tpcn csr2011 Eng 0622 · within global TOPCON group companies. TOPCON will acquire understanding...

TOPCON CSR REPORT 20111 TOPCON CSR REPORT 2011 2

● Corporate name : TOPCON CORPORATION● Established : September 1,1932● Location of the head office : 75-1, Hasunuma-cho, Itabashi-ku, Tokyo● President : Takashi Yokokura, President ● Capital : 10,297 million yen (as of March 31,2010)

● Consolidated subsidiaries : 12 domestic and 44 overseas companies (as of March 31,2011)● Number of employees : 4,727 (consolidated; as of March 31,2011)

● Business : Positioning business (surveying equipment) Eye Care business (Ophthalmic & medical equipment) Finetech business (industrial equipment

and optical devices)

● Major international CSR-related charters TOPCON supports : United Nations Global Compact

Company Overview Editorial Policy: About the Disclosure of Our CSR-Related Information

TOPCON GROUP

Financial Information

JAPAN14 companies

(2,125 employees)

EUROPE17 companies

(614 employees) CHINA5 companies

(968 employees)

NORTH AMERICA13 companies

(808 employees)

ASIA & OCEANIA8 companies

(212 employees)

PBU : Positioning Business UnitEBU : Eye Care Business UnitFBU : Finetech Business Unit

http://global.topcon.com/about/profile (Corporate Profile)

http://global.topcon.com/invest/library/finance/ (Financial Results)

(100 million yen)Less than 100 million yen omission

0

●Consolidated Sales ●Operating Income, Net Income ●Sales by Region

Total PBU EBU FBU

2006 2007 2008 2009 2010

(100 million yen)

(FY)

309

199

536

384

183

1,104

509

398

200

1,108

580

335

211

1,126

493 515

315

139

1,024

948

0

100

200

300

400

500

600

1000

1100

1200 Operating IncomeNet Income

2006 2007 2008 2009 2010

(100 million yen)

(FY)

152

109

-69

14 17

-12

85 77

-99

1

-100-80-60-40-20

020406080

100120140160

Japan284

North America173

Europe226

China120

Asia andOceania

125

Others97

In 2006, the TOPCON Group published a CSR report for the first time, combining an environment report that had been issued previously. Since then, the TOPCON Group has endeavored to convey to all our stake-holders our ideas about corporate social responsibilities (CSR) and our efforts at fulfilling our CSR obligations. As a fundamental principle, the TOPCON Group has set forth the “TOPCON WAY”to re-clarify our traditional values cultivated over decades and the facets of our corpo-rate identity we should not change. The CSR Report 2011, the sixth edition since 2006, contains articles that we think are in line with the “TOPCON WAY”. In editing the CSR Report 2011, we have used well-accepted guidelines for CSR activities and reporting, information ex-changes with nonprofit organizations (NPOs), and working sessions of the Global Compact Japan Network (GC-JN) as a basis for effective disclosure of in-formation.The feature story introduces our prod-ucts that contribute to the development of social infrastructure, one of the social responsibilities that the TOPCON Group should share. As a participant in the UN Global Compact, the TOPCON Group is expected to integrate in an annual Com-munication on Progress (COP) report a description of the ways it has imple-mented the GC10 principles (with regard to human rights, labor, environment and anti-corruption). The CSR Report 2011 was designed to also serve as a COP re-port.

Company Overview 1

TOPCON GROUP 1

Financial Information 1

Editorial Policy 2

Message from Top Management 3

“TOPCON WAY” 4

Basic Policy for CSR, etc. 5

Introduction of Business 6

The measure and target of CSR 7

TOPCON Products That Contribute to the

Development of Social Infrastructure 9

Addressing Corporate Governance Issues 11

Holding events for CSR Month 11

Addressing Risk-Compliance issue 12

Grappling with the Business Continuity Plan (BCP) 12

Quality Improvement Activities 14

Activities with Business Partners 14

Responsibilities to Employees 15

Labor Union 16

Measures for Smoking; health promotion, etc. 17

UNGC-related activities 19

Environmental Protection Activities 20

Contribution to the global and local community 23

Hoping for an Early Recovery from Disaster 25

Joining Forces with Our Stakeholders 25

Third-Party Opinion 26

In Response to Third-Party Opinion 26

● Report Period

This CSR report mainly covers our ac-tivities for the period from April 1, 2010 to March 31, 2011.

● Scope of the Report

Basically, this CSR report describes the activities and achievements of the entire TOPCON Group, except where specifically noted otherwise.

● Date of Publication

June 2011 (Previous issue: June 2010)

● Guidelines Used as References

ISO26000 “Guidance on social respon-sibility“

Global Reporting Initiative (GRI) G3 Guidelines

Environment Reporting Guidelines 2007 from the Ministry of the Environment of Japan

Our Code of Business Conduct states, "TOPCON will have communication-widely with the society and disclose the correct corporate information ap-propriately on a timely basis." In line with this commitment, the TOPCON website provides information as required by and in accordance with appli-cable laws and stock exchange regulations.

In addition, TOPCON will continually post information that may be of interest to our stakeholders in a timely and appropriate fashion.The TOPCON website has been highly appraised by several rating agencies.For details, please see the Investor Relations page on the website.The Website of the TOPCON Group is highly rated by multiple website rating or-ganizations. For details, see Joining Forces with Our Stakeholders on page 25.

TOPCON CSR REPORT 20111

CONTENTS

CS

R M

ind

Sp

ecia

lFe

atu

reThird-Party

OpinionC

SR

Ma

na

gem

en

t Rep

ort

CS

R A

ctivity R

ep

ort

About Our Website

● The Management Vision, Management Policy and Business Conduct Guidelines were integrated and rearranged into the “TOPCON WAY”, a newly-defined fundamental principle of the TOPCON Group http://global.topcon.com/about/philosophy/ (“TOPCON WAY”)

● The Social and Environmental Activities (CSR) page contains the PDF files of this and previous CSR reports, as well as additional environment-related information not covered in the CSR report, and our Business Conduct Guidelines and CSR Policy. http://global.topcon.com/csr/index.html (Social and Environmental Activities (CSR))

http://global.topcon.com/csr/code/index.html (TOPCON Code of Business Conduct)

http://global.topcon.com/csr/policy/index.html (Major policies of CSR)

● The Investor Relations page provides information about stocks and financial performance, IR website award that TOPCON has received and so on. http://global.topcon.com/invest/index.html (Investor Relations)


First of all, I'd like to express my condolences to the people affected by the Great East Japan Earthquake and pray for them to recover a normal life as soon as possible.TOPCON is engaged in businesses that are closely re-lated to people's daily life, namely Positioning (social infrastructure), Eye Care (medical care) and Finetech (advanced technology). We'd like to exert our exper-tise to provide reconstruction assistance to the af-flicted areas.In April, the TOPCON Group set forth the “TOPCON WAY” as a management vision shared by all the group companies. TOPCON has a corporate identity cultivated since its establishment in 1932. Fortunate-ly, TOPCON has enjoyed the trust and goodwill of many stakeholders and steadily expanded its busi-nesses.However, given rapidly-changing social and business environments, we were challenged to re-think our so-cial significance and how we can better connect to our stakeholders. Consequently, the “TOPCON WAY” re-clarifies a set of values we should keep."The “TOPCON WAY” consists of seven principles listed on the right page.Regarding relationships with international and local communities, the “TOPCON WAY” reflects the princi-ples of the UN Global Compact which we have partici-pated in since 2007. This is because we think that compliance with international standards is a key to a continual growth of sound global markets."With the “TOPCON WAY” as guidepost, TOPCON will continue to study the possibilities of "light" with TOP-CON-likeness, and contribute to build a rich human society and support all life forms.The keywords are "proactive and responsive atti-tudes" and "compliance." It is my sincere desire to re-spond to social needs expeditiously and flexibly. I'd be grateful for your support, suggestions and feed-back.

CSR MindMessage from Top Management

Integrating CSR Management into the Corporate Culture

●The “TOPCON WAY” defines a set of values, decision-making criteria and overriding principles that all executives and employees of the TOPCON Group share beyond the national and corporate boundaries.

●Clause 1 defines the principle of our existence; Clause 2 clarifies the prerequisite for our existence; and Clauses 3 to 7 declare our relationships with our stakeholders.

●The word “light” in Clause 1 refers to a wide range of our technologies in the areas of radio waves, infrared rays, visible light, ultraviolet rays and X rays.


CSR Mind

To fulfill our CSR obligations in accordance with the “TOPCON WAY”, TOPCON Code of Business Conduct

and the 10 principles of the Global Compact, the TOPCON Group shares the basic policy and the CSR

organization.

The TOPCON Group introduces various products to the global market by leveraging its core competency

in optics accumulated since its establishment. Following is an overview of the three business units of

the TOPCON Group and their products from a CSR point of view.

Introduction of Business

123456

TOPCON will locate CSR activities in the center of business and work on it intentionally in order to build, share and implement the sense of values and standards suitable for global enterprise.

TOPCON will, to the extent of our influence, support and implement the rules and regulations that are globally approved regarding Hu-man Rights, Labor Standards,Environment and/or Anti-Corruption as declared in THE GLOBAL COMPACT.

TOPCON will make a social contribution voluntarily and actively through developments, production, sales and services of useful products.

TOPCON will promote an environmental management through the creation of environmentally-conscious business process and through providing with environmentally-conscious products and ser-vices.

TOPCON will strive to establish CSR activities in everyofficer and employee's daily work and to infiltrate and establish them within global TOPCON group companies.

TOPCON will acquire understanding and confidence of all the stake-holders of TOPCON group companies by providing with information actively.

Reconstruction Assistance for the Ar-

eas Affected by the Great East Japan

Earthquake

The Positioning Business Unit offers vari-ous high-precision positioning and dis-tance-measuring instruments to the world market ahead of its competitors by leverag-ing its state-of-the-art GPS, laser and image analysis technologies. Total stations and GPS receivers are most widely used for land surveying, civil engineering and 3D measurment.These products are collectively referred to as positioning sensors. They are combined with other kinds of sensors and control technologies to create diverse products for a broad range of applications, such as Con-struction ICT, precision agriculture and mo-bile control. (The positioning sensor appli-cations are detailed in “TOPCON Products That Contribute to the Development of So-cial Infrastructure” on pages 9 and 10.

