The NGK Group considers the establishment and implementation of a compliance system to be an important management policy, and the CSR Committee’s Compliance Subcommittee plays a central role in compliance education and awareness efforts. Principal among these efforts are Anti-monopoly Law lectures attended by employees as well as executive managers and Legal Compliance Liaison Meetings, where legal explanations are provided and case examples introduced to workplace managers from a wide range of Group organizations. The Group also conducts position-based training programs for new hires, regular employees and middle managers to inculcate a compliance mindset, and enable them to acquire required knowledge.
Training in the European Community Competition Law was conducted in Germany in September 2008. Frontline sales managers and sales representatives from Group companies in the U.K., France, and Germany participated to gain a deeper knowledge of these laws.
A company seminar about the European Community Competition Law (Germany)
To consolidate legal risk management in Group companies outside Japan in concert with international sales expansion, from fiscal 2007 through fiscal 2008, the Company conducted a fact-finding study of legal affairs management at each company. In this way, the Company defined the roles Head Office and the local Group companies should play in various legal affairs and instituted periodic reporting to Head Office on the state of legal risk management. The Company will continue to promote cooperation between Head Office and local Group companies and enhance systems for appropriately and promptly responding to legal risks.
To deal with violations of laws, internal regulations or corporate ethics that cannot be resolved within the organization, the NGK Group has established a helpline system as a compliance aid for directly accepting consultations and reports from concerned parties.
To ensure effective operation of the helpline, the Company has arranged to provide protection for those seeking consultation, guarantee fairness of procedures, and facilitate access by preparing five points of contact, including an outside lawyer and someone who specializes in consultation with women.
In November 2008 the Company conducted a Compliance Awareness Questionnaire Survey, which covered all officers and employees of NGK and Group companies in Japan (including temporary workers, part-time workers, and employees seconded to overseas Group companies). We have aggregated and analyzed the results and are using the findings to develop measures for future helpline operation and compliance assurance.
A helpline card
To contribute to the maintenance of international peace and security and prevent the spread of weapons of mass destruction, the NGK Group has organized the Security Export and Specified Export Control Committee and strives to reliably comply with laws and regulations related to export security. In fiscal 2008 overseas Group companies further strengthened their export security posture by preparing compliance manuals, providing more rigorous education for employees taking up new posts, and other measures.
In December 2008 the Company obtained authorized exporter approval from Nagoya Customs. This authorization is granted to business operators that have put in place integrated security controls covering operations, sales, and exports and established compliance systems. This authorization has made it possible to perform export application procedures at NGK warehouses and other locations and to rapidly and smoothly load export cargo. These efficiency improvements can be expected to reduce lead times and logistics costs.
