Sustainability
Corruption Prevention Structure
Basic Approach
The NGK Group endorses the UN Global Compact (UNGC) and abides by the principle that businesses should work against corruption in all its forms, including extortion and bribery.
The NGK group conducts fair and transparent transactions, in accordance with our pledge to undertake business activities with common sense and based on strict compliance and ethics, as stipulated in the NGK Group Corporate Business Principles.
Corruption Prevention Structure
Assessing Risk and Dealing With Corruption
The NGK Group carries out risk management for major compliance risks, including corruption, by considering them from a management-level perspective. We then sort those deemed important risks into the categories of business environment, strategy, and internal factors, and continually review them. The Compliance Committee and other committees and responsible departments take a leading role in working to avoid and prevent risks in each business by conducting risk analysis through surveys and the evaluation of special risks in internal control processes.
In FY2015, NGK formulated Rules for the Anti-Bribery of Public Officials in order to ensure compliance with anti-bribery laws as well as ethical standards for business conduct. These prohibit all acts of bribery (entertainment, gifts of money and goods), whether they are committed directly or indirectly via third parties such as representatives or distributors of our business partners. In principle, these regulations also prohibit payments to public officials for the purpose of facilitating business procedures (facilitation payments), and stipulate items for future risk assessments. Furthermore, when using new companies or distributors, we perform due diligence by checking for the existence of items stipulated by our suspicious signs list, and sign a contract that includes a clause about understanding and complying with laws and regulations related to preventing corruption. In addition, we check the state of transactions with new representatives and distributors twice a year based on our Rules for the Anti-Bribery of Public Officials, and conduct a bribery risk assessment. The Group Compliance Department can appoint a person in-charge of collecting information about trends in compliance issues related to relevant laws and regulations in the markets and industries where the NGK Group conducts business. The appointed person will then be responsible for ascertaining new problems that come to light in our operations, and collecting information on industry trends. If they identify any trends requiring special mention, this person will report them to the Manager of the Group Compliance Department, and if deemed necessary, will determine a suitable response in consultation with the Business Ethics Committee. If we receive a report of violation or possible violation of relevant laws or regulations for the Rules for the Anti-Bribery of Public Officials, we investigate and examine the facts with the advice of external experts (lawyers, etc.), and determine the appropriate response. Our Auditing Department has also been reviewing overseas remittances and entertainment expenses since FY2017.
Moreover, we distribute the NGK Group’s Supply-Chain CSR Guidelines to our suppliers, and require that they understand them and agree to not engage in bribery. In accordance with the section on preventing corruption, bribery includes unlawful donations, payment, prices, or financial or non-financial benefits or other gifts to any stakeholders for the purposes of unfair profit, or the acquisition or maintenance of preferential treatment.
NGK Group's Supply-Chain CSR Guidelines (PDF:141KB)
Conducting Anti-Bribery Training
In addition to having in-house lecturers provide job grade-specific training to NGK employees, in FY2019 we began conducting training for sales department employees that incorporates interactive lectures by outside lawyers and group discussion of case studies. We also arrange attorney-led seminars and other training at all Group companies.
Corruption and Bribery Incidents
In FY2022, there were no confirmed incidents of corruption or bribery in the NGK Group.
Incidents of Corruption or Bribery
Responsible Political Involvement
Donations to Political Parties and Political Fund Raising Organizations
The NGK Group strives to maintain transparent, sound, normal relationships with political and administrative bodies. We make political contributions and donations in accordance with the laws and regulations of each country, and do not engage in actions that may lead to suspicion or distrust from society.
When making political donations, we follow the procedures stipulated by our internal regulations, while fully complying with the Political Funds Control Act, the Public Offices Election Act, and other relevant laws and regulations.