Sustainability
Anti-Corruption
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 FY2024, there were no confirmed incidents of corruption in the NGK Group.
Examples of Corruption/Bribery
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, or receiving such benefits (bribes) from another person. 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 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.
Anti-Corruption Initiatives
To ensure thorough compliance with relevant laws and regulations, the NGK Group takes a risk-based approach in implementing anti-corruption measures for our employees, consultants, agents, distributors, and other business partners. First, NGK has formulated internal 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), regardless of whether or not the other party is a public official, or whether the acts are committed directly or indirectly (including with the involvement of third parties such as company’s representatives and other business partners). These regulations also stipulate the actions that NGK should take to reduce bribery risks. As part of these efforts, when appointing business partners such as new representatives, etc., we perform due diligence (by checking for the existence of items defined by us as suspicious signs), and make it mandatory for contracts to include a clause about complying with laws and regulations related to preventing corruption.
For transactions that typically entail a high risk of bribery (foreign remittances, entertainment, commission payments to agents, etc.), we regularly conduct audits of transaction status and remittance records. We also conduct periodic audits, education, and training focused on Group companies thought to have a high risk in light of various indicators such as CPI (Corruption Perceptions Index). In this way, we are working to comprehensively prevent corrupt actions throughout the entire Group.
Moreover, the NGK Group receives reports of violation or possible violation of relevant laws or regulations and the Anti-Bribery Regulations via our hotline. 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 officers, be involved in the process of investigation and review.
Anti-Corruption Training
In our NGK Group Corporate Business Principles, NGK Group Code of Conduct, and NGK Group Anti-Corruption Policy, the NGK Group forbids employees from participating in all corrupt practices, including bribery, conflict of interest, and money laundering. We are making these policies well known by all employees of NGK and our Group companies in and outside Japan, through various compliance training, our code of conduct guidebook, and other efforts.
Specifically, NGK conducts yearly anti-corruption education, including level-specific small group training taught by in-house instructors and lawyers, and biannually checks for violations or signs of violations in the workplace with a compliance awareness survey of all Group employees in Japan.
Number of Sessions and Participants in Anti-corruption Training by Lawyers
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 region, 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 FY2024.