We believed that the products of the Posi-tioning Business Unit (such as GPS survey-ing equipment) are indispensable for the re-construction of the areas affected by the Great East Japan Earthquake and donated our GPS and other survey equipment.

Positioning

Business Unit

TOPCON's Optical Technology Used

for Space Exploration

The main product offerings of the Finetech Business Unit include inspection and pro-duction systems used in the semiconductor and flat-panel display (FPD) industries. It also offers electron beam products, optical units for projector applications, optical components for DVD recorder/player appli-cations and optical instruments for aero-space applications.Asteroid explorer Hayabusa launched on May 9, 2003 by the Japan Aerospace Explo-ration Agency (JAXA) re-entered the Earth's atmosphere on June 13, 2010 above the Woomera desert in Australia. It returned to Earth after a long odyssey of seven years and approximately six billion kilometers.Hayabusa was equipped with a number of optical sensors using TOPCON's compo-nents, which contributed to the success of the space mission. Among these compo-nents are optical sensors for autonomous space navigation; a laser altimeter used to measure Hayabusa's distance from the asteroid Itokawa for landing navigation; an obstacle sensor used to prevent solar battery panels from touching the asteroid surface during descent; and an infrared spectrometer used to observe mineral compositions on the surface of Itokawa.

Finetech

Business Unit

Basic policy for CSR Overview of Corporate Governance, Internal control,Risk-compliance

Relationship between stakeholders

and the TOPCON GROUPBased on the basic policy for CSR, the TOPCON Group offers products and services that will help address social challenges. At the same time, the TOP-CON Group attaches great importance to communications with its stakehold-ers and endeavors to make social contributions through its business activities.

Consumers&

customers

Providing productsand services

Skill development, fair evaluation,safety, health, etc.

National andlocal

administration

NPOs & citizengroups

SuppliersStockholders

&investors

Public information disclosure, dividend distribution, governance, etc.

Third-party opinions, cooperative works

Observing laws and regulations

Localcommunity

Environmental protection, plant tours, and linkage for local revitalization

Employees

Specifying materialprocurement policiesand promoting SCM

TOPCON

GROUP

Exhibitions, Exhibitions, academic academic conferences,conferences,publications,publications,call centerscall centers

Legal documentsLegal documentsSupport for Support for environmental environmental administrationadministration

RoHS compliance RoHS compliance assurance systemsassurance systems

CSR INFO-LINK CSR INFO-LINK TOPCON Code of TOPCON Code of Business ConductBusiness Conduct

Support for Support for local eventslocal events

Stockholder Stockholder newsletters newsletters IR magazinesIR magazines

Exhibitions, academic conferences,publications,call centers

Legal documentsSupport for environmental administration

RoHS compliance assurance systems

CSR INFO-LINK TOPCON Code of Business Conduct

Support for local events

Stockholder newsletters IR magazines

Support for Support for activities, activities, information information exchangesexchanges

Support for activities, information exchanges

In addition to CSR reports and websites, the TOPCON Group utilizes various channels of communication.Company's Committees

Observinglaws and

regulations

Risk-Compliancecommittee

BCPcommittee

InformationSecurity

committee

ExportControl

programs

Environment

GlobalEnvironmentConference

EnvironmentalProtectioncommittee

Qualityassurance

President

Committee members (Heads of each division)

Secretariat: (Div. in charge of CSR)

Chairman of TOPCON CSR Committee (Executive Officers in charge of CSR)

QScommittee

Customersatisfaction

CS activity

Human rightsand employee

satisfaction

Linkage

Employmentof persons with

disabilities

Safety andhealth

committee

Gender equalsociety

Welfarecommittee

Socialcontribution

SocialContributions

Activities

TOPCON CSR Committee

Topcon studies the possibilities of “light,” creates new values toward the future, and contributes to build a rich human society.C

SR

Min

dTO

PCO

N

Innovative PASCAL Retinal

Photocoagulator

The Eye Care Business Unit mainly of-fers ophthalmic examination equipment, advanced medical equipment, diagnostic systems, and optical lens edgers.

In August 2010, TOPCON set up a new firm to make a full-scale entry into the market of ophthalmic treatment sys-tems. The PASCAL photocoagulator is designed for retinal photocoagulation procedures (a method of treating tears of the retina using a laser) using a pre-determined pattern array.As the population ages, elderly persons account for an increasingly larger per-centage of diabetic patients. Diabetes leads to various health complications, of which diabetic retinopathy is the leading cause of blindness in Japanese adults.For the treatment of diabetic retinopathy, photocoagulation is one of the important therapeutic alternatives along with sur-gery and medications.PASCAL steers a laser beam in a prede-termined pattern array, which provides benefits such as less patient pain and shorter treatment time.

Eye Care

Business Unit

Structure of Promoting CSR

Topcon studies the possibilities of “light,” creates new values toward the future, and contributes to build a rich human society.

　 http://global.topcon.com/about/philosophy/ (“TOPCON WAY”) http://global.topcon.com/csr/code/index.html (TOPCON Code of Business Conduct) 　 http://global.topcon.com/invest/strategy/governance/(Corporate Governance)

　　 http://global.topcon.com/products (Products)

Corporate Governance Priniples Corporate Governance

Participation in the UN Global Compact in October,2007【Corporate culture, based on our corporate vision and code of conduct】

“TOPCON WAY”　”TOPCON WAY”Promotion CommitteeTOPCON Code of Business Conduct Whistleblower hot-line

【Internal control】

【CSR,Risk-Conpliance】

Corporate Auditor, Corporate Audit Div., Compliance program audit against each corporate staff department＊Compliant with the board resolution "Establishing an organization for maintaining the appropriateness of business practices"

Key Committees Key Regulations

TOPCON CSR Committee Basic policy for CSR

Basic regulation for Risk Compliance

BCP committee BCP Basic policy

Information Security committee Basic Regulation for Information Security,Basic Regulation for Personal Data Protection

Safety and health committee Basic regulation for Safety and Hygiene

Global Environment Conference/Environmental Protection committee Basic regulations about environmental protection

QS committee BASIC POLICIES for TOTAL QUALITY ASSURANCE

made on May 25, 2006

Risk-Compliance committee

©JAXA


CSR MindThe measure and target of CSR

General Overview of the CSR Activities in 2010

Comments from the Chairman of the CSR Committee

CS

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ind

TOPC

ON

Items Key Goals and Plans for FY2010 Key Achievements in FY2010 ※ Key Goals and Plans for FY2011

Corporate

Governance

○ Implementation of corporate governance & CSR seminars○ Formulated the Corporate Governance Principles○ Formulated the “TOPCON WAY”○ Updated in-house training programs and held seminars for new managers ○

○ Disseminating the Corporate Governance Principles and the “TOPCON WAY”○ Holding seminars on the Corporate Governance Principles and CSR

○ Issuing a reference leaflet on TOPCON Code of Business Conduct and disseminating it throughout the TOPCON Group

○ Issued a reference leaflet on TOPCON Code of Business Conduct and posted it on the bulletin board of the in-house database ○ Disseminating the reference leaflet on TOPCON Code of Business Conduct across the TOPCON Group

Risk Compliance

○ Reviewing the BCP and holding BCP training ○ Took measures regarding the Great East Japan Earthquake and reviewed the BCP action plan (Conducted an earthquake emergency drill and drew up anti-flu checklist)

○

○ Reviewing the BCP (Continued)○ Drawing up and implementing the BCP, based on expected summertime power shortage

○ Holding Risk-Compliance seminars

○ Held Risk-Compliance seminars and improved content of the in-house Risk-Compliance bulletin board.

○ Formulated basic regulations on public relations management and regulations on prevention of bribery of domestic and foreign public officials, etc.

○ Compliance with the statutory employment rate for persons with disabilities○ Reviewing the content of and continuing Risk-Compliance seminars

○ Holding topic-by-topic compliance seminars (Continued) ○ Held seminars for all qualified ○ Held seminars for all qualified

Responsibilities to

Customers

○ Developing and releasing new products through promotion of TM-1 activities (Continued) ○ Conducted Technology/Quality innovation project to shorten development times and improve quality

○

○ Developing and releasing new products through promotion of TM-1 activities (Continued)

○ Improving the total quality assurance system across group companies ○ Conducted quality-first drives by declaring Technology/Quality Month and holding quality forums ○ Improving the total quality assurance system across group companies (Continued)

○ Improving pre-verification capabilities in upper stream and prevention of quality problems ○ Held process improvement seminars for engineering departments ○ Improving pre-verification capabilities in upper stream and prevention of quality problems (Continued)

○ Promoting prompt feedback of customer information ○ Promoted speedup in the feedback of quality information from call centers and group companies ○ Promoting prompt feedback of customer information (Continued)

Responsibilities to

Business Partners○ Extending applications of the RoHS compliance assurance system to overseas

suppliers○ Conducted as planned 4 companies (2 companies in 2010A and 2010B each) ○ ○ Further extending applications of the RoHS compliance assurance system to

overseas suppliers(4 suppliers)

Responsibilities to

Employees

　

○ Improving physical and mental checkup items and implementation of preventive measures (restricts working hours, etc.) based on their results

○ Gave interviews with industrial medical advisors after checkups and restricted working hours

○

○ Measures for reducing metabolic syndrome cases (special health maintenance guidance, in-house plans)

○ Implementation of no-smoking programs (smoking cessation support) ○ 46 employees quit smoking as a result of no-smoking/smoking-cessation promotion (Smoking rate decreased from 33% to 30%.) ○ Continuing no-smoking programs (Target smoking rate = 28%)

○ Implementation of management training programs on safety assurance obligations ○ Conducted as part of training for new managers ○ Strengthening cooperation in safety and health matters with group companies and improving management levels

○ Drawing up a Basic Policy on Human Resource Development ○Conducted as part of training for new managers Collated existing related policies and re-declared a human resource development policy to group companies. ○ Continual improvement of the personnel system

Responsibilities

to International

and Local

Communities

○ Providing environmentally conscious and resource-saving products, and products and services useful for improving medical care, health care and life in general (Continued)

○ Provided products that would help address social issues (global warming, population aging, resource depletion).

