About NGK
NGK Group Anti-corruption Policy
The NGK Group has declared in the NGK Group Corporate Business Principles that it will strive to realize a sustainable society, respect human rights, and conduct fair and transparent business activities with integrity, and that pursuant to the NGK Group Code of Conduct it will strive for the comprehensive prevention of corruption. Corruption hinders the realization of a sustainable society and causes human rights violations, which violates the NGK Group Corporate Business Principles and the NGK Group Code of Conduct, and it cannot be tolerated.
We have established this "NGK Group Anti-corruption Policy" (this “Policy”) in order to comply with applicable laws and regulations, prohibit any direct or indirect involvement in corrupt practices, and strive to promote anti-corruption in all of our business activities, live up to our stakeholders’ trust and realize a sustainable society.
1. Compliance with Applicable Laws and Regulations
The NGK Group will comply with applicable anti-corruption laws and regulations in the countries and regions in which we conduct our business activities.
2. Prohibition of Corrupt Practices
The NGK Group will:
- Prohibit its officers and employees from conducting or engaging in corrupt practices, such as bribery, embezzlement, situations whereby there are any breaches of trust, conflicts-of-interest, insider trading, money laundering, obstructions of justice and any other abuses of their own or a third party’s authority or position for personal or organizational gain; and
- Prohibit its officers and employees from engaging in corrupt practices through any third parties, such as agents or consultants. We will implement necessary measures, such as strictly managing contracts with third parties and regularly checking transaction statuses.
3. Establishing an Anti-corruption System
The NGK Group will:
- Develop internal rules and organizational structures to raise awareness and promote this Policy;
- Assess corruption risks in the countries and regions where we conduct business, and implement risk countermeasures, focusing on high-risk business activities; and
- Establish a whistleblowing system that allows officers and employees to report any corrupt practices that they become aware of. We will maintain the confidentiality of reports, and prohibit the disadvantageous treatment of whistleblowers.
The implementation status of this Policy and related measures will be reported to NGK Insulators’ Board of Directors and reviewed as necessary.
4. Education
The NGK Group will regularly educate its officers and employees about this Policy and related actions and procedures.
5. Proper Accounting Procedures
The NGK Group will execute accurate accounting procedures in accordance with laws, regulations, and internal rules, and properly record and maintain its accounting books.
6. Records and Storage
The NGK Group will keep accurate business records and properly manage and store them.
7. Audits and Monitoring
The NGK Group will:
- Conduct internal audits of the implementation status of this Policy and promptly take corrective measures against any issues that are discovered; and
- Verify the effectiveness of internal audits and other measures and strive for continuous improvement.
8. Information Disclosure
The NGK Group will strive to disclose the status of its efforts to prevent corruption.
9. Response to Violations, etc.
The NGK Group will:
- Promptly address any actual or potential violations, make necessary corrections, and also take thorough measures to prevent any recurrences; and
- If our officers or employees violate any laws or regulations, the NGK Group Code of Conduct or our internal rules, we will take fair and strict actions in accordance with the internal rules.
10. Top Commitment
Top management will:
- Raise the awareness of this Policy within the NGK Group, allocate the necessary resources for its implementation, and maintain the system; and
- In the event of any violation of this Policy, proactively respond to the situation, including resolving the issue, investigating the causes, and working to prevent the issue from recurring.
This Policy has been signed by the President of NGK Insulators, Ltd.
President
