An effective ethics and compliance program must constantly evolve and be evaluated to ensure the company is addressing current risks and expectations. The Bridgestone Group actively monitors resources such as the Transparency
International’s Corruption Perceptions Index (CPI) to understand the key compliance risks in the places where it does business.
Key compliance issues, including anti-corruption, antitrust, fraud, discrimination and other compliance risks, have long been included in annual enterprise risk assessments, and breaches of regional codes of conduct and/or
anti-corruption policies have been tracked on a regional basis. Since 2018, tracking has been consolidated on a global basis and formal and informal compliance-specific risk assessments have been conducted in each region
in 2019 and 2020 for a deeper view of compliance risks.
Key risks identified through these processes are communicated to senior leadership on a regional and global basis. Controls are implemented to address critical risks, including corruption risks (such as risks related to facilitating
payments, gifts and entertainment, money laundering, and political contributions) in high-risk locations. These controls are carefully considered and strategically implemented to effectively counter significant risks without
placing an undue burden on Bridgestone’s business.
The effectiveness of key controls, including those related to fraud, corruption and money laundering, are reviewed within the scope of periodic enterprise audits. In the spirit of continuous improvement (kaizen), processes
and controls are frequently reviewed and optimized. Bridgestone’s new global compliance structure has created many opportunities for reviewing existing processes, identifying best practices and gaps, and implementing enhancements.
Similarly, the global compliance framework creates opportunities for reviewing and optimizing policies related to key compliance risks. When preparing Bridgestone’s global Code of Conduct, the company's Global Compliance team
considered the effectiveness of existing regional policies and codes of ethics and sought to address any existing gaps. The Code of Conduct is a living document, and the global team will continue this practice of periodically
reviewing its effectiveness and adjusting it, or the compliance program more generally, as needed to meet the goal of maintaining a best-in-class compliance program.