System / Procedure
We have established a helpline to receive inquiries and reports from employees aimed at curtailing and preventing activities contrary to the spirit of the NGK Group Code of Conduct and to facilitate the quick resolution when issues occur. Each Group company outside Japan has its own helpline.
Number of Helpline Consultation Cases (at NGK)
We have established a hotline as a whistleblowing system for responding to fraud and legal infractions committed by senior management of NGK, and competition law and anti-corruption law-related violations. The hotline is operated by outside lawyers, with issues handled by the Business Ethics Committee, composed mainly of outside directors, who report directly to the Board of Directors.
We have been pushing forward with the establishment of the hotline at Group companies outside Japan in light of the circumstances in each country. We have, however, established contact points at all Group companies outside Japan for reporting competition law and anti-corruption law-related violations.
A whistleblowing system is in place, which everyone who works for NGK and its Group companies (including executives, employees, employees temporarily assigned to outside companies, advisors, contract employees, temporary employees hired on a worker dispatch agreement, and subcontractor local employees) can utilize.
As a rule, actual names are used for consultations and reports, but outside contact points can be utilized for anonymous consultations. Those seeking advice or reporting issues are promised protection under corporate rules.
In addition, we are planning to update and improve our corporate rules and whistleblowing system to coincide with the enactment of the Revised Whistleblower Protection Act in Japan.
Organization of Whistleblowing System
For thorough awareness of the whistleblowing system, we created a carry-size Compliance Card and distributed it to all employees at NGK and all Group companies in Japan.
Observing Competition Laws and Other Laws and Regulations Pertaining to Business Transactions
In addition to mandating compliance with competition laws in the NGK Group Code of Conduct, we have established the Competition Laws Compliance Rules, set forth to comply with international standards, which are strictly enforced by the NGK Group both in Japan and its overseas locations. We have established these policies and procedures in order to eradicate unfair business practices and maintain fair and equitable business relationships with our business partners.
We also provide education and training aimed at ensuring widespread awareness and thorough compliance with the Competition Laws Compliance Rules and the Competition Laws Compliance Handbook, and we have established the Competition Laws Compliance Activities Portal Site, which contains practical instruction manuals for complying with competition laws. The Competition Laws Compliance Handbook will be revised and updated in response to changes in the social environment.
At the same time, since fiscal 2015, we have contracted PwC Advisory LLC (hereinafter, “PwC”) as our independent compliance professional. PwC is engaged to annually review the implementation status of the NGK Group’s competition law compliance program per the Competition Laws Compliance Rules as well as assessing the overall oversight and reporting structures in place for NGK Group companies, both in Japan and overseas locations. On top of this, starting in fiscal 2017, PwC has also conducted interviews with the directors overseeing NGK’s various business groups in order to: 1) assess the tone of each director’s approach toward competition law compliance; and 2) to further enhance their awareness of these efforts. The results of these reviews are being leveraged for a variety of purposes, such as operating and improving the competition law compliance program.
Anti-Competitive Behavior Incidents
In fiscal 2020, there were no confirmed incidents of anti-competitive behavior in the NGK Group.