Sustainability
Compliance Initiatives
Compliance with Competition Laws
Observing Competition Laws on an International Level
In addition to mandating compliance with competition laws in the NGK Group Corporate Business Principles, we have established the Competition Laws Compliance Rules, set forth to comply with international standards. These standards are strictly enforced by the NGK Group. 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. The Competition Laws Compliance Activity website we established posts practical manuals to guide compliance with competition laws. The Competition Laws Compliance Handbook was revised in FY2021 to accommodate changes in social conditions.
Strengthening Our Compliance System in Relation to Competition Laws
Year conducted | Regulation development | Creation of internal systems | Education |
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FY1997 |
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FY2011 |
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FY2012 |
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FY2013 |
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FY2014 |
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FY2015 |
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FY2016 |
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FY2017 |
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FY2018 |
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FY2019 |
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FY2020 |
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FY2021 |
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FY2022 |
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These items continue every year
Third-party Review of Competition Law Compliance Program
Since FY2015, NGK has contracted PwC Advisory LLC (PwC) as a compliance specialist to review the operation of our competition law compliance program based on the Competition Law Compliance Rules, as well as NGK Group's unified supervision and reporting system for domestic and international group companies, from an objective point of view. Since FY2017, PwC has been conducting interviews with executives of our business groups in order to assess their attitude toward compliance with competition laws, and to further raise their awareness of such compliance efforts. The results of these reviews are used to operate and improve our competition law compliance program.
Instances of Anticompetitive Behavior
In FY2022, no instances of anticompetitive behavior were observed within the NGK Group.
Instances of Anticompetitive Behavior
Import/Export Transaction Management
Strict Adherence to Laws and Regulations Relating to Import/Export Management
As part of its full compliance efforts, NGK is engaged in strictly observing and enforcing laws and regulations related to import and export control. Based on the NGK Group Corporate Business Principles, we stipulate abidance with laws and regulations related to secure export control, and we carry out export control and employee training in accordance with internal rules and the Export/Import Handbook.
Using Databases to Conduct Comprehensive Inspections and Customs Management
In response to the Foreign Exchange and Foreign Trade Act and other export control-related laws and regulations, NGK has screened exports to determine whether export licenses are required and has recorded screening results in a security export control database. However, since October 2017, we have moved to a security export control system (TTP) and are performing management via this new system. Furthermore, export management with respect to the export of certain products is conducted under the Japanese government’s AEO (authorized economic operator) Program.
We have used an export/import cargo management ledger to fulfill our obligations to track and record imports and exports; however, since our switch to a security export control system (TTP), we have been using the system’s shipment ledger to track and record exports. We continue to use an import cargo control ledger for imports. Each department performs voluntary inspections of imports and exports under the AEO Program at the start of the fiscal year.
In addition, we use NACCS data (Nippon Automated Cargo and Port Consolidated System) to verify the completeness of import cargo management ledgers and shipment ledgers. We have achieved nearly 100% completeness for both imports and exports.
Familiarization with the Export/Import Handbook
NGK also makes efforts toward thorough compliance with the Export/Import Handbook, in use since FY2021 and revised in FY2022, that summarizes items for the observance of export/import customs clearance regulations.
In addition to publishing this handbook on the company intranet where it can be viewed throughout the entire company, we provide training to spread awareness of the content of the handbook through study meetings related to export/import management conducted in each department.
Study meetings on the AEO Program and export/import management are held one or more times per year targeting relevant staff in departments responsible for export and import activities. In FY2022 these meetings were held not only in-person, but via web conferencing and newsletters. The meetings were held a total of 32 times, with 518 employees in attendance.
Anti-Harassment Measures
We conduct annual position-based training as part of our measures to combat harassment in the workplace. In FY2022, based on the responses to our compliance awareness survey conducted in FY2021, we also began training on harassment from a position of power, which targeted executives at Group companies in Japan, and employed a group discussion format utilizing specific case studies (178 participants at 6 locations from 3 companies). In addition, we created self-study materials based on recordings of this training which require trainees to identify what points constitute harassment from a position of power, and distributed these within NGK (341 participants). We continue working to prevent harassment before it occurs and improve the workplace environment by providing more effective training content.
Number of Position-based Anti-Harassment Training Sessions
Number of participants in position-based harassment training
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 FY2018, we have included quality compliance and contract observance as part of our career education courses.
