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
|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
|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|
Latest trends in insider trading regulations
|Force Majeure Clause||Video presentation||1|
Latest Trends in Anti-Bribery Regulations
Anti-Monopoly Act Revisions for 2019
|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
|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
|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
Other Dissemination Activities
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
|May||Personal use of workplace PC|
|June||Lost mobile phone issued for work|
|July||Environmental protection activities|
|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|
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|
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.