With recognition that our company is a member of society, we enhance corporate ethics and understand the spirit and meaning of laws, company regulations, international rules, and social norms in order to appropriately meet social demand and become a company trusted by the international community.
- We not only comply with laws and regulations, but also act in good faith with common sense and responsibility as a member of society.
- We regularly educate and raise the awareness of all our employees to impart a high level of ethics and correct knowledge, with which they can act voluntarily to prevent a violation.
- Should a violation occur, we will promptly investigate the causes and take remedial actions. We will strive to take appropriate countermeasures to prevent recurrence and fulfill our accountability.
We work to increase awareness among employees regarding compliance to act in a socially sensible manner, helping them to bear in mind that our enterprise is a member of society.
Compliance Promotion System
The Compliance Committee made up of the chairpersons of the other 5 expert committees under the CSR Committee and the chairperson of the Disciplinary Action Committee, headed by the Representative Director, holds meetings on a regular basis, carrying out inspections and correcting serious problems.
Promoting Compliance Education
To raise employees awareness and of and improve knowledge regarding compliance, we continue education and edification using the Compliance Guidebook, which collects rules concerning the company and society, and the Compliance Newsletter, which features examples of incidents that happen nearby as well as position-based training. In addition to the level-specific training we have used in the past, we also hold training on the themes of competition law, export control, and business law.
Corporate Ethics Helpline
We created the “Corporate Ethics Helpline” to be an in-house reporting system that encourages employees and business partners to consult us and report issues regarding compliance. We have worked to increase convenience by establishing channels not only inside the company but also with an external expert private company, enabling consultation and reporting outside of business hours, on holidays etc. Anonymous consultations are also accepted.
Regarding consultations and reports received, facts are investigated with discretion, so the reporting employee is not identified and does not feel uncomfortable, and if problems are confirmed, they are dealt with promptly.
We received 73 cases of consultations and reports in fiscal 2018, including those from employees for our group companies. The consultations and reports mainly involved with issues such as labor and in-house rules. We immediately took remedial actions upon identification of problems of accepted cases. This system will be continuously made known to every employee through opportunities, for example, by introduction in trainings, display of posters, and distribution of portable cards.
Initiatives to Prevent Corruption
The NGK SPARK PLUG Group works to prevent corruption, stating in our corporate code of conduct “we shall promote fair, transparent, free competition and sound trade. We shall also ensure that our relationships and contacts with government agencies and political bodies are of a sound and proper nature.”
In the Compliance Guidebook we issued in 2012, we set rules concerning the prevention of corruption, including the prohibition of involvement in political contributions or bribery, and subsequently educated employees about these. In 2013, we educated employees about our Conduct Guidelines Concerning the Giving and Receiving of Gifts and Entertainment and are raising awareness to eliminate any misconduct. Further, in 2016 we signed the United Nations Global Compact, openly reaffirming our commitment to undertaking the prevention of corruption. While addressing the prevention of corruption in accordance with these and other guidelines, we respond to any incident of violation primarily through our Compliance Committee. We also accept information provided through the Corporate Ethics Helpline.
Our overseas group companies are also taking action to prevent corruption, especially preventing bribery towards civil servants, and conduct education for employees along with surveys of local laws.
Through our CSR Procurement Guidelines, we further require that suppliers refrain from acts of bribery. In fiscal 2018, there were zero related violations committed by our Group.
Initiatives Concerning Competition Law (the Anti-Monopoly Act)
Responding with sincerity to violations of competition law (the Anti-Monopoly Act) uncovered in fiscal 2014, the NGK SPARK PLUG Group has established a system to promote compliance with competition law and ensures legal compliance both inside and outside of the company. In addition, we have formulated an Anti-Monopoly Act Compliance Manual to educate employees, including holding various seminars for employees and directors on the topic.
Furthermore, we have introduced an in-house e-mail inspection system for monitoring and prevention of recurring violations of the Competition Law.
As for overseas group companies, the status of competition law and compliance is reported to the head office in Japan on regular basis as well as the domestic competition law and compliance measures team visits overseas group companies to conduct audits on compliance systems and their operational status, and to confirm that rules are thoroughly promulgated and enforced. In addition, we conduct checks of the readiness status of internal reporting systems, as a means for quickly discovering the possibility of violations. From fiscal 2015 to fiscal 2016, we conducted on-site audits at almost all overseas group companies. We will continue to conduct education and audits both in Japan and overseas and will enforce the strict observance of competition law.
Policies Regarding Taxes
The NGK SPARK PLUG Group has set a compliance policy by which we recognize that we are a member of society, and, with understanding of the spirit and the purpose of laws and ordinances, respond appropriately to the demands of society and aim to become a company trusted by the international community. We also undertake the payment of taxes on the basis of this policy and in accordance with the following principles.
- The Group will fulfill its social responsibilities by observing laws on corporate taxation and other tax laws in every country, as well as international taxation standards including the OECD Transfer Pricing Guidelines and the Action Plan on Base Erosion and Profit Shifting.
- In order to ensure compliance with the above laws and ordinances, our Group will work toward improving our knowledge of, and correct understanding of taxation, and to enhance reliability and transparency with an attitude of sincerity toward tax authorities.
- The Group will properly manage taxation risks by working toward appropriate declaration and payment of taxes in each country, thereby enhancing shareholder value.