Compliance Education Conducted in FY2022 (Overall)
Name | Target | Content | Instruction Format | Number of sessions |
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Career education | New hires | Compliance basics, competition laws, anti-bribery regulations for dealing with foreign officials | Training by an in-house instructor | 1 |
Promoted or career-change employees | Compliance basics | Video presentation | 1 | |
Mid-career hires | Compliance basics, competition laws, anti-bribery regulations for dealing with foreign officials | Video presentation | 1 | |
Newly appointed supervisors | General compliance, competition laws, anti-bribery regulations, quality compliance, contract observance, security export control | Video presentation | 1 | |
Newly appointed managers | General compliance, competition laws, anti-bribery regulations, quality compliance, contract observance, security export control | Video presentation | 1 | |
Managers promoted to second grade | Compliance (including quality compliance) | Video presentation | 1 | |
Training for employees scheduled for postings abroad (global training) | Employees scheduled for postings abroad | Competition laws, anti-bribery regulations, security export control | Video presentation | 1 |
Compliance education | Managers and sales staff of Group companies outside Japan | Compliance basics, competition laws, anti-bribery regulations for dealing with foreign officials | Lectures provided by lawyers and paper materials-based in-house training | 19 (24 sites) |
General employees of NGK and Group companies in Japan | Compliance, harassment prevention, whistleblowing system | Video presentation | 1 | |
Sales staff of NGK and Group companies in and outside Japan | Anti-bribery regulations for dealing with foreign public officials | Lawyer-led seminar | 4 | |
Executive officers | Competition laws | Lawyer-led seminar | 2 | |
Newly appointed executive officers | Companies Act and competition laws | Lawyer-led seminar | 1 | |
Managers and sales staff of NGK and Group companies in Japan | Competition laws | Video presentation | 1 | |
Executive officers and general managers | Oral training on competition law | Seminar by executive officer or General Manager of Group Compliance Department | 4 | |
Laws and Compliance Seminars | Managers and other targets depending on content | May Export controls for technical information | Video presentation (in-house instructor) | 1 |
July Electronic contracts | Video presentation (in-house instructor) | 1 | ||
September Latest trends in insider trading regulations | Video presentation (in-house instructor) | 1 | ||
November Latest trends in anti-bribery regulations | Video presentation (outside lawyer) | 1 | ||
January Handling revisions to the Electronic Books Maintenance Act | Video presentation (in-house instructor) | 1 | ||
March Act on the Protection of Personal Information - Explanation of revised law and our company’s response - |
Video presentation (in-house instructor) | 1 | ||
Other training | Directors and managers of NGK and Group companies in Japan | Quality compliance seminar “Thorough Quality Compliance” - Reviewing NGK inspection non-conformities - |
Training by executive officers | 1 |
Business groups and Group companies in Japan | Competition laws, anti-bribery regulations, Subcontract Act | Training by an in-house instructor | 5 |
Competition Law Education Conducted in FY2022
Name | Target | Content | Number of sessions |
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Training for newly appointed directors | Newly appointed directors and executive officers | Outside lawyer-led live seminar | 1 |
Competition law compliance lectures | All directors, managers, and sales staff of NGK and its Group companies in Japan | Streamed video of outside lawyer-led live seminar | 2 |
Compliance training for Group companies outside Japan | Managers and sales staff of Group companies outside Japan | Lawyer-led live seminar; e-learning; seminar conducted by an internal lecturer | 19 (24 sites) |
Training on competition laws by internal lecturer | Targets depend on content | Department-requested on-site training | 1 |
Anti-Bribery Training Conducted in FY2022
Name | Target | Content | Number of sessions |
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Training for sales staff | Sales staff in Japan and some Heads of Group companies outside Japan | Anti-bribery regulations for dealing with foreign public officials | 1 |
Legal Compliance Seminars | Managers of NGK | Anti-bribery regulations for dealing with foreign public officials | 1 |
Compliance education | Managers and sales staff of Group companies outside Japan | Outside lawyer-led live seminar and online seminar; seminar conducted by an internal lecturer; conducted using paper-based resources | 19 (24 sites) |
Other Dissemination Activities
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 FY2017, we began making October the annual compliance strengthening month, during which we do things such as put up educational posters and inform employees about the whistleblowing system.
In FY2021, we trialed a Compliance Activities Award System and have begun to put it into practice from FY2022. In FY2022 we presented Energy Support Corporation with an award for its activities to foster openness and greater understanding of its corporate philosophy. The chairman of the Compliance Committee presented a certificate of commendation and held a discussion meeting for the members promoting these activities. We will continue to give awards for compliance activities, from each department and Group companies, that are particularly independent and original. They are then publicized throughout the NGK Group as good examples.
Themes Covered in the Compliance Newsletter in FY2022
April | Are you prepared to protect yourself from earthquakes? |
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May | Avoiding speech and conduct that hurt LGBT people |
June | When you receive an invoice by email |
July | What to do if you witness fraud |
August | Will what I share with the consultation hotline stay secret? |
September | If you are harassed or witness harassment in the workplace |
October | Compliance strengthening month |
November | What happens if you use undisclosed information when trading stocks |
December | Human rights week |
January | When carrying your work computer or smartphone with you |
February | The importance of “Ho-Ren-So” (reporting, contacting, and consultation) |
March | What constitutes harassment from a position of power |