Compliance

In NHK Spring Group, we regard compliance as a vital foundation and cornerstone for contributing to the realization of a sustainable society through manufacturing. Beyond compliance with laws and regulations, we consider adherence to the Employee Code of Conduct, company rules, and social norms (manners and ethics) as essential to fulfilling our social responsibilities to stakeholders and building relationships of trust. We are therefore committed to raising employee awareness and preventing misconduct before it occurs.

Under the supervision of the President, the Director of the Legal Department in the Corporate Planning and Control Division has been appointed as the person responsible for promotion, with the directors of each department responsible for providing guidance and the Legal Affairs Department acting as the promotion secretariat. In addition, the Company systematically conducts compliance education and awareness-raising activities to prevent the occurrence of legal violations and antisocial behavior.

As a mechanism for employees of the Company and its domestic subsidiaries to consult or report internally when they have questions or doubts, a Compliance Hotline, which allows anonymous reporting, has been established at a contact point operated by an external third-party organization from the viewpoint of neutrality and impartiality. 

In the event where a whistleblower makes a report, the Company reports the matter to the Compliance Promotion Manager and conducts an investigation to ascertain the facts. If a problem is confirmed to exist, corrective measures are taken and the whistleblower is briefed on the response if they desire feedback. In addition, the Company has a system in place for appropriately reporting to the Board of Directors on serious matters. 

At global locations, similar systems have been introduced in overseas Group companies including those in North America, China, Thailand. In addition, we have set up a "Partner Compliance Reporting Desk” on our website for business partners to report any compliance violations in the course of doing business with us. The Company has established a system for realizing the early detection and correction of problems by appropriately handling reports that are made to these contact points. 

Partner Compliance Reporting Desk - number of reports: 0

Every November, which is designated as the "Month for Strengthening Ethical Values", the Group's top management sends out messages and displays posters. As one initiative in this, since FY2021, the Company has conducted a Compliance Awareness Survey of employees in NHK Spring and domestic Group companies. The results of these checks are reported to top management and fed back to the Group companies and divisions. Moreover, the degree of penetration of compliance awareness is confirmed and, based on the results, a compliance activity plan for the next fiscal year is formulated.
(Number of respondents to the Compliance Awareness Survey in FY2024: 8,751)

NHK Spring is continuously implements training and awareness-raising activities for its employees. In addition to the training listed in the table below, we also disseminate a monthly Compliance newsletter and designate November as the “Month for Strengthening Ethical Values”. We also disseminate messages from top management in multiple languages, post posters, and take other dissemination measures. Through these initiatives, we aim to raise the awareness of each and every employee.

In 2016, the Company received an on-site inspection by the Fair Trade Commission and other authorities for violating the Antitrust Act. Learning from this lesson, we have been conducting annual antitrust law training for employees in sales departments without fail to ensure compliance with antitrust laws globally. Overseas, we also offer training programs with content that is consistent with local activities. In addition to the above, we conduct e-learning on antitrust law, implement and check preliminary notifications throughout the Group when coming into contact with competitors, and conduct e-mail audits to check for problematic behavior before it occurs. 

The "NHK Spring Group Human Rights Policy” states that “We do not tolerate any form of harassment”. By implementing training, distributing guidebooks, and providing e-learning, we are cultivating employee awareness and creating a safe and secure Company and a workplace that is both rewarding and easy to work in.

Under the Employee Code of Conduct, Compliance Regulations, and Anti-Bribery Rules, the Group has defined bribery, corruption, and improper donations as prohibited acts, and has conducted training on bribery, particularly in high-risk areas overseas. In addition to prohibiting bribes to public officials, we also send out compliance newsletters to promote awareness about the prohibition of excessive business entertainment and gifts that go beyond social common sense, even among private companies. 
To further strengthen the NHK Spring Group’s initiatives, we revised the NHK Spring Group Anti-Corruption Policy in April 2024 and established the NHK Spring Group Guidelines for Entertainment and Gift-Giving in August. These Guidelines, under the framework of the Anti-Corruption Policy, clearly define prohibited acts related to bribery, serve as a code of conduct to guide employees in making fair and honest decisions, and aim to prevent violations in advance through the establishment of rules for entertainment and gifts, as well as through approval and record-keeping procedures. 

(Structure of the Guidelines)
1 About the NHK Spring Group Guidelines on Entertainment and Gifts
2 Definition of Terms
3 Prohibition of Bribery and of Entertainment/Gifts Beyond the Scope of Social Courtesy
4 Procedures and Criteria for Preventing Bribery
5 Penalties and Disciplinary Actions for Bribery
6 Reporting to the Company
7 Implementation of Regular Training and Audits

In response to the global strengthening of laws and regulations concerning security export control, the NHK Spring Group has established Security Export Control Regulations and Detailed Rules to ensure compliance. Under the supervision of the Export Control Headquarters, export control departments have been set up within each production division, and necessary training is provided. In addition, export transactions are subject to classification determinations and transaction reviews, ensuring that appropriate export control measures are implemented.