Toshiba Corporation

Based on public information, there is no readily available evidence that the company publishes a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company. TI notes the company publishes a statement from the CEO supporting the company approach to integrity, but this is deemed insufficiently strong.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer or Chair of the Board demonstrate strong personal, external facing commitment to the ethics and anti-corruption agenda of the company.

Based on public information, there is no readily available evidence that the company’s Chief Executive Officer demonstrates a strong personal internal-facing commitment to the ethics and anti-corruption agenda.

Based on public information, there is some evidence that the company publishes a statement emphasising integrity. However, this falls short of the range of values sought by the question and there is no evidence that this statement is translated into company’s policies.

Based on public information, there is evidence that the company is a signatory of the UN Global Compact.

Based on public information, there is no readily available evidence that the company has appointed a Board level individual or committee with overall corporate responsibility for its ethics and anti-corruption agenda. TI notes that the terms of reference for the Audit Committee include responsibility for investigating violations of the law, but it is not clear whether it has responsibility for the ethics agenda. To score higher the company would need to demonstrate that the Audit Committee has overall responsibility for the ethics and anti-corruption agenda, and that its terms of reference are clear and detail what this responsibility entails.

Based on public information, there is evidence that the company has appointed a Chief Implementation Administrator with the responsibility for implementing the company’s Standard of Conduct. However, this individual is not identifiable by name. The company therefore scores 1.

Based on public information, there is evidence that the company regularly monitors and reviews the performance of its company’s ethics and anti-corruption agenda.

Based on public information, there is evidence of an underlying structure guiding the review of the ethics and anti-corruption agenda, and of improvement plans being implemented when issues are identified. The company’s CSR Assessment and Internal Audit procedures suggest that there is a general plan for review of ethics and anti-corruption. However, there is no evidence of a formal, written plan. The company therefore scores 1. To score higher the company would need to demonstrate that there is a formal, clear, written plan that guides Board and senior management review.

Based on public information, there is some evidence that the company has a process in response to compliance violations. However, it is unclear if it reviews and where appropriate updates its policies and practices in response to actual or alleged instances of corruption. The company therefore scores 1.

Based on public information, there is evidence that the company undertakes risk management activities, but there is no readily available evidence that this includes an anti-corruption risk assessment implemented enterprise-wide.

Based on public information, there is no readily available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting or reappointing its agents.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption. TI notes that there is a request for cooperation in their procurement policy.

Based on public information, there is some evidence that the company has made clear to contractors, sub-contractors, and suppliers its stance on bribery, but falls short in stating the consequences of breaches to this stance. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company explicitly addresses the corruption risks associated with offset contracting.

Based on public information, there is no readily available evidence that the company conducts due diligence that minimises corruption risk when selecting its offset partners and offset brokers.

Based on public information, there is evidence that the company has an anti-corruption policy that prohibits corruption. However, this does not explicitly cover all the forms that corruption may take and is only in regard to government, public and political officials, rather than private third parties. The company therefore scores 1.

Based on public information, there is no readily available evidence that the anti-corruption policy is explicitly one of zero tolerance. However, the company has a zero tolerance policy of violations of the Code of Business Ethics and Conduct, as shown by its explicit stance on disciplinary procedures in the event of a violation by any employee or director. The company therefore scores 1.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible to Board members, employees and third parties.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear to board members, employees and third parties. It is written in clear language without dense, legal terms.

Based on public information, there is evidence that the company’s anti-corruption policy explicitly applies to all employees and members of the Board.

Based on public information, there is no readily available evidence that the company has a policy on potential conflicts of interest.

Based on public information, there is no readily available evidence that the company has a policy that prohibits the giving and receipt of gifts, or regulates such transactions to ensure that they are bona fide and not a subterfuge for bribery. TI notes the company’s statement on improper payments which includes the offering of gifts, but this is not assessed to be comprehensive and detailed enough to merit a score.

Based on public information, there is no readily available evidence that the company has a policy that prohibits the giving and receipt of hospitality, or regulates such transactions to ensure that they are bona fide and not a subterfuge for bribery. TI notes the company’s statement on improper payments, which includes entertainment. However, this does not seem to prohibit or regulate the exchange of hospitality.

Based on public information, there is no readily available evidence of a policy that explicitly prohibits facilitation payments. TI notes that there is a policy on improper payments, but it is not clear that this refers to facilitation payments.

Based on public information, there is evidence that the company regulates political contributions. However, there is no evidence that the company publicly discloses such contributions. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy on lobbying in order to prevent undue influence or other corrupt intent, or discloses the issues on which it lobbies.

Based on public information, there is evidence that the company regulates its charitable contributions and donations. However, there is no evidence that the company publically discloses recipients. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company provides written guidance to help Board members and employees understand and implement the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that the company has an explicit anti-corruption module as part of its ethics and compliance training programme.

Based on public information, there is evidence that the company provides anti-corruption training in all countries where it operates.

Based on public information, there is evidence that the company provides targeted anti-corruption training to top executives, but it is unclear if this refers to members of the board.

Based on public information, there is evidence that the company provides tailored anti-corruption training for employees in sensitive positions.

Based on public information, there is no readily available evidence of a clear and formal process by which employees can declare conflicts of interest. TI notes the company’s reporting system for violations.

Based on public information, there is evidence that the company clearly states it will apply disciplinary procedures to employees who have violated its anti-corruption policy. This policy is applicable to employees and Board members.

Based on public information, there is evidence that the company has some accessible reporting channels for employees to report concerns or instances of suspected corrupt activity. However, evidence does not suggest that one of the channels is externally operated or facilitates anonymous reporting. The company therefore scores 1.

Based on public information, there is evidence that across geographies, all employees have access to more than one whistleblowing channel. These channels include the Risk Hotline and the Attorney’s Office.

Based on public information, there is no readily available evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively. TI notes the company’s whistleblower system, but there is no evidence of mechanisms such as independent employee surveys or the analysis of whistleblower channel statistics.

Based on public information, there is limited evidence that the company has well-publicised resources available to all employees where help and advice can be sought on corruption-related issues. A Risk Hotline is available via the intranet, but there is no evidence that employees are directed to seek advice from this source, or that they have access to trained managers or advisors. The company therefore scores 1.

Based on public information, there is insufficient evidence that the company has a non-retaliation policy for bona fide reporting of corruption. TI assesses it is not a strong commitment and there is no evidence that employees breaching this policy are disciplined.