Sustainability
Compliance
Promoting Compliance Education
Compliance Education for Employees
Compliance training and awareness among corporate officers and employees is driven primarily by the Group Compliance Department and the Legal Department. In addition to career training and training for employees to be posted overseas, we provide Laws and Compliance Seminars to explain laws and regulations and to introduce case studies.
Since fiscal 2018, we have included quality compliance and contract observance as part of our career education courses.
Compliance Education Conducted in Fiscal 2019 (Overall)
| Name | Target | Content | Number of sessions |
|---|---|---|---|
| Career education | New hires | Compliance basics, competition laws, anti-bribery regulations | 2 |
| Promoted or career-changed employees | Compliance basics | 3 | |
| Mid-career hires | Compliance basics, competition laws, anti-bribery regulations | 1 | |
| Newly appointed supervisors | General compliance, competition laws, anti-bribery regulations, quality compliance, contract observance, security export control | 1 | |
| Newly appointed managers | General compliance, competition laws, anti-bribery regulations, quality compliance, contract observance, security export control | 1 | |
| Managers promoted second grade | Compliance (including quality compliance) | 1 | |
| Training for employees scheduled for postings abroad (global training) | Employees scheduled for postings abroad | Competition laws, anti-bribery regulations, security export control | 2 |
| Compliance education | Managers and sales staff of Group companies outside Japan | Lectures provided by attorneys and paper materials-based in-house training | 22 |
| General employees of NGK and Group companies in Japan | Compliance, harassment prevention, whistleblowing system | 31 | |
| Laws and compliance seminars | Managers and other targets depending on content | Corporate structure, centered on the General Meeting of Shareholders and Board of Directors Internal lecturer; 409 participants in total Suspicious email awareness training results Outside lecturer; 582 participants in total Latest trends in insider trading regulations Internal lecturer; 497 participants in total Adapting to the amended Civil Code Internal lecturer; 331 participants in total International trends in anti-corruption practices Outside lecturer; 536 participants in total |
5 |
| Other training | All directors and managers, and others connected to training content | Quality compliance seminar Outside attorney, internal lecturer |
2 |
| Divisions and Group companies in Japan | Subcontract Act explanatory meeting | 3 | |
| Training to support new presidents of Group companies in Japan | Compliance, harassment prevention, whistleblowing system, etc. | 1 |
Competition Law Education Conducted in Fiscal 2019
| Name | Target | Content | Number of sessions |
|---|---|---|---|
| Training for newly appointed directors | Newly appointed directors and executive officers | Outside attorney-led seminar | 1 |
| Competition law compliance lectures | All directors and managers, and sales staff of NGK and its Group companies in Japan | Streamed video of outside attorney-led seminar | 1 |
| Compliance training for Group companies outside Japan | Managers and sales staff of Group companies outside Japan | Attorney-led, live seminar; seminar conducted via video conferencing; conducted by an internal lecturer; conducted using paper-based resources | 22 |
| On-demand training on competition laws by internal lecturer | Targets depending on content | On-demand training upon divisions' request | 1 |
Anti-Bribery Training Conducted in Fiscal 2019
| Name | Target | Content | Number of sessions |
|---|---|---|---|
| Training for sales staff | Sales staff in Japan Heads of Group companies outside Japan (some) |
Outside attorney-led seminar; small-group case study discussion | 5 |
| Training on anti-bribery regulations for Group companies outside Japan | Managers and sales staff at Group companies outside Japan | Attorney-led, live seminar; seminar conducted via video conferencing; conducted by an internal lecturer; conducted using paper-based resources | 22 |
Other Dissemination Activities
Compliance Newsletter
Note: Provided by “Compro Custom” compliance training tools service
We post the Compliance Newsletter on the company's intranet once a month. The Newsletter features a four-frame cartoon that explores familiar themes followed by detailed explanations of what we can learn from these examples.
In fiscal 2017, we began making October the annual compliance strengthening month, during which we do things such as put up educational posters and through employees of whistleblowing system.
Themes Covered in the Compliance Newsletter in FY2019
| April | Being a good citizen | |
|---|---|---|
| May | Human rights | |
| June | Reliably executing agreements with customers | |
| July | Sexual harassment | |
| August | Unlawful conduct | |
| September | Preventing falling accidents | |
| October | Corporate ethics month | |
|---|---|---|
| November | Harassment | |
| December | Human rights week | |
| January | Contract compliance | |
| February | Compliance first | |
| March | Unpaid overtime | |
Compliance Awareness Surveys
We conduct a compliance awareness and business risk-related Corporate Risk Survey (CRS)* within the NGK Group once every two years.
The compliance awareness-related portion of the CRS conducted in October 2019 focused on the degree and scope of awareness among Group personnel, whether they were aware of compliance violations, and what the atmosphere in their workplace was like. There was an increase in the number of responses indicative of compliance awareness among divisions compared with the previous CRS conducted in 2017. Among those responses stating that a compliance violation had occurred or was suspected, harassment was the violation most commonly given. Also, 70% of respondents stated that their workplace atmosphere was conducive or mostly conducive to openly exposing violations.
Based on the responses we have received, we will continue to work towards greater and more widespread compliance awareness, violation prevention, and improvement in workplace atmosphere.
- CRS target respondents
1) Compliance awareness survey – Japan: All directors and employees (including temporary employees) / Overseas: Employees dispatched overseas
2) Business risks – Japan: Group S* and higher *Assistant manager and supervisor class