○

Continued

○ International volunteer assistance ○ Conducted as planned Continued

○ Assisting of medical and academic institutes (product donation and sponsor seminars) (Continued) ○ Conducted as planned Continued

Enforcing

Environment

Management System

○ Increasing the number of companies to be audited　Environmental auditing: 10 group companies

○ Increased the number of companies to be audited Environmental auditing: 11 group companies ○

○ Continuing environmental auditing　Environmental auditing: 11 companies　Integrating and extending ISO certification

Providing Environmentally

Conscious Products and Services○ Providing environmentally conscious products　Over 60% of sales

○ Provided environmentally conscious products Over 64% of sales　 ○ ○ Providing environmentally conscious products

　Over 64% of sales

Establishing

Environmentally

Conscience

Business Processes

○ Implementation of measures against global warming (Reduction in CO2 emissions)　Total emissions relative to 1990 (per unit of sales): 25% reduction (less than 9.06)

○ Implemented measures against global warming (Reduction in CO2 emissions) Total emissions relative to 1990 (per unit of sales): 19.5% reduction (9.73)

△

○ Implementation of measures against global warming (Reduction in CO2 emissions)　5.5% reduction from the previous year (to comply with Tokyo metropolitan ordinance)

○ "Effective use of resources Total waste volume relative to 2000 (per unit of sales): 20% reduction (less than 1.108)"

○ Effective use of resources Total waste volume relative to 2000 (per unit of sales): 33% reduction (0.852)

○ Effective use of resources　Continuing zero-emission efforts (Less than the previous year)

○ Management of chemical substances Use of organic solvents: 72.5% reduction (less than 3,275 kg)

○ Management of chemical substances Use of organic solvents: 75.6% reduction (2,910 kg)

○ Management of chemical substances　"Strengthening central management(Using less chemical substances than the previous year)"

Promoting Environmental

Communication○ Strengthening of cooperation with administration and local residents ○ Strengthened cooperation with administration and local residents

Assisted with public projects and cooperated with civic groups. ○ ○ Strengthening of cooperation with administration and local residents

Responsibilities to

Stockholders and Investors○ Providing information to stockholders and investors○ Maintaining external evaluations and increasing analyst coverage

○ Improved Web content.○ Increased analyst coverage by two firms ○ ○ Providing information to stockholders and investors

○ Maintaining external evaluations and increasing analyst coverage

Communication

○ Issuing TOPCON GROUP CSR Report (Continued) ○ Issued TOPCON GROUP CSR Report

○

○ Issuing TOPCON GROUP CSR Report (Continued)

○ Issuing group media of CSR (CSR INFO-LINK) (Continued) ○ Continued publications ○ Issuing group media of CSR (CSR INFO-LINK) (Continued)

○ Participating in the GC-JN working group (CSR Report, etc.) ○ Participated in the GC-JN working group CSR Report, in-house GC awareness-raising working group, etc. ○ Participating in the GC-JN working group (CSR Report, etc.)

○ Posting corporate information on the website in a timely fashion ○ Posted corporate information in a timely fashion ○ Posting corporate information on the website in a timely fashion

○ Social contribution activities in collaboration with NPOs ○ Cooperated with NPOs specialized in social contributions and labor issues. ○ Social contribution activities in collaboration with NPOs

※ Legend in the "Self-Assessment" column:○ 100% met△ Partly not met, or there is room for improvement.

The TOPCON CSR Committee reviews year-by-year achievements regarding our CSR activities, and sets goals and plans for

the next year. In 2010, TOPCON carried out a wide range of activities, including a formulation of the Corporate Governance

Principles and the “TOPCON WAY”, a review of the business continuity plan (BCP), health promotion for employees and so

on. The CSR Report 2011 contains the results of self-assessment for our CSR activities.

■ The summary table shown at left gives a snapshot of the CSR activi-

ties we carried out in 2010, and the goals and plans for 2011 in line

with the seven principles of the “TOPCON WAY”. Last year, we not

only sought to achieve the initial goals, but also laid the foundation for

the future, re-clarifying the values that underpin the core principles of

the TOPCON Group.

■ Central to our values are the Corporate Governance Principles and

the “TOPCON WAY”. The process of repeated discussions was valu-

able in it-self, but even more important, I believe, is to make them

work brilliantly so that they will not wear thin with time.

■ In the wake of the earthquake that hit Japan on March 11, our Busi-

ness Continuity Plan (BCP) was really put to test. Since BCP is a cy-

clic method that calls for continual improvement; the 2010 CSR plan

included "re-viewing the BCP and holding BCP training." It can not be

denied, however, that there was a great gap between a plan based on

assumptions and what-ifs, and the reality of crisis. Although the basic

policy is invariable, we will review our BCP preparations in light of the

lessons learned from the disaster.

■ When it comes to risk-compliance, we have created a reference book-

let that discusses TOPCON Code of Business Conduct. It contains a

description of the code, as well as the latest information and policies

and measures. Additionally, we have improved the content of the Risk-

Compliance bulletin board that is designed to share our compliance

scores and up-to-date information. This bulletin board is a database

that organizes key information on risk-compliance and is regarded as

a tool for leaping further ahead.

■ We have included the "Self-Assessment" column for the first time.

Since there are many agendas that can only be scored qualitatively,

there is much room for improvement in terms of objectivity and valid-

ity. The more difficult quantitative scoring, the more important it is to

hold a discussion as to the assessment criteria; I believe this discus-

sion itself is conducive to spurring CSR management.

■ In conclusion, I'd appreciate it if you'd give us frank opinions and

suggestions about our CSR management from the readers of this CSR

report.


Civil Engi

neering and Construction ICT

Civil Engi

neering and Construction ICT

3D Measurement3D Measurement

Precision AgriculturePr

ecision Agriculture

Mobile MappingMobile Mapping

Land Sur

veying and Civil Engineering

Land Sur

veying and Civil Engineering

TOPCON Products That Contribute to the Development of Social Infrastructure

Sp

ecia

l Fea

ture

TOPC

ON

TOPCON has cultivated unique optical technologies over decades since its establishment. The Positioning Business Unit combines them with state-of-the-art GPS, laser and image analysis technologies to lead the world in various fields such as surveying, Construction ICT, precision agriculture and mobile control.

The products of the Positioning Business Unit play important roles in the building, maintenance and management of social infrastructure shown in the illustration such as roads, railways, rivers and ports that support our daily lives.TOPCON is determined to make a multi-faceted contribution to the reconstruction of the earthquake-affected areas through infrastructure development.

Land Surveying and Civil EngineeringContributing to the Reconstruction Using High-Accuracy and

Labor-Saving Survey Technology

The huge earthquake moved the Japanese land by as much as a few meters. Thus, land

surveying is of fundamental importance for the reconstruction of the affected areas.

Surveying instruments have evolved tremendously thanks to the development of

science and technology. Today, GPS surveying instruments are commonly used.

TOPCON’s GNSS receivers* provide hybrid satellite positioning capabilities that

can use both U.S. GPS and Russian GLONASS signals. Due to the incredibly high

precision, the GNSS receivers are highly valued both in Japan and abroad.

Additionally, the latest robotic total stations utilize a new tracking engine with an

enhanced stability. They eliminate the need for an assistant staff member and al-

low the operator to work alone efficiently and with high accuracy.

* Global Navigation Satellite Systems

Civil Engineering and Construction ICTContributing to Fast Recovery Thanks to Reduced Work Processes

Construction ICT is a technology that streamlines construction projects by utiliz-

ing IT technology to process various data.

The core of Construction ICT is a machine control system that consists of a heavy

construction machine coupled with a suite of sensors. It allows the operator to con-

trol the height and angle of the machine blade according to design data.

Use of 3D digital data collected by surveying greatly improves construction ac-

curacy even when a machine is running at high speed. An inertial sensor enables

high-speed precision guidance and automated control. These lead to a significant

reduction of a construction period.

Additionally, a combination of Construction ICT and GNSS positioning provides

extremely accurate control even when a machine is moving at high speed. This

makes it possible to achieve smooth civil engineering finish. Quick construction and

reduced iterations help to improve the productivity, cut fuel bills and reduce CO2

emissions.

3D MeasurementContributing to an Investigation of the Affected Areas and the

Creation of Reconstruction Simulation Data

3D measurement services are expanding year by year, being driven by the needs

for the maintenance and management of buildings and other structures. Laser

scanners are primarily used for 3D measurement to render high-density details

without contact.

Applications of laser scanners include: road maintenance and repair planning; de-

bris volume calculation; landfill volume measurement; maintenance management

of large structures such as bridges and steel towers, etc. Laser scanners are well

suited to investigate the quake-affected areas and create reconstruction simula-

tion data. Also, imaging stations IS, which consist of a total station coupled with

digital cameras and a simple scanner, allows surface data collection as well as

point data collection.

Mobile MappingUseful for Simulating Urban Reconstruction

Digital mapping is now a component of information infrastructure essential for

everyday life. Geographical information systems (GIS) stack various location data

tailored for specific needs onto digital maps. These tools are becoming increasingly

and widely used to develop and maintain national land; enhance governmental ac-

tivities; improve the convenience of everyday life; create new services and so on.

By driving a car mounted with TOPCON's mobile mapping system, accurate

geospatial information on roadway and roadside features can be collected. At the

same time, a digital camera can be added to capture 360-degree spherical im-

ages synchronized with geological locations. The captured images and 3D point

metadata can be processed to assess, identify and extract various objects on and

around roadways. TOPCON's mobile mapping system provides 3D geospatial

information efficiently and at low costs.

For the post-quake reconstruction, the mobile mapping system provides pre-

disaster 3D geological location data and images and creates simulation data for

post-disaster urban planning. It will play more important role for a quick recovery.

Precision AgricultureEnvironmentally Friendly Agriculture Using GPS Technology

Recently, there is a worry about a major food crisis as the per-capita crop acreage is on

the decrease as a result of world population growth. As high-efficient production systems

are required for agriculture, precision agriculture that combines GPS positional informa-

tion and IT technology is becoming increasingly popular especially in US and Europe.

TOPCON has leveraged the technologies used in control systems for construction heavy

machines, which combine the core GPS technology with control technology, to develop

an integrated agricultural system that can be utilized for the entire cycle of planning, plant-

ing, growing and harvesting.

