Sustainability

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 2020 (Overall)

Name Target Content Instruction format Number of sessions
Career education New hires (regular-position employees) Compliance basics, competition laws, anti-bribery regulations Training by an in-house instructor 1
New hires (engineering staff) Compliance basics, competition laws, anti-bribery regulations Video presentation 1
Promoted or career-changed employees Compliance basics Video presentation 1
Mid-career hires Compliance basics, competition laws, anti-bribery regulations 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 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 3
Compliance education Managers and sales staff of Group companies outside Japan Compliance basics, competition laws, anti-bribery regulations Lectures provided by attorneys and paper materials-based in-house training 19
(24 bases)
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 Japan Anti-bribery rules for dealing with foreign public officials Attorney-led seminar 4
Executive officers Competition laws Self-study using paper-based resources; attorney-led seminar 2
Newly appointed executive officers Companies act and competition laws Attorney-led seminar 1
Managers and sales staff of NGK and Group companies in Japan Competition laws Video presentation 1
Laws and compliance seminars Managers and other targets depending on content July Happy Living – Protecting yourself from traffic accidents, crime and criminal groups – Video presentation 1
September
Latest trends in insider trading regulations
Video presentation 1
Force Majeure Clause Video presentation 1
January
Latest Trends in Anti-Bribery Regulations
Attorney-led seminar 1
March
Anti-Monopoly Act Revisions for 2019
Video presentation 1
Other training Directors and managers of NGK and Group companies in Japan Quality compliance seminar “Building a quality-focused organizational culture” Seminar by an outside instructor 1
Divisions and Group companies in Japan Competition laws, anti-bribery regulations, Subcontract Act Training by an in-house instructor 7

Competition Law Education Conducted in Fiscal 2020

Name Target Content Number of sessions
Training for newly appointed directors Newly appointed directors and executive officers Outside attorney-led live 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 live seminar 2
Compliance training for Group companies outside Japan Managers and sales staff of Group companies outside Japan Attorney-led live seminar and online seminar; seminar conducted by an internal lecturer; conducted using paper-based resources 19
(24 bases)
On-demand training on competition laws by internal lecturer Targets depending on content Division-requested on-site training; training by legal department staff 6

Anti-Bribery Training Conducted in Fiscal 2020

Name Target Content Number of sessions
Training for sales staff Sales staff in Japan
Heads of Group companies outside Japan (some)
Anti-bribery rules for dealing with foreign public officials
4
Compliance education Managers and sales staff at Group companies outside Japan Attorney-led live seminar and online seminar; seminar conducted by an internal lecturer; conducted using paper-based resources 19
(24 bases)

Other Dissemination Activities

Four-panel comic strip published in the 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 FY2020

April Anonymous consultations
May Personal use of workplace PC
June Lost mobile phone issued for work
July Environmental protection activities
August Confidential conversations
September Differences in nationality or culture
October Compliance strengthening month
November Outsourcing of personal information management
December Human rights week
January Safe and enjoyable work environment
February Harassment prevention
March Contract compliance

Compliance Surveys

We conduct a Corporate Risk Survey (CRS)* within the NGK Group once every two years to gauge compliance and business risk-related awareness among employees.
In fiscal 2020, we continued working to address the risks identified from the survey results in fiscal 2019, such as by providing training in identifying actual compliance violations and how to prevent them. In addition, individual business groups and other organizations within the NGK Group conduct their own surveys and use the results to propose and implement measures each fiscal year.
For the CRS in fiscal 2021, we plan to expand the scope to some of our Group companies outside Japan and collect local employee responses as well.

  • * CRS respondents
    1) Compliance awareness survey – Japan: Directors and employees, including those who are temporary or part-time / Overseas: Employees dispatched overseas
    2) Business risks – Japan: Assistant manager and supervisor class or higher

