UK Modern Slavery Act Statement for the year ended March 2021
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 2020 (which ended on March 31, 2021).
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 45 consolidated subsidiaries in 20 countries and regions (including the United Kingdom, the United States, and Australia), 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 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.
With the "NGK Group’s Supply-Chain CSR Guideline", 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
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. The NGK Group will continue to conduct this survey to enable the NGK Group to identify such risks, and to verify what approaches have been taken, and what progress has been made, to address them.
The NGK Group will start self-assessment surveys for CSR procurement to determine the supply chain member’s understanding and status.
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. As to the NGK Group’s supply chain, the NGK Group established a supplier helpline, where the NGK Group can accept reports on risks of human rights violations, including slavery.
4.Risk assessment and management
The NGK Group found no cases of forced labor, child labor, or human trafficking in the survey for fiscal year 2020, based on the above due diligence process. The NGK Group has set up an HR Committee chaired by the General Manager of the Human Resources Management Department at NGK Insulators, Ltd. The committee manages, shares, and evaluates various risks related to human rights, and establishes countermeasures, if necessary.
In fiscal year 2020, the NGK Group conducted the above-mentioned risk assessment with NGK Insulators and 17 domestic group companies using the self-assessment questionnaire based on the RBA Code of Conduct. The NGK Group will gradually expand the scope of the risk assessment to the overseas group companies. The NGK Group will continue to conduct the above-mentioned risk assessment every year to determine if the performance indicators have been achieved.
The NGK Group will implement a risk assessment of its supply chain using the Global Compact Network Japan (GCNJ) self-assessment questionnaire, in addition to the current activities to spread the understanding of CSR procurement through site visits.
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 fiscal year 2021 and thereafter.
The NGK Group issues notifications, distributes guidebooks, posts posters, and conducts on-site education regarding the “NGK Group Code of Conduct”. In addition, the NGK Group plans to implement e-learning for "NGK Group Human Rights Policy".
Regarding its supply chain, the NGK Group requests its business partners annually to submit an agreement to comply with the above-mentioned " NGK Group’s Supply-Chain CSR Guideline".
This statement was approved by ;
(i) the Board of Directors of NGK Insulators, Ltd. on November 22, 2021
(ii)all the directors of NGK Europe GmbH on November 22, 2021
NGK Insulators, Ltd.
NGK Europe GmbH