Initiatives for Human Rights
Concerning respect for human rights within NGK Group business activities, our relationship with employees has been governed by the NGK Group Code of Conduct, and our relationship with suppliers has been governed by our Supply-Chain CSR Guideline. 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 the company, but accelerates our efforts to respect human rights.
NGK Group Human Rights Policy
The NGK Group hereby establishes this "NGK Group Human Rights Policy" (this "Policy") based on the "United Nations Guiding Principles on Business and Human Rights" and will promote initiatives to respect human rights to prevent violation or abuse of human rights of anyone impacted by the NGK Group's business operations.
1. Basic Approach to Human Rights
The NGK Group supports and respects the "International Bill of Human Rights" adopted by the United Nations (consisting of the Universal Declaration of Human Rights and the International Covenants on Human Rights), the "ILO Declaration on Fundamental Principles and Rights at Work" , the "OECD Guidelines for Multinational Enterprises" and other international norms.
With NGK INSULATORS, LTD. ("NGK") signed up to the United Nations Global Compact, the NGK Group supports and respects the Ten Principles of the United Nations Global Compact.
2. Applicable Laws
The NGK Group conforms with all laws and regulations of the countries and territories in which it conducts business. When a law or regulation conflicts with internationally accepted principles of human rights, every effort is made to conform with the latter.
3. Scope of Application
This Policy applies to all directors, officers and employees of the NGK Group (the "Directors and Employees"). The NGK Group expects that its suppliers will also comply with this Policy.
4. Education and Training
The NGK Group will provide the Directors and Employees with appropriate education and training to effectively implement this Policy throughout its group-wide business operations.
5. Main Focus of the Group's Commitment to Human Rights
The NGK Group will:
- Comply with international norms on human rights and respect diversity of people;
- Respect human rights and undertake business activities without the use of forced labor or child labor; Provide young workers with fair working conditions that strictly comply with the Legislation of each country and region.
- Respect the individuality and independence of each employee and not engage in discrimination on the basis of race, citizenship, gender, age, religion, belief, existence of handicaps, sexual diversity or any other aspect; and
- Prevent the occurrence of harassment in the workplace and take prompt and appropriate action in the case where it occurs.
The NGK Group will:
- Strictly comply with the Legislation of each country and region relating to safety and sanitation, provide a safe and enjoyable work environment that is comfortable for everyone to work in for all;
- Strictly comply with the Legislation of each country and region relating to labor, safety and sanitation, we provide fair working conditions such as working hours, holidays, vacations, wages, and welfare programs.
- Respect employees’ right of freedom of association and of collective bargaining in accordance with the Legislation of each of countries and regions where it operates.
- Aim to harmonize work and life, and support a variety of working styles;
- Build up a relationship of trust through sincere debate and discussion with employees;
- Give educational opportunities to employees and provide opportunities to stretch their motivation and abilities; and
- Encourage free and open discussions and aim to create a corporate culture conducive to active communication.
6. Human Rights Due Diligence
The NGK Group will establish a system of human rights due diligence, and will implement processes to identify, prevent and mitigate adverse human rights impacts that the NGK Group's business operations may cause.
If it is revealed or suspected that the NGK Group has caused adverse human rights impacts (whether directly through its business operations, or through its suppliers), the NGK Group will endeavor to deliver appropriate and effective remedy through good-faith dialogue with related parties.
8. Dialogues and Discussions
In the process of implementation of this Policy, the NGK Group will earnestly engage in dialogue and discussions with stakeholders, acquiring and drawing on independent external expertise on human rights.
9. Information Disclosure
NGK will disclose the status and results of implementation of this Policy on its website and integrated reports or through other channels.
10. Administrative Authority
NGK will designate the director in charge of the personnel division as the director responsible for the implementation of this Policy. The Board of Directors will oversee the status of implementation of this Policy by having the director regularly report the implementation status to the Board of Directors.
This Policy has been approved by NGK's Board of Directors and signed by NGK's Representative Director and President.
NGK Insulators, Ltd. President
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 whistle-blowing 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.
In April 2020, we established the HR Committee as a cross-sectoral, deliberative body chaired by the executive in charge of the HR 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.
The HR committee coordinates and cooperates with related committees and departments on initiatives for ensuring respect for human rights, according to their content and importance. At the same time, 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.
In FY2021, we focused on the following human rights initiatives.
|April 2021||Disclosed NGK Group Human Rights Policy|
|August 2021||Revised NGK Group Human Rights Policy|
|November 2021||Newly formulated and disclosed Statement on the UK Modern Slavery Act|
|October 2021||Conducted investigations into human rights-related grievances at Group companies in and outside Japan during the first half of FY 2021 (human rights related grievances at NGK headquarters are investigated and recorded on a case by case basis)|
|December 2021 to March 2022||Conducted a Human Rights Due Diligence survey of NGK headquarters, and all group companies in and outside Japan|
Initiatives for Due Diligence Processes, Assessment, and Rectification
The NGK Group is making a variety of efforts to identify, prevent and mitigate practices within the NGK’s business operations that negatively impact human rights. The HR Committee has verified this approach and reported to the Board of Directors.
Self-Assessment by Each Group Company
NGK and a total of 39 Group companies in and outside of Japan, conduct a 55 question self-assessment survey based on the RBA* Code of Conduct which looks at the three categories of labor, safety and health, and ethics.
As a result, no violations of the laws or regulations of each country were found. On the other hand, there were some issues identified which do not comply with the RBA Code of Conduct.
We have already made improvements to address some of these minor matters (such as providing health and safety information in a language employees can understand). For matters like hiring procedures and working hours, we are aware that these are issues and are considering how to address them in light of the laws, norms, and customs 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 collect information through our internal whistleblowing system, and receive reports from Group companies once every 6 months through the Human Rights Grievance Survey. In FY2021, we received 52 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.
Risks to Supply Chain
For our supply chain, every year we ask all suppliers, including new suppliers, to submit a written agreement to comply with our Supply-Chain CSR Guideline. Moreover, in FY2021 we conducted a self-assessment survey to ascertain the level of understanding of, and status of activities related to, CSR procurement at our approximately 700 suppliers in Japan.
NGK Group’s Supply-Chain CSR Guideline
Grievance Mechanisms and Remediation / Remedy Framework
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.
- Business and Human Rights — Initiatives for Respecting Human Rights (held June 2022)
Conducted e-learning about the responsibility of companies to respect human rights, risks related to human rights, the NGK Group Human Rights Policy, and our own human rights initiatives.
- Introduction to LGBT — Aiming for a worker-friendly workplace — (held March 2021)
Conducted e-learning on basic knowledge about LGBT as well as our own initiatives.
- Training related to harassment (held FY2021)
We conducted training related to harassment whenever an employee was promoted. It defined both sexual harassment and harassment from a position of power, explained how to handle them in accordance with workplace regulations, and promoted understanding through case studies.