
  8. We create value through innovation and continuous improvement (Kaizen).
  9. We respect human rights.
  10. We respect diversity and promote a professional environment based on respect.

Anti-corruption framework

As part of its compliance program, the CFAO Group has implemented a structured system to prevent corruption and influence peddling.

In line with the provisions of the Sapin II law on transparency and anti-corruption, CFAO has adopted its Anti-Corruption Code of Conduct, which complements the Code of Conduct and Ethics (COCE).

This Code is supported by dedicated procedures, notably relating to the whistleblowing system, prevention of conflicts of interest, and third-party due diligence.

Together, these tools form a consistent and comprehensive framework applicable to all Group entities.

Ethical alert system

As part of its ethical approach and its legal obligations, CFAO Group has set up a Whistleblowing system called SPEAK UP.

Its purpose is to allow any person, Group employee or third party (customers, suppliers, business partners, etc.), to report a violation of law, or breach of company rules and/or behavior that they consider unethical or contrary to the rules set out in the Group’s compliance policies and procedures, namely: the Code of Conduct and Ethics (COCE), the Anti-Corruption Code of Conduct, etc.

This system is supplementary to the other available channels like hierarchy line manager; HR; appropriate Corporate department etc.

The SPEAK UP whistleblowing system is a dedicated communication channel to report alerts of potential cases of non-compliance, available at any time (24/7, 365 days a year).

Confidentiality and non-retaliation

Anyone who makes a report in good faith, will be protected. Be assured that you will not suffer as a result of raising an alert about potential non-compliance or misconduct. Any form of threat or retaliation will not be tolerated by CFAO.

CFAO undertakes to process all the data collected (particularly the identity of the whistleblower, that of the persons affected by the alert and the facts reported), with the highest degree of confidentiality and in accordance with the requirements of the European Data Protection Regulation.

For more information, please consult the Whistleblowing Procedure applicable within CFAO group.

 

External alert

The Whistleblower, either after having made an internal report (via the company’s internal system), or directly, can make an external report to the competent authorities, the list of which is established by a decree of the Council of State.

The list of authorities competent to receive external reports is communicated via the following link: Decree No. 2022-1284 of October 3, 2022.

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