Respect for Human Rights

Basic Approach

Concerning respect for human rights within NGK Group business activities, our relationship with employees has been governed by the NGK Group Corporate Business Principles, and our relationship with suppliers has been governed by the NGK Group Supplier Code of Conduct. In April 2021 we established the NGK Group Human Rights Policy as a separate policy on human rights. This not only clarifies our messaging both inside and outside of NGK, but accelerates our efforts to respect human rights.

NGK Group Human Rights Policy

NGK Group Corporate Business Principles

NGK Group Supplier Code of Conduct

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Related Policies and Approaches

Statement on the UK Modern Slavery Act

We have disclosed our UK Modern Slavery Act Statement based on the Modern Slavery Act passed by the United Kingdom in 2015.

UK Modern Slavery Act Statement

Respect for the Human Rights of Children

The NGK Group is aware that there are a variety of impacts that corporations can have on children. In addition to signing the UN Global Compact, we support the Children’s Rights and Business Principles, respect the rights of children through our business activities, and engage in social contribution activities and other efforts to promote children’s rights.

Social Contribution Activities

Compliance with Local Labor Laws

The NGK Group complies with the laws of each country and region concerning labor and occupational safety and health.
We have also established a reporting mechanism for whistleblowing and consultation to handle possible violations.
Regarding child labor and forced labor, we use sources such as official public documents to confirm the age of candidates before they are hired. To date, we have found no cases of child labor or forced labor through the regular surveys.

NGK Group Supplier Code of Conduct

The NGK Group expects all of our suppliers to comply with our human rights policy in terms of respect for human rights in our supply chains. We also ask them to thoroughly implement the policy using the NGK Group Supplier Code of Conduct. This code gives clear guidance on concrete measures concerning basic human rights, including prohibition of discrimination, forced labor, and child labor, consideration for appropriate wages, working hours, and the like.
We ask all our suppliers to consent to compliance with this code once a year. We also ask suppliers to consent to compliance with this code when starting new transactions.

Supply Chain Management

NGK Group Supplier Code of Conduct

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Management System

In April 2020, we established the HR Committee as a cross-sectoral, deliberative body chaired by the director responsible for the Human Resources Department and tasked with ensuring that corporate activities have a stronger focus on human rights and that important personnel issues are addressed by the NGK Group as a whole.
Two committees work to promote initiatives that ensure respect for human rights. For the NGK Group this is the HR Committee, and for our supply chain it is the Supply Chain Subcommittee of the ESG Management Committee. These committees coordinate and cooperate with related committees and departments on such initiatives, according to their content and importance. Meanwhile, the managing director of the HR department regularly reports to the Board of Directors concerning the status of their implementation, and the Board of Directors overseas the status of implementation.

Organizational Structure Chart

Overall Picture of Initiatives for Respect for Human Rights

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FY2023 Activities

In FY2023, we focused on the following human rights initiatives.

Implementation Timing	Details of Implementation
(Ongoing from FY2021)	Conducting human rights due diligence surveys (SAQ) for Japanese and overseas suppliers of NGK headquarters
April to June	Investigated human rights related grievances in all Group companies in and outside Japan during the second half of FY2022 (human rights related grievances at NGK headquarters are investigated and recorded on a case-by-case basis)
September	Disclosed Statement on the UK Modern Slavery Act (fiscal year ended March 31, 2023)
October to November	Investigated human rights-related grievances at Group companies in and outside Japan during the first half of FY2023 (human rights related grievances at NGK headquarters are investigated and recorded on a case-by-case basis)
November to December	Conducted human rights due diligence surveys (SAQ) for primary suppliers of Group companies outside Japan
December 2023 to March 2024	Conducted human rights due diligence surveys (SAQ) for Japanese and overseas suppliers of NGK headquarters
March	Conducted “Business and Human Rights: NGK Group Human Rights Policy” e-learning program

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Human Rights Due Diligence

Human Rights Risks Accompanying Group Business Activities

NGK regularly conducts a self-assessment survey based on the RBA^* Code of Conduct on ourselves and our Group companies in and outside of Japan. In FY2023, a total of 40 companies including NGK underwent the self-assessment survey with a total of 55 questions in the three categories of labor, health and safety, and ethics. Conducting this survey gives us a comprehensive overview of the business activities in our group and identifies human rights issues.
As a result, no violations of the laws or regulations of each country were found. On the other hand, we confirmed multiple instances of issues which, while legal, do not comply with the RBA Code of Conduct. We recognize that these are human rights issues requiring our attention. Based on that, we will consider our response while taking into account the laws/ordinances, customs and practices of each country.

Responsible Business Alliance: Focusing primarily on the electronic equipment industry, the RBA establishes standards and conducts audits with the aim of promoting safe working environments, worker protection, and environmental responsibility.

Human Rights Risks to Employees

Concerning human rights risks to employees, we accept reports and queries about human rights through our internal whistleblowing desk, and receive reports from Group companies once every 6 months through the Human Rights Grievance Survey or the Legal Risk Management Report. In FY2023, we received 27 reports related to human rights (harassment, labor-related, etc.) from the entire NGK Group. We are handling these with fact-finding investigations, rectification, instruction, and warnings. Once every two years we also conduct a Corporate Risk Survey (CRS) to identify latent risks.

Human Rights Risks to Supply Chain

For our supply chain, every year we ask all suppliers, including new suppliers, to consent to compliance with the NGK Group Supplier Code of Conduct. Moreover, in FY2023, we conducted a supplier CSR procurement survey at approximately 70 suppliers of our Group companies outside Japan.

NGK Group Supplier Code of Conduct

Supplier Assessment

Human Rights Issues Requiring Our Attention

Based on these results, the NGK Group has identified the following as human rights issues requiring our attention. We are now considering our response to them.

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Grievance Mechanisms

NGK has established a whistleblowing desk (helpline) which can be used by all officers and employees of NGK and our Group companies in Japan. We have set up internal and external desks to be able to accept anonymous inquiries and reports. At the same time, we are striving to protect those who make inquiries and whistleblowers so that they are not treated unfavorably as a result of making an inquiry or report. We are establishing effective whistleblowing structures in our Group companies outside Japan. For example, our Group companies are establishing mechanisms to receive inquiries and reports which can be used by all officers and employees to suit the actual circumstances in their countries.
Moreover, we have established the Supplier Helpline to accept inquiries and reports from suppliers. Together with this, we are capable of receiving inquiries and reports from all our stakeholders through the Contact page on the NGK website.

Whistleblowing System

Supplier Helpline

Contact Page on the NGK Website

When we receive an inquiry or report relating to human rights, the Human Resources Department provides remedies for the affected parties if we confirm human rights have been affected upon discussions with the Group Compliance Department and other related departments. Together with this, the Human Resources Department takes corrective and preventative measures. It then makes reports to the Compliance Committee, HR Committee and ESG Management Committee as necessary depending on the degree of importance about our response to those issues.

Grievance Mechanisms and Remediation / Remedy Framework

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Education Concerning Human Rights

NGK conducts various types of training, through seminars and e-learning, for executives and all employees, with the goal of improving their level of understanding for respecting human rights in our corporate activities.

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