About NGK

UK Modern Slavery Act Statement for the year ended March 2022

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, 2022.

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 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.

About NGK

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.

NGK Group Code of Conduct

NGK Group Human Rights Policy

NGK Group’s Supply-Chain CSR Guideline

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, 2022, based on the above due diligence process, in addition to 17 domestic group companies (including NGK Insulators) of the previous year, the NGK Group also conducted surveys using a self-assessment questionnaire in 23 overseas group companies to confirm the existence and level of risk.

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, 2022, thorough the above surveys and whistleblowing systems.

The NGK Group started implementation of a risk assessment of its supply chain using the Global Compact Network Japan (GCNJ) self-assessment questionnaire for CSR procurement to determine the supply chain member’s (about 700 suppliers of NGK Insulators) understanding and status, from the fiscal year ending March 31, 2022. 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, 2022, thorough the above surveys and whistleblowing systems.

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 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, 2022 and thereafter.

6.Educations

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", modern slavery, and human trafficking.

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 August 22, 2022

(ii)all the directors of NGK Europe GmbH on August 22, 2022

NGK Insulators, Ltd.
President
Signature of Shigeru kobayashi, President, NGK Insulators, Ltd.

NGK Europe GmbH
Managing Director
Signature of Ryugo Takeda, Managing Director, NGK Europe GmbH

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