Sustainability

Initiatives to Ensure Thorough Compliance

Compliance with Competition Laws

Observing Competition Laws on an International Level

In addition to mandating compliance with competition laws in the NGK Group Corporate Business Principles and Code of Conduct, we have established Competition Laws Compliance Rules, which have been set forth to comply with international standards. These standards are strictly enforced by the NGK Group both inside and outside of Japan. We have established these policies and procedures to eradicate unfair actions and business practices, and work to maintain fair and equitable business relationships with our business partners.
We have also compiled basic items related to compliance with competition laws into our Competition Laws Compliance Handbook, and are promoting its utilization in our operations. We reviewed our internal rules in March of 2024, before publishing the 4th edition.
We have published these rules, our Handbook, operations manuals, and other educational materials on our Competition Laws Compliance Website so that everyone within the NGK Group can easily access them.

Strengthening Our Compliance System in Relation to Competition Laws

Year conducted	Regulation development	Creation of internal systems	Education
FY1997	Formulated guidebook and briefing document for the Anti-Monopoly Act	Required each headquarters to submit a Compliance Status Report on the Anti-Monopoly Act	Lectures on competition laws by outside instructors (lawyers)^*
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 lawyers held at Group companies outside Japan
FY2013			Conducted briefing on the Competition Laws Compliance Handbook Invited U.S. lawyers 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. lawyers^*
FY2015	Competition Laws Compliance Rules of all NGK Group companies inside and outside Japan were revised to ensure that the NGK Group’s compliance system meets global standards Revised the Competition Laws Compliance Handbook	The Competition Laws Compliance Program was resolved by the Board of Directors Established the Global Compliance Office Contracted Pricewaterhouse Coopers to conduct an unbiased expert review of the implementation status of the NGK Group’s Competition Laws 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	Progress status of the Competition Laws Compliance Program was quarterly reported to the Business Ethics Committee, which is composed mainly of outside 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 lawyers in Asia Prepared online-based training aimed at realizing broader training programs (implemented in FY2017 in Japan)
FY2017	Created an operating manual for database used to document competition law compliance	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
FY2019	Revised Competition Laws Compliance Rules at NGK Electronics Devices, Inc. to strengthen that subsidiary’s competition laws compliance system		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^*
FY2021	Revised the Competition Laws Compliance Handbook		Conducted legacy training for all NGK directors and general managers about past violations of competition laws at NGK
FY2022		Added the Corporate NV Creation as the headquarters responsible for things such as implementing a Competition Laws Compliance Program	Conducted legacy training for managers in sales positions at NGK about past violations of competition laws at NGK
FY2023	Revised the Competition Laws Compliance Handbook		Compliance with domestic competition laws Conducted comprehensive training about violations of competition laws at NGK for those responsible and in charge of operations.
FY2024	Reviewed the definition of competitors, scope of meetings, etc. for which notification procedures are required, from a risk-based point of view Promoted revisions of Competition Law Compliance Rules at Group companies in and outside Japan Promoted establishment of Competition Law Compliance Rules at overseas sub-subsidiaries		Performed comprehensive training about competition law violations at NGK targeting managers responsible for competition law compliance and the management of Group companies in the Asian region Created educational videos about NGK competition law violation examples

These items continue every year

Review of Competition Laws Compliance Program Based on Advice from External Specialist

Starting in FY2015, NGK contracted an external compliance specialist to review the operation of our Competition Laws Compliance Program based on the Competition Law Compliance Rules, as well as the NGK Group's unified supervision and reporting system including for group companies inside and outside Japan. This continued every year until FY2023. Since FY2021, we have been receiving advice on improving our Competition Laws Compliance Program. In FY2024, we began considering improvements based on this advice, and have incorporated these improvements into our Competition Laws Compliance Program for FY2025. In FY2025, we will put even more highly effective activities into practice through the operation of this program.

Instances of Anticompetitive Behavior

In FY2024, no instances of anticompetitive behavior were observed within the NGK Group.

Instances of Anticompetitive Behavior

Governance Data Collection

Page top

Export/Import Transaction Management

Strict Adherence to Laws and Regulations Relating to Export/Import Management

As part of its full compliance efforts, NGK is engaged in strictly observing and enforcing laws and regulations related to export and import control. Based on the NGK Group Corporate Business Principles and 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 Export Control System 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 screens exports to determine whether export licenses are required and performs management via a security export control system (TTP). Furthermore, export management with respect to the export of certain products is conducted under the Japanese government’s AEO (authorized economic operator) Program.
For export and import results, we use the security export control system (TTP) shipment ledger to track and record exports, and an import cargo management ledger for imports. Each department performs voluntary inspections of export and import 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 import cargo management ledgers and shipment ledgers. We have achieved nearly 100% completeness for both export and import.

Familiarization with the Export/Import Handbook

NGK also makes efforts toward thorough compliance with the Export/Import Handbook, in use since FY2021 and revised in FY2022, that 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 department.
When appropriate, study meetings on the AEO Program and export/import management are held targeting relevant staff in departments responsible for export and import activities. From FY2024, videos about our export and import system have been published on our logistics website, and we have launched an easy course that employees can do in their spare time.

Page top

Anti-Harassment Prevention

NGK conducts annual position-based training as part of our efforts to prevent harassment. In FY2022, we also began training courses on the prevention of workplace bullying which are taught by experts such as lawyers, and employed a group discussion format utilizing specific case studies. This training boosts the effectiveness of our education by using small group discussions about sexual harassment and workplace bullying from a position of power to promote proper understanding and awareness by participants of the problem of power harassment. In FY2024, 504 employees from five companies and five locations attended. They hailed primarily from the management ranks of our Group companies in Japan. In addition, we distributed learning materials throughout the NGK Group for use as part of self-study and harassment prevention training by each department, based on the results of the compliance awareness survey conducted in FY2023. These were viewed more than 9,000 times in the first year of distribution. We are improving our training content based on the results of surveys we conduct after the training is complete. We continue working to prevent harassment before it occurs and further improve the workplace environment by providing more effective training content.

Number of Lawyer-Led Harassment Prevention Training Sessions / Number of Participants

Governance Data Collection

Page top

Compliance Awareness Survey

In FY2023, as part of our efforts to strengthen the NGK Group compliance structure, we conducted our fourth Compliance Awareness Survey for employees working at NGK and Group companies in Japan. Therein, we identified risks that have become apparent, and asked respondents what they thought about their impacts, etc. Each department and company is now formulating initiatives and working to reduce risks based on the results.

Page top