TOPCON's precision agriculture systems keep track of the kinds and amounts of the

sprayed chemicals. This helps to ensure the food safety.

The combination of auto steering and variable spraying systems helps to save fertilizers

and fuels, leading to cost reductions. This is also environmentally friendly since it reduces

the amounts of agrochemicals used and CO2 emissions.

SpecialFeature


Holding events for CSR Month

Since 2009, we have set June as the "Environment Month" and carried

out various awareness-raising programs.

In 2010, we held a monthly event to offer an opportunity to "think about

CSR management and the relationships with stakeholders."

Main Events

● Communicated a message about the "CSR Month" and the event schedule

the group companies by publishing CSR INFO-LINK.

● Revised the Basic Regulations on Environ-

mental Preservation.

Added clauses on biodiversity preservation.

● Held a global environment conference.

● Held CSR and environment educations.

● Published CSR Report.

Distributed the Japanese version of the

CSR Report to all employees.

● Donated old books, involving all employees.

As an event of the CSR Month, TOPCON

held a social action program in which all

employees can participate.

We collected old books from employees and donated them to a nonprofit

organization (NPO) called SHAPLA NEER, which is working in Asia. We

made a donation of 1,236 books to its “Sutenai Books-The sole of second-

hand book” program, which amounted to 23,528 yen in value.

● Adopted a business-casual dress code throughout the year (to work in

more comfortable attire and lift up an uninhibited corporate culture).

● Formation of the Regulation on Prevention of Bribery of Domestic

and Foreign Public Officials, etc.

This regulation bans both management and employees from improperly

offering financial or other advantage to civil servants or public officers

in whichever country or region in order to maintain a fair competitive

order. It is related to Principle 10, Anti-Corruption, of the UN Global

Compact.

● Formulation of the Basic Regulation on Public Relations Management

This regulation obliges both management and employees to reject any

demands from, and bans them from having any relationships with anti-

social forces or organizations that might pose a threat to the order and

safety of civil society.

● Holding Risk-Compliance Educations

The TOPCON Group holds risk-compliance seminars for employees re-

garding TOPCON Code of Business Conduct, human rights, harassment,

safety and health, environment, export control, information security and

so on.

The TOPCON Group has held these seminars for managers since 2008

and held them for 22 new managers in 2010. We will continue to hold

risk-compliance seminars for those in managerial positions.

● Establishing of a Decision-Making Scheme

To further improvement of the risk management quality, we have drawn

up the guidelines for descriptions in proposal forms so that appropriate

information will be supplied to decision-making board meetings and in

request form of approval.

● Improving the Content of the Risk-Compliance Bulletin Board of the

In-House Database

We reviewed and improved the content of the Risk-Compliance Bulletin

Board, which is designed as an information-sharing vehicle for the

TOPCON Group. It poses information about corporate governance, risk

countermeasures, CSR and so on. We have been trying to keep it up-to-

date.

The Great East Japan Earthquake that hit Japan on March 11 measured Inten-sity 5 Upper in Tokyo on the Japanese scale and shook the TOPCON's head-quarters building. Although a few ceiling panels fell down, the building was not damaged structurally.We were reviewing the 2010 Business Continuity Plan (BCP), but in light of the repercussions of the earthquake on social infrastructure such as water, elec-tricity and gas as well as supply chains, the earthquake brought some issues to light that need to be addressed.Specifically, it is necessary to fix shelves and cabinets so that they will not fall down; establish a means of two-way communications with employees; improve preparedness for those who would have difficulty returning home; secure accommodations for the mission-critical crew; build IT network infra-structure; and review supply chains. It is also necessary to share a new revision of the BCP across the company, make careful prior prep-arations and break the BCP into detailed plans.These ef for ts will be continued in 2011 to get a clear picture of what would happen if an inland quake hit Tokyo and what we would be able to do in practice to deal with possible situations.

Whistleblower hot-lineTOPCON established Whistleblower hot-line in 2006 to collect information and take action to resolve issues regarding risk-compliance (information of prohibited actions under laws and/or TOPCON Code of Business Conduct, or actions which breaks socially accepted idea, or information of suspicions of these actions).This system allows employees, etc. to report risk-compliance information directly to Division in charge(Corporate Audit Div.), bypassing the normal office organization so that any misconduct or corruption will be found and addressed early. One case was reported in 2010 using this system. TOPCON will continually inform its employees of the presence and significance of this system so as to further improve compliance management.

Internal Auditing of TOPCON GROUPIn order to regularly monitor the internal control status of the group compa-nies, 35 companies in and outside of Japan have been audited in 2010 using a checklist for self-assessment on the internal control system.We reviewed the range of items on the checklist, based on the results of the previous year in order to determine more accurately whether internal controls are being conducted properly. As a result, the overall score for the establish-ment of internal controls was 88%, four points up from fiscal 2009. TOPCON provided guidance to the group companies that needed an improve-ment on specific items to have them further address the issues of internal controls. TOPCON will continue monitoring to enhance the internal control environment across the TOPCON Group.

Here is a report about CSR activities that TOPCON Group has carried out.

CSR Management ReportTopcon will maintain a proactive and responsive attitude by foreseeing any changes and place the utmost priority on compliance under all circumstances, thereby continually striving to be a trustworthy partner to all stakeholders.

Philanthropy with unnecessary books

Addressing

Risk-Compliance issue

TOPCON CSR INFO∙LINKJune 2010 issue

○Defi nition of Corporate Governance

TOPCON's definition of "corporate governance" is a corporate system in which 1) the board of directors selected by shareholders decides on the matters stipulated in the basic management policy, laws and institutions, as well as on other matters of importance regarding management; 2) the board of directors supervises the business practices that executives perform using management resources; and 3) the board of auditors supervises and monitors these corporate business practices. At TOPCON, "corporate governance" is viewed as a framework designed to let the company exhibit its best performance whilst keeping the corporate system and order.

○Basic Ideas on Corporate Governance

1) The directors and auditors take responsibility for corporate governance practices of TOPCON. All stakeholders are involved in corporate governance, including sharehold-ers, customers, business partners and employees.2) TOPCON continually improves its corporate governance; observes corporate eth-ics and acts with integrity; endeavors to increase corporate value incessantly; and enhance the soundness and transparency of management.

○Missions of the Company Organizations (Omitted)

○Relationships with Stakeholders

1) In order to offer highly reliable products to help customers expand their business, TOPCON makes its utmost efforts to improve quality in all phases, ranging from de-sign, development and production to sales and after-sales services.2) TOPCON respects mutual trust and partnerships with its business partners such as distributors and expands mutual business through information sharing and close cooperation.3) TOPCON thinks it important to communicate with its employees and respects their uniqueness, value, creativity and enterprising spirits to let them show their best performance. Employees, as members of the community, share the principles of exis-tence and value of TOPCON to contribute to the enhancement of its corporate value.4) As a member of international and local communities, TOPCON respects global standards with regard to human rights, environment, labor and so on and contributes to the establishment of sustainable markets.5) TOPCON discloses appropriate information to shareholders in a timely fashion to foster a trusting relationship and increase corporate value. TOPCON respects the fundamental rights of shareholders and ensures the equality of treatment of all share-holders by prohibiting any undue treatment of specific shareholders.

○Internal Corporate Governance Controls (Omitted)

○Information Disclosure (Omitted)

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Topcon will maintain a proactive and responsive attitude by foreseeing any changes and place the utmost priority on compliance under all circumstances, thereby continually striving to be a trustworthy partner to all stakeholders.

Philan

Acknowledgment from SHAPLANEER Risk-Compliance Bulletin Board

Disaster drill assuming earthquake

Addressing Corporate

Governance Issues

●Formulation of the Corporate Governance Principles

There are various views on and definitions of corporate governance.

The board of directors, auditors and executives discussed the way

corporate governance should be exercised in TOPCON for half a year to

formulate the Corporate Governance Principles. We referred to the cor-

porate governance principles of the Tokyo Stock Exchange, the Japan

Corporate Governance Forum, etc. as guiding models.

There are differences in views about who owns a company among Ja-

pan, the U.S. and Europe. With such differences taken into account, we

have concluded that a company exists for the sake of all stakeholders,

including shareholders and employees, and clarified the relationships

with many stakeholders involved. Additionally, we have reached a com-

mon view that governance responsibilities lie with the board of direc-

tors and auditors as trustees of shareholders.

http://global.topcon.com/invest/strategy/governance/(Corporate Governance)

Grappling with the Business Continuity

Plan (BCP)


Strengthening an Export Control System

Information Security and Personal Data Protection

Quality Improvement ActivitiesIn fiscal 2010, we started up a Technology/Quality innovation project to speed up development as well as to improve quality promoted quality-by-design initiatives, such as “a design review※ innovation for the devel-opment process”.On the occasion of the "51st Quality Month" in November, TOPCON set the "TOPCON Technology/Quality Month" to raise technology improve-ment and quality-first awareness and held various events such as a qual-ity forum.※ A milestone in the product development process whereby a design is evaluated for improvement by multiple people. Abbreviated as DR.

■Quality Forum

TOPCON holds quality forums twice a year. The August forum focused on preventing recurrence of problems and nipping problems in the bud. In keeping with these themes, innovation tools for the develop-ment process were introduced. Additionally, we displayed exhibit panels showing competitors' activities for quality improvement and

Activities with Business Partners■Information Security ManagementIn order to carry out information security measures effectively, all group com-panies in Japan share the same information security management system and endeavor to maintain and improve it through plan-do-check-act (PDCA) cycles.◇ TOPCON and eight group companies based in Japan held regular seminars for all their employees to raise the awareness of and compliance with informa-tion security and personal data protection. The participation rate was nearly 100%.

◇ We invited an external specialist to a lecture on information security.

◇ We held training courses on internal auditing of information security. In fis-cal 2010, seven employees of TOPCON were qualified as in-house auditors.◇ Each department of TOPCON made a self-assessment on its information security level, which was found to be improving, as shown at right.

◇ In-house auditors conducted internal audits

of the selected departments for the purpose

of maintaining and improving their levels of

information security management.

