Respect for Human Rights
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 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.
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.
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.
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.
Supply-Chain CSR Guidelines
The NGK Group expects all our suppliers to comply with our human rights policy in terms of respect for human rights in our supply chains. We ask them to thoroughly implement the policy using the NGK Group's Supply-Chain CSR Guidelines. The guidelines give clear guidance on the following matters: respect for basic human rights and abolishment of discrimination, prohibition on forced labor, prohibition on child labor, wages, working hours, safety and hygiene, dialogs and discussions with employees, and responsible resource and material procurement.
We ask all our suppliers to submit a form consenting to compliance with the guidelines once a year. We also ask suppliers to consent to complying with the guidelines when starting new transactions.
We have published the NGK Group's Supply-Chain CSR Guidelines on our website in Japanese, English and Chinese.
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.
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.
Organizational Structure Chart
Overall Picture of Initiatives for Respect for Human Rights
In FY2022, we focused on the following human rights initiatives.
|Implementation Timing||Details of Implementation|
|(Ongoing from FY2021)||Conducting human rights due diligence surveys (SAQs) for Japanese and overseas suppliers of NGK headquarters|
|April to June||Conducted a human rights due diligence survey (SAQ) on suppliers of Group companies in Japan|
|April to June||Investigated human rights related grievances in all
Group companies in and outside Japan in the second half of FY2021 (human rights related grievance of NGK headquarters are handled as the occasion demands)
|June||Provided the “Business and Human Rights: Initiatives for Respecting Human Rights” e-learning program|
|September||Disclosed Statement on the UK Modern Slavery Act (fiscal year ended March 31, 2022)|
|October to November||Conducted investigations into human rights-related grievances at Group companies in and outside Japan during the first half of FY2022 (human rights related grievances at NGK headquarters are investigated and recorded on a case by case basis)|
|December 2022 to February 2023||Conducted a human rights due diligence survey (SAQ) of NGK headquarters, and all Group companies in and outside Japan|
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 FY2022, a total of 43 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 FY2022, we received 28 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 submit a written agreement to comply with our Supply-Chain CSR Guidelines. Moreover, in FY2022, we newly conducted a self-assessment survey to ascertain the level of understanding of, and status of activities related to, CSR procurement at approximately 630 suppliers of our Group companies in Japan.
Based on the above results, the NGK Group recognizes that the following are human rights issues requiring our attention. We are now considering our response to them.
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 overseas Group companies. 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.
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
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.
|Category||Theme||Participants / Applicable Range||Number of Participants||Implementation Timing|
|Human rights in general||“Business and Human Rights: Initiatives for Respecting Human Rights” e-learning program Corporate responsibility to respect human rights, human rights related risks, NGK Group Human Rights Policy and internal initiatives||
||Viewed: 12,207 views
Questionnaire respondents: 3,846
|Human rights in general||Respect for human rights, NGK’s initiatives, and ESG risks and opportunities||Newly appointed managers, those promoted within managerial positions, career recruits in managerial positions||115||December 2022|
|Human rights in general||NGK Group Corporate Business Principles
Realization of a sustainable society through business activities, respect for human rights, and thorough compliance
|Employees promoted as those in general positions and career recruits with eligible qualifications||433||November 2022 to March 2023|
|LGBT||“Introduction to LGBT: Aiming for a Worker-friendly Workplace”
Basic LGBT knowledge and internal initiatives
|New employees||139||April 2022|
|Harassment||Definitions of workplace bullying and sexual harassment, concrete examples, treatment in workplace regulations, helpline introduction, and promotion of understanding through case studies||New employees, employees promoted as those in general positions, and mid-career recruits with the eligible qualifications||572||April 2022 to March 2023|
|Harassment||Compliance, workplace bullying and sexual harassment in manufacturing sites||New section chief training||11||July to December 2022|
|Harassment||Definitions of workplace bullying and sexual harassment, treatment in workplace regulations, and deepening of understanding of examples applicable to harassment and prevention of harassment through multiple case studies||Officers and employees of NGK and Group companies in Japan||519||October 2022 to March 2023|