As an initiative to combat corruption as stipulated in Principle 10 of the United Nation Global Compact, the Topcon Group prohibits giving out bribes or inappropriate profits in any form that violate laws, regulations or sound business practices. In addition, we prohibit employees from accepting inappropriate personal benefits or profits in connection to their work or position.
Ban on Giving Inappropriate Benefits
The Topcon Group does not give out bribes or inappropriate benefits or profits that violate laws, regulations or sound business practices. The Group’s employee recognize that bribery is prohibited not only of public-sector officials and employees but also of employees at private-sector companies depending on the countries involved, and we require our employees to understand the content of laws and regulations in countries and regions related to their work and comply with them.
The Group defines bribery as offering such things as specified below to another party as a way to receive inappropriate benefits or profits in business activities or rewards accepted in exchange for providing inappropriate benefits or profits to others that have some form of value, and applies this definition to such parties as identified below.
- Officials at foreign or domestic government bodies, including state-owned enterprises or international organizations
(applies to former officials at such bodies)
- Politicians, including candidates for office, political organizations, and their employees
- General customers regardless of whether they are a legal corporate entity or an individual
Bribery is not limited to monetary payments but can include business entertainment, receptions, gifts, donations, gratuities or other forms of benefits regardless of the monetary sum or value involved. In cases where active intermediaries such as agents are working on behalf of the Topcon Group, rules have been established to prohibit employees etc. from coercing agents to commit any of the aforementioned deeds and to clearly determine in advance a reasonable set of boundaries for the services and compensation of intermediaries such as agents.
Ban on Acceptance of Personal Benefits
The Topcon Group prohibits group employees from accepting offers for or demanding personal benefits in connection to their work or position.
That said, in cases where customers or suppliers propose to offer business entertainment, organize a reception or give gifts etc. within the bounds of common sense and the law, regulations, and sound business practices of the country or regions involved, we grant exceptions only for those cases where there is minimal risk the business entertainment, reception or gift etc. will influence decision-making at the Topcon Group. Our rules require group employees to refuse all requests for benefits with a large monetary value or that are extravagant in ways that go beyond common practice.
The Topcon Group will do its utmost to improve quality at all stages from development and design to manufacturing, sales, and services and supply highly reliable products that contribute to the development of our customers’ businesses, as set out in the TOPCON WAY. In these ways, the Topcon Group emphasizes quality assurance.
For these reasons, we perform quality assurance activities that place a high value on the four following commitments:
1) provide services and safe, high-quality products that respond to customer requirements via our dedication to a “customer-orientation” and “quality-first” approach; 2) build in quality via full employee participation across all functions from development and design to manufacturing, procurement, sales and after-service; 3) comply with the laws and regulations of each country relevant to our businesses, widely accepted rules and norms, notifications, guidelines, standards, contracts with customers, and internal company rules as well as understand and comply with the controlled substance laws and other relevant laws and regulations of each country regarding medical equipment manufacturing and sales; and 4) immediately confirm relevant facts and take proper steps in cases where we obtain information on accidents involving our services or products and strive to pursue actual causes and work to prevent recurrence.
In recognition of suppliers as a presence that make a sizeable contribution to our business success, the Topcon Group seeks to conduct honest transactions with suppliers. For procurement, we have established rules for procuring supplies based on a comprehensive and fair valuation that takes into account environmental considerations, the Group’s need to secure a stable supply as well as quality, price, delivery, and after-sales service.