●Technical measures for infor-

mation security

TOPCON implements technical measures for information security so that utilization and pro-

tection of information can be balanced.

◇We enhanced the functionality of the antivirus software to improve the security of the PCs

used by employees.

Audit at overseas company

Quality Forum

efforts being made at TOPCON.In November, we held a quality forum for department and section managers. They gave presentations on the measures for a design review reform being implemented as part of the Technology/Quality innovation project. Additionally, JMA Consultants Inc. gave a seminar entitled "DR Basics and Practical Tips."We will promote effective design reviews to be able to offer higher-quality products.

CSR Management Report

Topcon will build relationships of mutual trust and partnership with sales agents and other business

partners, and mutually develop business through information sharing and close cooperation.

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Conducting export control auditsTo determine that export control is being carried out properly, the entire TOPCON Group is systematically audited every year.In fiscal 2010, we conducted internal audits of the sales, engi-neering and other departments and also audited 10 group com-panies in and outside Japan. Additionally, we rated the export control performance of all group companies on a 5-point scale to determine that they were not violating any law or regulation.

Holding export control educationsIn order to raise compliance awareness, TOPCON held export control educations for new employees, those in the sales and engineering departments, and those in charge of export. In fis-cal 2010, TOPCON held export control educations 13 times on department-by-department and hierarchy basis for a total of ap-proximately 200 employees.

Training export control specialistsTo improve the expertise of employees involved in export con-trol, TOPCON recommends taking "Certification exam on export control" held by the Center of Information on Security Trade Control (CISTEC). In fiscal 2010, 12 employees passed the exam; 45 employees are now qualified. We aim to increase this number to 55 by the end of fiscal 2013.

Holding export control meetingsThe Export Control Department and the related sections meet regu-larly to share information about major international affairs and export control status in the TOPCON Group. In fiscal 2010, sales, engineer-ing and other related sections held such meetings four times.

Clarifying export control procedures and assigning approval authority based on se-curity levelsTOPCON is gathering information about international affairs (for example, in Iran, North Korea and Libya) to devise procedures for proper export control. We have simplified the export procedures for countries and group companies that have a reliable export control system and we are preparing to assign approval authority, based on security levels.

Topcon will do its utmost to improve quality in all stages from development and design to manufacturing,

sales and service;supply products of the highest quality, and develop our customers’ businesses.

Topcon will do its utmost to improve quality in all stages from development and design to manufacturing,

sales and service;supply products of the highest quality, and develop our customers’ businesses.

Topcon will build relationships of mutual trust and partnership with sales agents and other business

partners, and mutually develop business through information sharing and close cooperation.

Scoring

Management organization

Categorization and handling of information

Management of confidential informationMeasures for confidential information protectionImplementation of information security measures

Access controlClarification of the purpose of use and procedures of collecting personal information

Notification to and consent of the persons providing personal information

Observance of the purpose of use

Appropriate management and safekeeping

Provision or entrustment of personal information

Response to right-to-know requests

Note: Scoring is based on in-house criteria.

Information Security

Assessment Category

Personal Data ProtectionAssessm

ent Category

●Compared with FY2009 level, Up,　 Sustaining

Number of the Departments Audited

TOPCON HQ 12 dept.

GROUP Companies 33 dept.

TOPCON GROUP Total 45 dept.

Lecture on information security

■Value Analysis, Cost Reduction and Process Improve-

ment Case Study Exhibition

TOPCON implements international procurement procedures in accordance with the principles of the UN Global Compact (regarding labor, environment and so on).

In fiscal 2010, TOPCON held a case study exhibition together with group companies in order to speed up VA*1/CD*2 and improvements of work pro-cesses for in-house processing and assembly. These have been cultivated with business partners and help to greatly save energy, reduce burdens on the environment and cut costs.

*1 Value AnalysisContinual activities systematically performed to create necessary functionality at a minimum cost by studying balances between functionality and cost. Value analysis capitalizes on both internal and external expertise with regard to:Changes to design and material specifi cationsChanges to manufacturing processesChanges to suppliers

*2 Cost Reduction

■Briefi ng on the Procurement Policy

As part of cooperation with business partners, TOPCON held a briefing session on its procurement policy for Chinese suppliers (TOPCON’s supply chain involved in machine work, plastic molding, etc.). Twenty fi rms came to the briefi ng session, in which we gave an overview of TOPCON and pre-sented information about material and component procurement.

The participants gave positive comments like “It was not a mere cost reduction negotiation. I'd like to appreciate the proposal for making con-certed efforts among TOPCON and its suppliers to reduce costs.”

http://www.topcon.co.jp/en/privacy/ (Privacy Policy)

Case Study Exhibition

Venue of Briefing

http://www.topcon.co.jp/en/material/ (International Procurement)

http://www.topcon.co.jp/en/corporate/quality/ (Quality Assurance Activities)


In April 2010, we drew up TOPCON Group's Human Resources Development Policy. Although each group company

had already had an HRD policy and plans, it declared a basic policy anew, centering on "the fostering of profes-

sionals and global human resources".

The TOPCON Group respects employees' uniqueness, value, creativity and enterprising spirits to let them show

their best performance. To this end, the TOPCON Group has been endeavoring to establish personnel and HRD

systems, cultivate an inhibited corporate culture and create a comfortable workplace environment where human

rights are respected.

●Labor Union Name : TOPCON Labor Union

Representative : Executive Chairman, Akitomo Tazawa

Established : January 29, 1946

Form : Independent in-house union

Union member information: (as of April 1, 2011)

1. Number of union members: 829(702 men and 127 women)

2. Average age: 38.1 (Men: 38.5,Women: 35.7)

3. Average length of service: 14.9 years

(Men: 15.1 years, Women: 13.5 years)

Eligibility : Regular employees at or below the deputy manager level

Form : Union shop

(All employees must join the union for an agreed period.)

Superior body: None

●Communications Between Labor Union and Company

・Labor-management gatherings ： Regularly held once a month to share information. The com-

pany reports on the business conditions and new topics, and

the labor union in turn gives its opinions or suggestions.

・Labor-management negotiations： Held regularly once a month or when requested to exchange

opinions on specific issues or for the labor union to make

representations to the company.

●Labor Union Activities After the Earthquake

Looking at the disaster of the Great East Japan Earthquake, the ex-

ecutive committee discussed what we could do to help as a labor

union and union members. Consequently, we decided to call for

donations independently, which were defi ned as the "money used

for the relief and support of the affected people or money given

for charity." We held a fund raising event from March 22 to April 6.

We asked not only union members but also company executives

and employees of the group companies for donations. A total of

940 people kindly made donations of 1,729,322 yen.

Wishing the money would be any of help, it was sent to the em-

ployees, including those of the group companies, who were them-

selves or whose up to second-degree relatives were greatly affect-

ed by the quake; to

the greatly affected

group companies;

and to the Japan Red

Cross.

Fundraising activity

Practice at Recycle CenterNew employee training

CSR Activity ReportResponsibilities to Employees

1 3

24

The TOPCON Group provides opportunities for ca-pacity building and self-realization to employees with various skills and character traits to help them exercise their qualities to the fullest, placing human resources as the most valuable assets.

The TOPCON Group fosters professionals and glob-al human resources* in a planned manner.

The TOPCON Group clearly defines desired employ-ee characteristics (behavior traits and sense of val-ues) and shares the recognition with all employees.

Each TOPCON Group company develops human re-source development systems and specific plans suitable for its own business model and scale in ac-cordance with the Human Resources Development Policy, and communicates them to all employees for implementation.

Number of Employees Who Applied for Various Job Support Systems(TOPCON Headquarter only)

Educational System

Name of system Contents of education

Contents of education New employee training; mid-carrier training; low-level manager training; new-manager training, etc.

By occupational qualifi cation Specialized training in each department, such as engineer training, sales training and skill development training

Self-development assistance Foreign languages; in-house TOEIC tests, correspondence courses; license/qualifi cation acquisition assistance, etc.

Risk-Compliance educationTOPCON Code of Business Conduct; human rights; harassment; safety and health; environment; export control; infor-

mation security, etc.

Dispatch to external organizations Next-generation leader development; overseas trainee system, etc.

Name of support system Period / Qualifi cation Y2007 Y2008 Y2009 Y2010

Childcare Leave Till the end of the month in which a child reaches the age of 2 6 10 15 13

Short-time Work Till a child fi nished the 3rd grade at elementary school 13 13 12 10

Nursing Leave 1 year 0 1 1 0

Re-Employment System Those who have retired at retirement age 22 15 18 14

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Working in Diverse Ways

While respecting the diversity of people as to their nationality, human race, religion, age, gender, value and so on, the TOPCON Group has worked on establishing and maintaining a personnel system that provides fair appre-ciation of and treatment to employees according to their abilities and per-formance. In the last few years, we have established various employment formats to support diversifying lifestyles of employees.In addition to a two-year childcare leave, we offer several leave systems to help employees to balance work and home life or fi nd a better work-life balance: a short-time work system that is available until a child fi nishes the third grade at elementary school, a child nursing leave system and so on.Additionally, we also consider it important not only to place the right people in the right jobs but also respect the eagerness and motivation of employees in order to make the best use of their creativity and profes-sional expertise. TOPCON has been striving to create a workplace that makes employees feel proud and motivated. To this end, we have set up a free agent (FA) system, a job posting system, etc.To help people with disabilities manifest their abilities, we have defined

TOPCON Group's Human Resources Development Policy

work assignments according to the degree of disability, made wheelchair-accessible ramps, paid attention to their means of commutation and so on.In fi scal 2010, 1.51% of the total workforce were people with disabilities, slightly up from 1.34% in 2009. However, it still remains lower than the statutory employment rate of disabled people (1.8%). To address this is-sue, TOPCON has laid down the following basic policy to improve recruit-ment activities and employment environments, including those of the do-mestic group companies that have not met the statutory rate. (Companies with 56 or more regular workers are legally bound.)

Topcon will implement two-way communication with employees,and will respect diverse individualities, values, and the spirit of creation and innovation, and maximize the employees’ skills.Topcon will implement two-way communication with employees,and will respect diverse individualities, values, and the spirit of creation and innovation, and maximize the employees’ skills.

http://global.topcon.com/csr/policy/policy_human.html(TOPCON Group's Human Resources Development Policy)

Basic Policy

1. Companies with 101 or more regular workers shall meet the statu-

tory employment rate of disabled people by the end of 2011.

