About NGK
UK Modern Slavery Act Statement for the year ended March 2025
This statement (“Statement”) is made pursuant to Section 54 (Part 6) of the Modern Slavery Act 2015 of the United Kingdom to describe the policies and efforts of NGK Insulators, Ltd and its affiliated companies (hereinafter, the” NGK Group”) to prevent the occurrence of modern slavery and human trafficking for the fiscal year ending March 31, 2025.
Among the entities in the NGK Group, NGK Insulators, Ltd. and NGK Europe GmbH are subject to the reporting obligations under the Modern Slavery Act 2015 (United Kingdom); NGK Insulators, Ltd, as the parent company of these reporting entities, discloses this Statement as a joint statement to cover both entities.
1.Organization and supply chains
NGK Group engages mainly in the supply and development of products that support social infrastructure and contribute to environmental conservation, such as ceramic parts for automobiles, insulator products for electric power, electronic parts, and industrial equipment and devices with ceramic technology as its core technology.
The NGK Group is headquartered in Aichi Prefecture, Japan, and has 46 consolidated subsidiaries in 19 countries and regions (including the United Kingdom and the United States), doing business with about 20,000 employees.
In addition, materials and parts of NGK Group products are procured from procurement partners inside and outside the NGK Group around the world.
Please refer to the following URL for details on these companies and businesses.
2.Policies to prevent occurrence of modern slavery and human trafficking
NGK Group has established the "NGK Group Corporate Business Principles and Code of Conduct" and the "NGK Group Human Rights Policy", which stipulate the attitudes and matters to be respected in conducting business activities. The code and policy, with the approval of the Board of Directors, declare that the NGK Group excludes forced labor, child labor, human trafficking, and all other acts that lead to human rights violations.
In addition, regarding to the supply chain, we have established “NGK Group Supplier Code of Conduct”, which specifically defines the code of conduct for suppliers based on the NGK Group's various policies, guidelines, and codes of conduct. With the “NGK Group Supplier Code of Conduct”, the NGK Group requests its supply chain to understand and support the avoidance of the use of conflict minerals that can cause human rights violations and poverty, and the prohibition of forced labor and child labor. The NGK Group and its entire supply chain have made a clear commitment to prevent the occurrence of modern slavery and human trafficking.
3.Due diligence process
4.Risk assessment and management
5.Performance indicators
The NGK Group conducts surveys using a self-assessment questionnaire with reference to the RBA Code of Conduct. The assessment includes many aspects that are related to human rights, such as “identifying forced labor, child labor, and human trafficking," "working hours, wages, and welfare," "occupational safety and health," and "responsible mineral procurement." Through this survey, the NGK Group looks for, and could gather details on, any human rights risks in its business operations.
In the fiscal year ending March 31, 2025, based on the above due diligence process, we conducted surveys using a self-assessment questionnaire in NGK and its 37 Japan domestic and overseas group companies to confirm the existence and level of risks.
Additionally, the NGK Group has been establishing whistleblowing systems effective to apply in accordance with circumstances of country or region where each group company locates, such as reporting mechanism available to all employees at respective group companies.
The NGK Group found no cases of forced labor, child labor, or human trafficking in the survey for the fiscal year ending March 31, 2025, thorough the above surveys and whistleblowing systems.
In terms of supply chains, we regularly request our major suppliers, including new ones, to agree to comply with “NGK Group’s Supplier Code of Conduct”. We are currently preparing to conduct a self-assessment survey in accordance with this Code of Conduct. The NGK Group also operates a supplier helpline, where the NGK Group can accept reports on risks of human rights violations, including slavery.
The NGK Group found no cases of forced labor, child labor, or human trafficking in the survey for the fiscal year ending March 31, 2025, thorough the above surveys and whistleblowing systems.
In accordance with the UN Guiding Principles, the NGK Group has identified human rights issues related to its business activities. In accordance with the approach outlined in the OECD Due Diligence Guidance for Responsible Business Conduct (RBC), we assessed the significance of these issues based on two axes—severity and likelihood. Through stakeholder consultations and reporting to the Human Rights Committee, we identified priority human rights issues that require focused action. The NGK Group is taking proactive measures to prevent and remediate these issues, and we continuously review these priorities in light of changes in the business environment and feedback from stakeholders.
The NGK Group has set up an HR Committee chaired by the Director in charge of the Human Resources Management Department at NGK Insulators, Ltd. The committee manages, shares, and evaluates various human rights risks collected based on the due diligence process, and establishes countermeasures, if necessary.
The NGK Group will continuously improve the effectiveness of the survey by enhancing the assessment scope and contents to find and establish a fair performance indicator for the fiscal year ending March 31, 2026, and thereafter.
6.Educations
The NGK Group publishes a guidebook on its website that outlines specific actions and attitudes based on the “NGK Group Corporate Business Principles” and “NGK Group Code of Conduct”, and issues notifications, distributes guidebooks, posts posters, and conducts on-site education. In addition, in the fiscal year ending March 31, 2025, the NGK Group conducted e-learning based on the theme “2. Respect for Human Rights” from the “NGK Group Code of Conduct”.
Regarding its supply chain, the NGK Group requests its business partners to comply with the "NGK Group’s Supply-Chain Code of Conduct" and to regularly submit written consent.
This statement was approved by ;
(i) the Board of Directors of NGK Insulators, Ltd. on August 25, 2025
(ii) all the directors of NGK Europe GmbH on August 25, 2025
NGK Insulators, Ltd.
President
NGK Europe GmbH
Managing Director