Sustainability

Corruption Prevention Structure

Basic Approach

As laid out in the NGK Group Corporate Business Principles, the NGK Group has declared our commitment to working to bring about a sustainable society, respect human rights, conduct business activities that are fair, transparent, and sound, and strive to comprehensively prevent corruption as called for in the NGK Group Code of Conduct. Corruption is contrary to the NGK Group Corporate Business Principles and Code of Conduct, and cannot be tolerated. It not only impedes the realization of a sustainable society, but leads to human rights violations. We comply with applicable laws and regulations, prohibit direct or indirect involvement in corruption, and strive to prevent corruption in all of our business activities. We established the NGK Group Anti-Corruption Policy to earn the trust of stakeholders and bring about a sustainable society.

Examples of Corruption

In FY2023, there were no confirmed incidents of corruption in the NGK Group.

Examples of Corruption

Governance Data Collection

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Bribery/Conflicts of Interest/Money Laundering/Insider Trading

NGK Group executives and employees are prohibited from engaging or participating in corrupt practices such as bribery, embezzlement, conflicts of interest, money laundering, insider trading, obstruction of justice, or the abuse of their own or another person's authority or position for the benefit of an individual or organization.

Bribery

The NGK Group prohibits bribery, which is the giving of money, gifts, entertainment, etc., to another person for the purpose of obtaining an improper advantage. To prevent such actions, we will maintain sound relationships with stakeholders, including public officials and government officials, in the countries and regions in which we operate. And we will not accept these kinds of benefits (bribes) from others. We will only provide gifts and entertainment when there is a justifiable business reason for doing so, and within the scope of socially accepted norms. We will not provide gifts or entertainment on a habitual basis. Moreover, we will properly manage company assets such as cash, equipment, software, and vehicles, and use them only for legitimate business purposes. We will not use them for ourselves or other people.

Conflict of Interest

The NGK Group prohibits conflicts of interest in which NGK's interests are sacrificed to obtain personal gain, or to provide benefits to third parties such as relatives and friends. This can include selecting someone with whom you have a personal interest as a business partner, engaging in a business which competes with the company business, or the like. See the link below for more information on our approach to conflicts of interest.

Approach to Conflicts of Interest

Money Laundering

NGK Group executives and employees are prohibited from engaging in "money laundering" to conceal or disguise funds obtained through illegal activities such as tax evasion and fraudulent settlement of accounts.

Insider Trading

NGK Group executives and employees are prohibited from engaging in "insider trading," which entails buying and selling securities such as stocks based on important undisclosed information about a company or its business partners. One of our initiatives is to distribute educational videos to NGK Group members every year covering the latest trends, etc. concerning insider training.

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Anti-Corruption Initiatives

In FY2015, NGK formulated Anti-Bribery Regulations 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. These regulations also stipulate the actions that NGK should take to reduce bribery risks. As part of these efforts, when using new representatives, etc., 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 and existing representatives, etc. twice a year, and conduct a bribery risk assessment. Our Auditing Department has also been reviewing overseas remittances and entertainment expenses since FY2017.
Moreover, we receive reports of violation or possible violation of relevant laws or regulations and the Anti-Bribery Regulations via our hotline, etc. If we receive such a report, we investigate and examine the facts with the advice of external experts (lawyers, etc.), and determine the appropriate response. We maintain appropriate handling and independence, by having the Business Ethics Committee, which is composed primarily of outside directors, be involved in the process of investigation and review.
Plus, every other year, NGK checks for violations or signs of violations in the workplace with a compliance awareness survey of all Group employees in Japan, and conducts level-specific training during which in-house instructors explain specific corrupt practices.

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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.
We made no political donations in FY2023.

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