Strengthening Our Compliance System Related to Competition Laws

Year conducted Regulation development Creation of internal systems Training
FY1997
  • Formulated guidebook and briefing document for the Anti-Monopoly Act
  • Required each business group to submit a Compliance Status Report on the Anti-Monopoly Act
  • Lectures on the Anti-Monopoly Act by outside instructors (attorneys) (subsequently held annually)
FY2011
  • Formulated Competition Laws Compliance Rules
FY2012
  • Created and distributed the Competition Laws Compliance Handbook
  • Created and distributed an Appendix to the Competition Laws Compliance Handbook
  • Established an independent committee
  • In-house training led by legal department staff
  • Lectures by local attorneys held at Group companies outside Japan
FY2013
  • Conducted briefing on the Competition Laws Compliance Handbook
  • Invited U.S. attorneys to lecture on competition laws
FY2014
  • Revised Competition Laws Compliance Rules
  • Launched operation of a database for advanced notifications and participation reports pertaining to meetings
  • Launched operation of an e-mail monitoring system
  • Revised Competition Laws Compliance Rules at North American sales subsidiaries
  • Introduced company-wide centralized supervision and reporting structures led by the Board of Directors (independent of the President)
  • Appointed company-wide competition laws supervisory managers
  • Enhanced the helpline
  • Conducted study meetings for newly appointed directors on competition laws and the Companies Act by Japanese and U.S. attorneys (subsequently held annually)
  • Conducted study meetings on competition laws at Group companies outside Japan (corresponding to laws and regulations in each country)
FY2015
  • Competition Laws Compliance Rules of all NGK Group companies in and outside Japan were revised to ensure that the NGK Group’s compliance system meets global standards
  • Revised the Compliance Laws Compliance Handbook
  • The Competition Laws Compliance Program was resolved by the Board of Directors
  • Established the Global Compliance Office
  • Contracted Pricewaterhouse Coopers to review the implementation status of the NGK Group’s competition law compliance program and assess the overall oversight and reporting structures in place for NGK Group companies
  • Conducted study meetings on competition laws for new employees
  • Distributed a DVD on competition laws to Group companies in Japan
  • Upgraded training on compliance with competition laws provided in and outside Japan
FY2016
  • The U.S. version and Chinese version of the Competition Laws Compliance Handbook were created and distributed to Group companies in the U.S. and China, respectively
  • Progress status of the competition law compliance program was quarterly reported to the Business Ethics Committee, which is composed mainly of external directors. The program was promoted based on suggestions received from the Committee.
  • Retained PwC Advisory to assess the status of competition law compliance
  • Expanded seminars led by attorneys in Asia
  • Held seminars on the Companies Act and competition laws for newly appointed executive officers
  • Prepared online-based training aimed at realizing broader training programs (Implemented in fiscal 2017 in Japan)
FY2017
  • Operating manual for database used to document competition law compliance underwent maintenance and updating
  • Top management of headquarters, business groups, and Group companies provided notifications about compliance with competition laws at beginning of term
  • Online seminars provided to 861 employees in Japan
FY2018
  • Clarified items that should be reported to the hotline when there were violations or fear of violation of competition laws, and revised Competition Laws Compliance Rules
  • Created a working manual for compliance with competition laws
  • Top management of headquarters, business groups, and Group companies provided notifications about compliance with competition laws at beginning of term
  • Held seminars on the Companies Act and competition laws for newly appointed directors and executive officers
  • Held competition law compliance lectures. All executives and managers attended
FY2019
  • Revised Competition Laws Compliance Rules at NGK Electronics Devices, Inc. to strengthen that subsidiary’s competition laws compliance system
  • Top management of headquarters, business groups, and Group companies provided notifications about compliance with competition laws at beginning of term
  • Held seminars on the Companies Act and competition laws for newly appointed executive officers
  • Held competition law compliance lectures. All managers and those designated by competition law compliance managers attended.
  • Information session provided regarding the Competition Laws Compliance Handbook’s key points (on competitor information when creating email and documentation)
FY2020
  • Established the Competition Laws Compliance Activities Portal Site
  • Top management of headquarters, business groups, and Group companies provided notifications about compliance with competition laws
  • Held seminars on the Companies Act and competition laws for newly appointed directors and executive officers
  • Held competition laws compliance lectures attended by executives, all managers, and those designated by competition law compliance managers

Note: Items in blue continue every year

Strict Adherence to Laws and Regulations Relating to 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 Code of Conduct, 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 16, 2017, we have moved to a security export control system (TPP) 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 (TPP), 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 export/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, which was published in fiscal 2012 and 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 business division.
Study meetings on the AEO Program and export/import management are held one or more times per year targeting relevant staff in divisions responsible for export and import activities. In fiscal 2020, these meetings were held 12 times, with 205 employees in attendance.