Each and every employee strives to conduct in accordance with compliance.
Initiatives for compliance
At NHK Spring, we affirm at the very top of our Group management policy that “Compliance and trust are the root of survival.” While we naturally comply with the law, we also respond in earnest to the various demands society places on us, making compliance a major element of how we do business.
Specifically, the company president himself visits our plants regularly, working to foster awareness in all opportunities for conversation by directly impressing upon our employees the crucial nature of compliance.
Our Employees Code of Conduct stipulates that all corporate officers and employees are to comply with laws, regulations and corporate ethics. In order to spread this ethical knowledge, we administer various forms of training for employees of both domestic and overseas Group companies, including addresses by the company President regarding compliance with antitrust laws and bribery prevention, etc. We regularly distribute compliance news and publish a message from the President every November in the NHK Spring Ethics Monthly as part of our overall endeavor to shine a light on compliance throughout the entire Group. We engage in this work not just at our Japanese affiliates, but worldwide, through efforts such as displaying posters and planning various events to raise compliance awareness in the workplace.
Compliance promotion framework
Under the supervision of the President & Chief Executive Officer, who bears ultimate responsibility, the Chief Corporate Officer of the Corporate Planning & Control Division serves as CSR Committee Chairperson, while the leader of each department serves as a departmental Compliance Officer. A CSR Department established within the Corporate Planning & Control Division acts as the promotional secretariat to realize compliance management.
Framework with respect to antitrust laws
In 2016, NHK Spring underwent an on-site search by the Fair Trade Commission on suspicion of violation of the Antimonopoly Act. In order to apply the lessons learned from this experience to our global compliance with antitrust laws, we administer annual antitrust law training for all sales department employees.
In fiscal 2019, we held a total of 15 in-person antitrust law trainingsessions at domestic business sites, while also administering comparable training at group companies in the United States and Europe. We also hold e-learning courses for employees at NHK Spring and our domestic Group companies.
In-person antitrust law training sessions at NHK Spring
To help create workfriendly work environments, we administered e-learning with regards to harassment in fiscal 2019.We also distributed a “Guidebook on Preventing Abuse of Authority” to all employees as part of our efforts to create workplaces free of harassment.
| Fiscal 2019 e-learning course attendance rate:100 %
[Total attendees: 3,146]
Whistleblowing system (Compliance Hotline) /
Supplier Reporting Contact Point
We have established a system for employees of NHK Spring as well as Group companies in Japan to consult about and whistleblowing their concerns. We have put in place a Compliance Hotline to handle reports anonymously with the internal legal department and external legal firms with no conflicts of interest with the company. As part of our efforts to disseminate existence about our internal reporting system, we distribute compliance cards that include the contact information for this hotline, while including the contact information in various compliance training sessions and in compliance news distributed on a monthly basis.
We are also introducing this same system at overseas Group companies, including those in North America, China, and Mexico.
Our company website includes on its top page a “Reporting Contact Point for Suppliers,” enabling suppliers to make a report in the event that any compliance violation were to occur in a transaction with our company
|Fiscal 2019 Compliance Hotline case count:42
[NHK Spring Group]