2. Companies with less than 101 regular workers aim to meet the

statutory employment rate of disabled people by the end of 2011.


Health CareTOPCON has been grappling with health care for all employees so that they can stay healthy, happy and full of life and bring out their potential abilities at work.

● To help improve the health of employees, TOPCON picks up those with high health risks after a regular physical checkup and have them have an interview with an industrial physician to get advice on im-proving their lifestyles.This interview has shown good results as it inspired some people to receive early treatment. Also, depending on the result of a checkup, employees are removed from heavy-duty jobs or have their working hours limited not to increase their heath risk any further.

● TOPCON is taking active steps to encourage its employees to seek special health maintenance guidance (regarding metabolic syndrome) being promoted by the government.Lifestyle-related illnesses are chronic diseases that increase the risk of complications such as arterial sclerosis. Since 2010, TOPCON has conducted the so-called special health maintenance guidance in ear-nest to help its employees improve their lifestyles.To prevent health problems brought on by overwork, those who have worked more overtime hours than a certain limit are forced to have an

interview with an indus-trial physician. If it has been determined as a re-sult of the interview that working hours should be l imited for the sake of health, work supervisors are directed to give due

considerations.

● When it comes to the employees with mental health issues, the company asks the industrial physician to keep close contact with their doctors to share information.To prevent new mental cases, new managers are trained to recognize the signs of mental issues in early stages.

● Not only in-house health staff provide mental health care; there is also a system that allows employees to have mental counseling ses-sions at external organizations free of charge up to five times.Company is not concern about a counselee's name nor the contents.Since employees can take expert advice from experienced counselors, this system helps them lesson their worry or mental distress.Counseling cases: Y2009: 19 cases; Y2010: 20 cases

Health Promotion● TOPCON puts emphasis on health promotion in a daily life. We hold various events designed to help employees to have fun and get healthy at the same time, such as a "Walking Campaign," which encourages par-ticipants to walk 10,000 steps everyday for three months; a "Walk Around the Imperial Palace" event that lets employees bring their family; a "Get Slim" challenge that urges people with metabolic syndrome to go on a diet; special health maintenance guidance being promoted by the government; and vascular age measurement services carried out during lunch breaks.

Changes in Smoking Rates

CSR Activity Report

All smoking area located outdoor

"Walking Event 2010" sponsored by TOPCON and the TOPCON Health Insurance Union (at the outer garden of the Imperial Palace)

Y2008 Y2009 Y2010

Male 40% 36% 33%

Female 18% 11% 11%

Total 37% 32% 30%

Special health maintenance guidance

Salad bar at canteen

Health Corner

Seminar for non-smoking

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Four Accidents Not Accompanied by Lost

Work TimeIn 2010, there were four accidents that were not accompanied by lost work time.● Got dizzy on staircases, fell down and bruised the head, elbows and knees.● Injured the eyes due to glue.

● Injured the eyes due to leakage from a corroded pipe of a chloride cylinder.● Fell down from a stepladder and bruised the hip while trying to replace a ceil-

ing light.

TOPCON HQAverage of the Manufacturing Industry

FY2008/ More than 1,000 employee

Average of All Industries

FY2008/ More than 1,000 employee

Continuous accident-

free hours

Consecutive hours free of accidents resulting

in fatalities or absences of 1 day or longer

Total 5,400

thousand hours̶ ̶

Severity rate

(Absence of 1 day or longer)Percentage of serious accidents 0.00% 0.09% 0.09%

Frequency rate per working hours

(Absence of 1 day or longer)

Number of dead and injured per million

working hours0.00% 0.98% 1.61%

Frequency rate per 1,000 workers

(Absence of 4 day or longer)

Number of dead and injured per 1,000

workers per annum0.00% 2.5%※ 2.0%※

Number of Work-Related Accidents, Severity Rates, Frequency Rate Per Working Hours and Main Cases

※FY 2009

Measures for SmokingCigarette smoke, which contains numerous toxic chemicals, is a ma-jor cause of serious diseases. To help employees maintain and im-prove their health, the TOPCON Group drew up guidelines on work-place smoking in 2008 and has since promoted no-smoking and smoking cessation programs.TOPCON has put emphasis on these programs since they will lead to a reduction in medical expenses in the future. Here are a few activities conducted at TOPCON.

● To those who wanted to quit smoking, TOPCON offered smoking cessation medicine for free at the company clinic. They tried to give up smoking under the direction of an industrial physician. As a result, 46 people (or 4% of smokers) successfully broke free from smoking.

● When it comes to those who have no intention of quitting smoking, we exploited a number of opportunities to persuade them that smok-ing is a disease called nicotine addiction. Additionally, with the help of employees who had quit smoking, we created a smoking-awareness poster with their photos and comments to let all employees know the efforts and results of the smoking cessation program.

● TOPCON discontinued the sales of cigarettes at the shops in and removed cigarette vending machines from the company premises. TOPCON is also promoting efforts at improving smokers' manners.

●We consider that it is also important to have a healthy diet. In 2010, we endeavored to make the cafeteria menu healthier by cutting back on salt and offering a salad bar with free refills on a dish once a week to let employees eat more vegetables.

● Setting Up a Health CornerThere are a blood pressure gauge and a body fat scale. Not only em-ployees but also visitors can use them freely to check their health con-dition.


Participating in the GC

"In October 2007, the TOPCON Group joined the GC and declared that it will in-corporate the GC into its corporate activities. At the same time, the TOPCON Group established basic CSR guidelines that re-flect the spirit of the GC. And we featured the contents of the GC in our employee education textbook, get-ting the GC across in the group. "In addition, TOPCON has joined GC-JN, the local network in Japan, and is now engaged in three major activities: researching CSR reports, getting the GC across the internal organization, and taking countermeasures against global warming.

Activities of the GC-JN subcommittee

CSR report WG

The subcommittee interprets the topics to be introduced into the activity report re-quested by the GC, known as the Communication on Progress (COP). The sub-committee verifies the contents of the CSR reports produced by individual mem-ber organizations, and shares the information of good samples. These activities make it possible to share with members any new findings on the CSR and encourage the members to conduct active discussions, thereby helping them to increase their awareness of CSR. The outcome is expected to be reflected in the CSR reportDuring fiscal 2010, the GC announced new self-evaluation criteria for COP. In the process, in fact, the subcommittee gathered the opinions on the Japanese side to incorporate them into the definition and evaluation of the criteria.In-house GC awareness-raising WG

CSR Activity ReportTopcon, as a member of the global and local community, will respect global standards concerning human rights, the environment, labor standards, and anti-corruption measures, and contribute to building sustainable markets.

TOPCON GROUP Environmental Vision 2020

To fulfill its social responsibility as a corporate group that offers products to the global market, the TOPCON Group has established its position concerning this important environmental issue and is announcing its Environmental Vision 2020, as follows.

Environmental Burdens Caused by TOPCON (FY2010)The TOPCON Group will disclose the balance between energy and materials caused by our corporate activities.

1 Preventing global warming

The TOPCON Group, which regards global warming as the most important environmental issue, aims to reduce the amount of CO2 emitted by all of its Japanese sites by 25% before the end of fiscal 2020, as compared with fiscal 1990.Overseas sites will endeavor to reduce the amount of CO2 emis-sions site by site accordingly.

0.0 20.0 40.0 60.0 80.0 100.0(ton)

(FY)

0

2010

2009

500 1,000 1,500(ton)

(FY)

TOTAL 1,152

TOTAL 1,149

0

2010

2009

10,000 20,000 30,000 40,000(1,000kwh)

■TOPCON ■Domestic group companies ■ASIA ■U.S.A ■EU ■TOPCON ■Domestic group companies ■ASIA ■U.S.A ■EU■TOPCON ■Domestic group companies ■ASIA ■U.S.A ■EU

■TOPCON ■Domestic group companies ■ASIA ■U.S.A ■EU ■IPA ■1-BP ■Organic solvents ■Acid/Alkaline ■Others

(FY)

11,263 13,352

884

9,241

11,633 12,825 12,291

9242,199

2,452TOTAL39,872

TOTAL 37,192

TOTAL 20,382

TOTAL 18,453

0.0

2010

2009

100.0 200.0 300.0 400.0 600.0500.0(1,000ℓ)

(FY)

130 193 9777

117 201 69 102

13

0

2010

2009

5,000 10,000 15,000 20,000 25,000（t-CO2）

(FY)

3,787 4,586 9,979

1,348 682

1,500 651

3,927 4,827 7,548

13

2010

2009

TOTAL 85.7

TOTAL 78.8

●Energy consumptions

●Waste emissions ●Chemicals consumptions

●Fossil fuel consumption(crud oil conversion)●CO2 Emissions

TOTAL 502

TOTAL 510

36.8 14.0 27.1 6.5

1.3

33.4 12.4 25.4 6.4

1.2

54

154

67

420 370

369 508

119 157 83

Note: The calculations involve reviews mainly concerning the scope of data collected and the method of conversion. Therefore, some values for fiscal 2009 differ from the 2010 version of the CSR Report.Example: The amount of CO2 emitted by the TOPCON Group and its Japa-nese sites has been recalculated and adjusted according to the latest emission factors for individual electric power suppliers.The increase in the amount of production, for example, has caused increas-es in the amount of electricity and chemicals consumed.Regarding the increase or decrease in the environmental impact, which also includes the above data, we will check the details in the group environmen-tal auditing mentioned on page 22 and, if necessary, request the company concerned to implement improvement.

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Topcon, as a member of the global and local community, will respect global standards concerning human rights, the environment, labor standards, and anti-corruption measures, and contribute to building sustainable markets.

UNGC-related activities

What is the Global Compact of the United Nations?

In January 1999, the United Nations held a session of the World Economic Forum in Davos, Switzerland, when Kofi Annan, Secretary General of the United Nations, proposed the concept of the Global Compact (GC). In July 2000, the GC was formally inaugurated The GC requires the participating companies from around the world to support and implement the ten globally established principles spanning four fields, namely human rights, labor, the environment and anti-corruption.

