Compliance

Compliance enforcement is a top priority for the company. Our definition of compliance extends to conforming with generally accepted standards and practices, obeying all applicable laws and following in-house regulations. We have created a system for enforcing compliance on a global scale.
In April 2015, we created a set of rules for compliance promotion activities along with a Compliance Committee that has subsequently met periodically to work on compliance enforcement and improvement. Among the Global Risks selected by the Risk Management Committee, the Compliance Committee handles compliance risks that could lead to legal violations.
Committee members propose and implement policies for risk mitigation in collaboration with compliance promotion activities supervisors at domestic business units and the Internal Control Sections within each Office of the General Manager in five overseas regions. The nature and progress of these activities are reported to the Board of Directors. A whistle-blower system called Helpline has also been created to reduce compliance risks.

■Japan

We enforce in-house regulations created to reflect domestic and overseas anti-corruption laws and generally accepted standards and practices. They prohibit bribery, and set forth the rules and procedures to use when officers or employees are to provide property or profit to domestic or overseas public officials or trading partners. We also carry out rule-based audits, and are creating rules for preventing corruption among business partners.
Our domestic subsidiaries are each creating their own regulations while maintaining consistency with company policies.

■Overseas regions

Our subsidiaries in the China region enforce in-house regulations created to reflect China’s anti-corruption laws and generally accepted standards and practices. They set forth the rules and in-house procedures to use when property or profit are given to or received from public officials or trading partners. Audits are also being done to check enforcement.
ASEAN region subsidiaries have started to enforce in-house regulations localized for each country and created to reflect the applicable local laws and generally accepted standards and practices. Regulations for Thailand went into effect in June 2017, followed by regulations for Singapore and India.
Subsidiaries in the regions of Europe and the Americas are also progressively creating rules reflecting applicable local laws and generally accepted standards and practices.

■Preventing accounting misconduct

Audits are carried out in conformance with an annual accounting plan established for domestic and overseas subsidiaries.

■ Preventing labor law violations

Stricter methods have been applied by establishing new rules for time management and adopting new systems. Use of these rules and systems is checked on an ongoing basis. Comprehensive Personnel department site checks and in-house broadcasts ensure employee awareness on designated no-overtime days.

Compliance training

■Rank-based training

Separate training programs covering all areas of compliance are provided to employees of different ranks such as recent-graduate new employees, mid-career new employees and new managerial-level employees. Training for new managerial-level employees is designed for application to compliance enforcement in the workplace. Employees are provided with texts and study independently, taking e-learning-based comprehension tests. They are required to retake these tests until they pass, helping solidify their knowledge.

■Business unit-specific training

Priority topics are set for each business unit, and the unit’s compliance promotion activities supervisor provides separate training for each. Supervisors and staff take part in a mass training meeting held at the headquarters once a year. The event helps shape activities by providing opportunities to discuss and share information about issues in our group compliance work, and training activity topics and content.

■Topic-specific training

Applicable departments are periodically given individual training on specific topics such as Antimonopoly Act compliance, corruption prevention, security trade control and harassment prevention. We also create and administer training programs whenever needed, such as compliance training for CEOs of domestic and overseas subsidiaries.

■Training in overseas regions

In the overseas regions, the Internal Control Sections oversee the creation and administration of training activities tailored to local characteristics and needs while ensuring consistency with the company’s policies. One area of focus is corruption prevention, for which training is provided online and through a number of other training activities. The overseas regions have made varying degrees of progress in creating rules, so the training is tailored to the amount of progress attained in each case.

Compliance Day message from the President

NTN has held a Compliance Day on July 26 every year since 2016. The day is an opportunity to think about the importance of compliance (corporate ethics) aiming for our vision of the company, which brings sustained growth over our next 100 years. The day features a message from the President to all Group employees. It covers our work on Antimonopoly Act compliance and corruption prevention, as well as our continued groupwide compliance enforcement efforts at business sites engaging in R D, technology, manufacturing and quality operations.

Compliance awareness survey

We conduct an ongoing compliance awareness survey once every year to assess how effective education and awareness-raising activities have been and how well the Business Code of Conduct has been absorbed. The surveys let us identify issues to work on, and are used to enhance the compliance activities for the following year.

Compliance database “NTN’s Compliance”

NTN’s Compliance is a database for sharing compliance-related information. It is used to present compliance-related incidents arising within our group.

Legal Information Newsletter (monthly)

Raises employee awareness of legal issues by presenting up-to-date information on the latest compliance and legal trends, along with examples of legal violations.

Our domestic business units have created a Whistle-blower system called Helpline with both in-house and outside contact points. Employees can use the system to voice various concerns related to infractions of laws, Business Code of Conduct or in-house regulations. The discussion topics cover harassment, corruption and breaches of the Antimonopoly Act. Issues raised at Helpline contact points are reported to company committees while upholding the company’s duty to maintain confidentiality. Compliance-related issues are reported to the Compliance Committee. Issues related to laws on competition (Antimonopoly Act and Subcontracting Act) are reported to the Fair Trade Monitoring Committee. A report on the system’s operation is also provided to the Board of Directors (once a year). Whistle-blower information is used in the activities of the two committees and helps improve the our group-wide compliance work. To encourage employees to use the system, information on the Helpline contact points is provided in compliance training information and CSR guidebooks, and posted on our intranet. Whistle-blower systems are being progressively created and operated also in overseas regions, where they are tailored to local needs and circumstances.

To ensure compliance with the Antimonopoly Act and Subcontracting Act, the Fair Trade Promoting Department undertakes most activities under the guidance of the Fair Trade Monitoring Committee. The Committee is chaired by the President and reports directly to the Board of Directors.
The Fair Trade Promoting Department organizes awareness-raising activities such as internal training and e-learning programs. It also creates a system for keeping abreast of all contact with competitors through measures such as self-audits for Antimonopoly Act compliance and prior applications for preventing and monitoring competitor contact. The Department’s main awareness-raising activities in the fiscal year ended March 31, 2018 were (1) an Antimonopoly Act compliance training course (August, 379 trainees), (2) a compliance training course for sales staff (January, 585 trainees), and (3) an Antimonopoly Act e-learning program (November to December, 1,430 trainees). We have held a Compliance Day on July 26 every year since 2016. A special message from the President on this day gives employees the chance to reaffirm the importance of compliance.
Working with the Internal Control Section for each overseas region, the overseas business units have also created systems for activities such as locally led training, prior applications and self-audits. They have created legal compliance systems adapted to local laws on competition.