The NGK Group realizes that entrenching and ensuring compliance is critical to raising corporate reliability, and the CSR Committee’s Compliance Subcommittee plays a central role in compliance education and awareness.
In fiscal 2010, we sent out a survey to gauge compliance awareness among all employees, including temporary and part-time staff , at NGK and domestic Group companies. The survey was also taken by employees from NGK on loan to overseas Group companies. Over 80% of those targeted responded. Once analyzed, the results revealed that awareness around compliance has increased steadily since the previous survey was conducted in fiscal 2008.
Furthermore, we worked to gain a shared awareness of the issues surrounding greater propagation of compliance within the Group through a series of dialogues with management-level staff in each division.
Mizuho, an internal bulletin used for in-house education and training
In fiscal 2010, more than 1,350 people took part in six Legal Compliance Liaison meetings, where a wide range of workplace managers were provided legal explanations and case studies on compliance. Lectures on anti-monopoly laws led by outside instructors were also conducted in the vicinity of our head office and at our headquarters in Tokyo. The well-developed educational content of the training included the use at certain times of videos showing everyday examples of compliance issues.
Compliance education for regular employees incorporates group debates as part of position-based training. Training for staff members scheduled for assignment overseas focuses on anti-monopoly and competitionrelated laws, and has seen the adoption of curriculums tailored to China, Mexico and other regions in an eff ort to approach compliance issues more meticulously. Internal bulletins, meanwhile, off er intuitive explanations of the basics of Japan’s Subcontract Act and the execution of contracts. In these and other ways, compliance-related awareness and mechanisms are being broadly embedded throughout the Group.
For domestic Group companies, in addition to requesting the participation of supervisory personnel in Legal Compliance Liaison meetings, the NGK Legal Aff airs & Intellectual Property Department, among other tasks, provides individualized instruction on laws and regulations relevant to business transactions.
To strengthen legal risk management in overseas Group companies, NGK continues to operate a periodic reporting system launched in fiscal 2009, under which all Group companies report and share information on the state of their legal risk management responsiveness every six months.
In fiscal 2011, we will move to enhance compliance education further among domestic Group companies. Lectures on EU competition law are also scheduled for supervisory personnel at Group companies in Europe.
A helpline card
To ensure compliance with laws, internal regulations and corporate ethics, NGK has established a helpline system as a compliance aid for directly accepting consultations and reports from NGK Group and domestic Group company employees (excluding those at listed firms) and other concerned parties.
To ensure eff ective operation of the helpline, the Company has arranged to provide protection for those seeking consultation, extensively guarantee fairness of procedures, and facilitate access by preparing five points of contact, including an outside lawyer and a consultation channel exclusively for women.
All employees eligible to use the helpline are issued a helpline card, and we consistently strive to deepen employee understanding of the system. At overseas Group companies, since fiscal 2008 we have established and operated individualized systems or provide alternative measures that comply with local laws and other requirements. In fiscal 2010, NGK’s Legal Aff airs & Intellectual Property Department conducted a follow-up on the operational status of the helpline and measures, in consideration of the unique customs and diff erences in awareness present in each country.