The Ten Principles● HUMAN RIGHTS

Principle 1 Businesses should support and respect the protection of internationally proclaimed human rights; and

Principle 2 make sure that they are not complicit in human rights abuses.

● LABOUR Principle 3 Businesses should uphold the freedom of association and the effective recognition of

the right to collective bargaining;

Principle 4 the elimination of all forms of forced and compulsory labour;

Principle 5 the effective abolition of child labour; and

Principle 6 the elimination of discrimination in respect of employment and occupation.

● ENVIRONMENT Principle 7 Businesses are asked to support a precautionary approach to environmental challenges;

Principle 8 undertake initiatives to promote greater environmental responsibility; and

Principle 9 encourage the development and diffusion of environmentally friendly technologies.

● ANTI-CORRUPTION Principle 10 Businesses should work against corruption in all its forms, including extortion and bribery.

http://www.unglobalcompact.org/(UN Global Compact)

Materials※1 FY10 FY09Iron（kg） 2,383 3,063Copper（kg） 698 594Aluminum（kg） 2,234 2,563

EnergiesElectric (1,000kWh) 11,633 11,263Gas (1,000m3) 76 84Petroleum (kl) 33 36

Water contaminantsDrainage volume (m3) 41,380 44,978BOD (kg) 2,997 2,522SS (kg) 3,683 3,355

Water resourcePotable water (m3) 26,506 29,051Industrial water(m3) 16,246 16,701

Chemical substances※2

Amount of use (kg) 7,188 6,806

Procurement

Research,development and designing

Manufacturing

Greenhouse gas FY10 FY09CO2（t-CO2） 3,787 3,927

Chemical substances※2

Amount (kg) 2,881 2,591

Air contaminantsNOX (kg) 60 63

WasteAmount (tons) 369 420

※1：Using natural resources and raw materials as in-house processed goods※2：Expanding the target of chemical substances to cover all materials; mainly through atmospheric emissions※3：The value for fiscal 2009 has been corrected because of an error in the value disclosed in the previous report.

※3

To promote awareness of the Global Compact and CSR throughout the organi-zation, individual members of the group report the challenges they encoun-tered and how they resolved them. Through discussion, they can increase the depth of the topics covered and share the contents.The results are fed back into the organizations to which individual members belong to improve the level of their activities.Global warming

preventing WG

How companies should deal with global warming is a pressing issue. By conversing and sharing the challenges faced, in-dividual members explore solutions and incorporate them in their own resolu-tions.

After adopting the one-year tar-get of “efforts to reduce CO2 emissions over the medium and long term,” we held lec-tures that focused on the re-search papers presented by members of the conference.

CSR report WG Visiting construction site of2nd Tomei Expressway

In-house GC awareness-raising WG introducing TOPCON’s activity

2 Contribution by Products

We will promote efforts to reduce energy consumption and to conserve resourc-es to reduce the environmental impact through the product lifecycle much more.We will work with our customers to offer products, technologies, and services that help prevent global warming, that make effective use of natural resources, and that conserve biodiversity. Also, in manufacturing, we will commit to recy-cling and using effectively the waste material produced from our corporate activ-ities, including development, production and sales.

Environmental Impact of the TOPCON GROUP"Most of the environmental impact of the TOPCON Group, which owns processing plants in Japan and China, comes from CO2 emissions through the use of electricity and fossil fuels and the waste material from the production process. Because of its nature of optical instruments, much amount of organic solvents are used in machining and assembling process for washing."The following data shows the environmental impact of the emissions of the TOPCON Group’s corpo-rate activities. These figures include sales, assembly, and the activities of subsidiaries whose activities have low environmental impact.


Green Offi ce

Topcon Medical Systems, Inc.

In April 2010, Topcon Medical Systems, Inc., a member company based in the United States, relocated its offices to Oakland, New Jersey.This building incorporates the latest facilities and is expected to provide innovative solu-tions for the ophthalmic medical device sector and serve as a green office that is designed to

minimize environmental impact.Examples include the use of recycled resources, low-voltage illumination and human-sensitive sen-sors, as well as large fans in warehouse space to conserve energy.

Biodiversity Conservation

The private-sector partnership for biodiversityThe corporate activities of the TOPCON Group have no direct connec-tion with the overuse of animals and plants or the introduction of ex-otic species. However, we recognize that all environmental problems will lead to the destruction of native habitats.On June 1, 2010, we revised the environmental policy for TOPCON headquarters and TOPCON TECHNOHOUSE headquarters. As key ar-eas in conducting environmental activities, we gave top priority to consciousness to protect biodiversity as well as reducing environ-mental impact.In November 2010, we were admitted as a partner in promoting the declaration on biodiversity by the Japan Economic Federation, and we also joined the private-sector partnership for biodiversity.

Environmental Auditing of Group Members

To improve its environmental activities, the TOPCON Group conducts environmental auditing at regular intervals. The audits are conducted either on-site or based on documentation, depending on the situation.In fiscal 2010, on-site audits were conducted at four domestic companies and one overseas company. Documentation-based audits were conducted at three domestic companies and three overseas companies.Because of their nature, optical parts use a great deal of organic solvents for cleaning throughout the entire processing plant. To ensure employee safety and to prevent disasters, organic solvents must be handled with great care. We ensure that there is an appropriate level of management through the appointment of qualified personnel and through emergency countermeasures. For routine handling, however, there is also scope for improving management, and we have guidance for improvements according to the circumstances of individual companies.Sales companies also undergo audits, including legal compliance audits concerning the environmental laws for products.

The TOPCON Group is promoting activities to conserve the environment based on the “TOPCON WAY” and TOPCON Code of Business Conduct.

"Major factories of TOPCON Group have acquired ISO14001 certificate and are tackling the energy saving and reduction of wastes and chem-

ical materials. On this page, we are introducing some activities of environmental protection which they are tackling. "

Our initiatives to facilitate environmental activities include the acquisition of ISO 14001 certification and the en-

vironmental auditing of group members.

To manage the chemical substances in our products, we actively exchange information with suppliers.

ISO14001 Audit

In the TOPCON Group, five companies (four Japanese and one Chinese) whose production processes have a large environmental impact and who have acquired ISO 14001 certification are screened each year by the certification authority.

The following website presents data and other information regarding the company's environmental activities, including the efforts to understand and reduce the environmental impact.

Approval DateCertification organization

Latest audit date Type of auditCategory “A”(major)

Category “B”(minor)

Opportunity forimprovement

TOPCON andTOPCON TECHNOHOUSE

1997/9/29 JACO 2010/8/19～20 Surveillance 0 0 5

TOPCON YAMAGATA 2000/3/20 TUV 2010/07/21～23 Surveillance 0 4 4

Topcon Optical(Dongguan)Technology Ltd.(China)

2001/5/17 SGS 2010/05/10～11 Renewal 0 1 5

OPTONEXUS HQOPTONEXUS Takine Plant

2001/12/21 JQA 2010/10/19～22 Renewal 0 0 13

The private-sector partnership for biodiversity was formally inau-gurated at the 10th Conference of Participants in the Biodiversity Convention, held in Aichi Prefecture in Japan. This is an initiative by various stakeholders, including businesses willing to conduct activities that comply with the behavioral guidelines, as well as various organizations that support these businesses.

※TOPCON TECHNOHOUSE and OPTONEXUS (Takine plant) have expanded the scope of their certification.

No companies have received a category A (major) non-compliance and all companies have retained their certification. Companies that have re-ceived a category B (minor) non-compliance are implementing appropriate improvements.

CSR Activity ReportReducing the Environmental Impact

Briefing Sessions to Employees

Large fans

New office building

Topcon Optical(Dongguan) Technology Ltd’s Audit

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http://global.topcon.com/csr/add_ecp.html (Additional Information to CSR Report)

The REACH regulations, which is EU regulations concerning the management of chemical substances, has a list of hazardous chemical substances, such as car-cinogens and substances that are likely to cause reproductive toxicity. Informa-tion on the content of these substances in products must be disclosed, subject to a user request.Researching hazardous chemical substances included in products requires

following the supply chain from the man-ufacturers of components to the upstream manufacturers of materials.To address this requirement, we verify that

products are free of hazardous substances by promoting research into these substances in the plastic raw materials in cooperation with the manufacturers of plastic molds in the upstream supply chain, mainly in relation to plastic parts such as housings and casings.We also promote research using AIS (a research infor-mation sheet concerning the inclusion of chemical substances) provided by the Joint Article Manage-ment Promotion consortium (JAMP), of which we are a member.

Tier 3 suppliers (materials, surface treatment)

Tier 2 suppliers (manufacturers)

Tier 1 suppliers (trading firms)

End users

OEMs Agents and sales firms

TOPCON GROUP (assembly)TOPCON GROUP (assembly)

Tier 3 suppliers (materials, surface treatment)

Tier 2 suppliers (manufacturers)

Tier 1 suppliers (trading firms)

End users

OEMs Agents and sales firms

TOPCON GROUP (assembly)

Preliminary discussions with the manufacturers of plastic molds Supply Chains

Prevention of global warming

Energy Conservation in China（Topcon Optical(Dongguan)Technology Ltd.）

In October 2010, Topcon Optical (Dongguan) Tech-nology Ltd., which is a member of the TOPCON Group based in Guang-dong Province, China, initiated company-wide activities acting in ac-cordance with law to

promote clean production, the Chinese version of the energy conservation law. To understand the management and consumption of energy, it is striving to identify problems concerning energy use and exploring opportunities to reduce energy consumption, thereby improving economic effectiveness.

To promote the principle of saving energy, reducing consumables and reducing waste to all employees, the Chinese company prepared a training handbook and issued it to each employee. It also has installed bulletin boards carrying the "clean production" slogan throughout its factories.

Making Effi cient Use of ResourcesReusing Rare Earth ElementsCerium, a rare earth element, is the main component of an abrasive compound used in the production of glass lenses. To recycle abrasive compounds, OPTON-EXUS, a group company, conducted joint research among industry, academia and government to evaluate the element through abrasive performance testing and has confirmed its feasibility.Fiscal 2010 saw a restricted supply of rare earth elements to the extent that ceri-um oxide was no longer imported. The consumption of this element has been sig-nificantly reduced through the use of equipment for regenerating cerium oxide developed under the project.The activity started as a countermeasure against environmental problems related to the depletion of natural resources. However, the company engaged in the pol-ishing of glass lenses has found it very effective in its greatest challenge of con-tinuing business operations when faced with the discontinued supply of rare earth elements.This particular issue was covered by a local TV station and broadcast locally.

Equipment for regenerating News gathering by TV

Responding to the EU REACH RegulationsPromoting Research into Hazardous Chemical Substances through Supply Chains


CSR Activity Report

The following is part of the TOPCON Group's activities to contribute global and local communities through its

corporate activities.

Every year, SOKKIA TOPCON Co., Ltd. provides equip-ment and materials required by training facilities as cur-ricular support for university surveying courses.In fiscal 2010, we provided guidance and other support to roughly 130 students (from four disciplines at three universities) for a period of 20 days.

Work experience programs orga-nized by an NPO and consigned by government agencies

Recycling activities for local children’s groups; provision of on-site emergency drills

Regional contribution

Academic assistance

TOPCON CSR REPORT 2011 24

Ongoing Cooperation

with the Special Olympics

For many years, the TOPCON Group has cooperat-ed with the Special Olympics, targeting athletes with intellectual disabilities.To help these athletes display their full potential, we conducted Opening Eyes, an athlete health pro-gram, providing personnel, medical checkups, op-tometry equipment and spectacles.

Collaborating with

Ophthalmologic ExaminationThis year, Topcon Medical Systems, Inc., a member of the TOPCON Group in the United States, sent four teams of six volunteer employees to the OneSight Mission organized by Luxottica. The two-week camp provided free ophthalmologic exams and spectacles to underprivileged children.In May 2010, the Wills Eye Institute, a renowned ophthalmic specialist hospital in the United States, initiated Wills on Wheels, mobile eye screening centers for those unable to visit hospitals.We provided this facility the 3D OCT-2000, a three-dimensional fundus photographic device, and the EyeRoute Image Management System, an image management system, free of charge.

Acknowledgment

TOPCON Green Christmas 2010

Participating in Community Events (Employee Interviews)

At TOPCON, we often heard that events for local children are organized ev-ery year during the Christmas season.After seeing illuminated decorations in the lead-up to Christmas, we be-came interested in how they were accepted by the locals. We responded immediately when we heard that volunteers were needed for the current program.On the day of the event, we participated in the program starting with site management. We were responsible for photography during the event. We saw the many smiling faces of the children and other locals and we believe that the community was very happy with the event.

Kanegae Toshiaki(SOKKIA TOPCON Co.,Ltd)

3D OCT-2000

Contribution to the global and local community

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Mobile eye screening centers “Wills on Wheel”

OneSight Mission’s volunteers

Work experience programs for high-school and junior high-school stu-dents; plant tours organized by local industry associations

Providing Support to Facilities

for Victims of Child AbuseTopcon Positioning Systems, Inc., a member of the TOPCON Group in the United States, provides a range of support, including financial sup-port, to Open Arms Shelter, temporary residence for children who have been removed from their homes due to abusive parents or guardians.Mike Tibbit, advertising manager, also made every effort through televi-sion appearances to have these ac-tivities widely ac-cepted through news coverage.

Ophthalmic Treatment

for Earthquake-Affected AreasJim Bashant, Corporate Sales director in Topcon Medical Systems, Inc., a member of the TOPCON Group in the United States, joined the mis-sion of 20 volunteer doctors visiting Haiti’s capital, Port-au-Prince, which was damaged by earthquakes in January 2010.Of the nearly 1000 people who gathered to receive medical treatment, 400 required ophthalmologic exams.Their treatment ac-tivities gave these people a ray of hope.

Providing Warm Clothing to Low Income AreasTopcon Optical (Dongguan) Technology Ltd., a member of the TOPCON Group in China, responded to a call by the government to engage in charitable work. In November 2010, the company called on its employees to offer winter clothing and bedding. The collected proceeds were donated to low income areas.

Receipt of suppliesRelief SuppliesCollected

Image from KTHV feature story, a CBS network affiliate located in Little Rock, Arkansas.

Members of the volunteers


Joining Forces with Our StakeholdersAs it is indicated in “TOPCON WAY”, the TOPCON Group makes every effort to cultivate a relationship of trust with our stockholders and other stakeholders by disclosing appropriate and timely information in accordance with laws and regulations stipulated by the stock ex-change.

CSR Activity Report

Support for the Affected AreasFollowing the devastation of the earthquake and tsunami in eastern Ja-pan on March 11, 2011, we provided the following support. We thought that GPS and other types of survey equipment produced and marketed by our group would help in the reconstruction of the affected areas.・Donating GPS and other types of survey equipment (implemented

through government organizations)・Relief funds When this CSR Report is published at the end of May 2011, the total

support is expected to be worth 170 million yen.

We have been supporting the devastated customers at business places and medical organizations, as well as the business partners at agencies, because of the earthquakes and tsunami waves.Our support includes the following main areas:・Repairs to equipment (free other than the cost of parts)

・Free loan of equipment

・Provision of free software

・Provision of emergency supplies (from the company's stock), includ-ing emergency food supplies, drinking water and heating oil

The TOPCON Group is ready to help customers and business partners recover from the devastation as soon as possible.

Providing Support to Those Having Difficulty Going to Work and Returning Home・Taking into account the disaster-affected duty

・Providing accommodation facilities, as well as drinks and foods

・Allowing for the disruption of public transportation (such as flexible working hours and the use of alternative transport)Support for employees engaged in the reconstruction effort, as well as confirmation of the safety of family members in the affected areas・Providing special leave, compensation for return travel and fuel, consultation for routes, and surplus supplies (such as emergency drinking water)

Supporting Customers and Business Partners

Providing Support to Employees

Hoping for an Early Recovery from Disaster

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Topcon will appropriately disclose information to shareholders in a timely manner, work to build a

relationship of trust with them, and continually strive to improve our corporate value.

Topcon will appropriately disclose information to shareholders in a timely manner, work to build a

relationship of trust with them, and continually strive to improve our corporate value.

We would like to express our deepest condolenc-

es to people from the devastated regions and

hope that the affected areas will recover as soon

as possible.

Award-Winning Websites

Third-Party Opinion

Often, the concept of CSR is likened to an endless journey. This is proba-bly because the essence of CSR lies in the fact that demands from soci-ety change over time and companies are expected to consistently re-spond to the changing demands."For this reason, companies should make a constant effort to create a mechanism to promote the CSR concept and cultivate it profoundly.After joining the Global Compact in 2007, the TOPCON Group has been actively making these efforts.In addition to the “TOPCON WAY”, this report covers the process of drawing up corporate principles such as principles for corporate gover-nance, the anti-bribery regulations for Japanese and non-Japanese pub-lic service workers, the regulations for basic liaison management, and basic guidelines for the development of human resources in the TOP-CONGroup.Drawing up these things requires deep in-house discussions. Mr. Miy-awaki, chairman of the CSR Committee, was right when he made the fol-lowing comment in his general overview: “The process itself is a short-cut to accelerating CSR management.”In future, it will be necessary to define the relationships among many items (such as the “TOPCON WAY”, CSR basic guidelines, corporate gov-ernance principles, TOPCON Code of Business Conduct, Environmental Vision 2020) and the current TOPCON Vision and their roadmap to en-sure that they are fully understood and widely accepted by the group's employees.Along with creating this system, the current report also includes self-evaluation in each category.I also agree with the general overview regarding this self-assessmemt item when it says, "There is still some margin for flexibility when it comes to ensuring the objectivity and validity of assessmemt ."However, I believe that making a self-assessmemt with some margin for flexibility will enhance the PDCA circle for CSR and that the descriptions

in the report will change from the present PD-only stance to the PDCA-circle stance, creating significant opportunities for cultivating CSR.In the future, I would like you to set up quantitative targets well as Key Performance Indicators (KPIs) in each category.In line with the implementation of the “TOPCON WAY”, this report is con-structed on seven pillars.For this structure, I use the word "approach," by which I mean an ap-proach to the ideal figure. I think that following the “approach” continu-ously in the future will help you to verify the extent to which the “TOP-CON WAY” has been realized.In this meaning as well, I believe that it is essential to set KPIs.As can be seen, this report clearly identifies the departure to the "next journey." In the fiscal 2011 report, your stakeholders are watching the re-ports relating to great earthquakes in eastern Japan and the handling ISO 26000.Writing about the earthquake begins with the message from your top of-ficial and is followed by articles such as the special topic, BCP and sup-port for the reconstruction efforts.Indeed, this information is essential. However, I would like to have found an article that emerged dealing with problems in the face of the earth-quake. An example would be the supply chain, the location of production sites, measures related to energy, and the relationships with communi-ties.As the report was due out in May, you may have had insufficient time to verify the material. In this sense, I am looking forward to reading your contribution in the next issue of the report.Regarding ISO 26000, you have signed a memorandum of understanding (MOU) for cooperation with the participating GC members. Reference is also made to the GRI and ISO. I have high hopes that by referencing this international standard, you will verify your own CSR and report the result of your verification.

Tamio Yamaguchi,Representative

Specified non-profit organization Junkan Workers Club

Junkan Workers Club:This is a civic group whose main purpose is to (1) discuss from a glob-al point of view, the ideal figure of a circulation-based society, which is to have harmony with the natural ecosystem that should be handed down to our next generations, and (2) research, support, and imple-ment any efforts to form a circulation-based society by local citizens, businesses, and public administrations.

URL:http://www.nord-ise.com/junkan/

In Response to the Third-Party OpinionI believe that squarely addressing the demands of a society that

is continuously evolving and changing will be important in en-

abling the Topcon Group community to grow sustainably.

The CSR Report for fiscal 2011 is one achievement along the way.

Therefore, the opinion of Mr. Yamaguchi as a third party is a pro-

posal on behalf of the needs of society. I understand this propos-

al expresses the viewpoint required in the future.

Although different degrees of interest in the issues to be ad-

dressed, we would like to deal with them face to face and arrive

at solutions together with our stakeholders.

TOPCON CSR Committee

Hiromasa Miyawaki, Chairman

How Relief Supplies Are Being Transported

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