Compliance

We have in place the Compliance Committee and the Fair Trade Monitoring Committee.
The Compliance Committee handles the global compliance risks excluding those relating to Antimonopoly Act and Subcontracting Act. The committee members propose and implement policies for risk mitigation, in collaboration with compliance promotion activities supervisor who is appointed at each domestic business unit, and the Internal Control Section which is established at each Office of the General Manager in five overseas regions. The details of these activities are reported to the Board of Directors.
The Fair Trade Monitoring Committee, chaired by President, Executive Officer, discusses implementation plans and reports of antimonopoly and Subcontracting Act compliance activities. Additionally, we established the Fair Trade Promoting Department in CSR Headquarters as an overall management department for the antimonopoly compliance. Under the direction of the Fair Trade Monitoring Committee, the Fair Trade Promoting Department conducts education, instruction, audit and other activities for relevant divisions. Additionally, overseas subsidiaries are monitored for the implementation status of antimonopoly compliance in cooperation with the Internal Control Section, within Office of the General Manager in each region.
Also, the Legal Department works to enhance the promotion activities in each business unit by holding the mass training meeting for compliance promotion activities supervisors once a year, and sharing information and exchanging opinions on important issues. Furthermore, we hold the CSR Global Meeting in which persons in charge of compliance in domestic relevant divisions, mainly within the CSR Headquarters, and persons in charge of compliance in overseas regions participate. In the meeting, participants exchange information about compliance promotion activities to define new issues and mutually confirm the policy of activities.

■Structure

Actions to Enhance Compliance

The Business Code of Conduct stipulates the basic requirements for business activities that all NTN Group officers and employees in their operations must comply with.

From the fiscal year ended March 31, 2018, as a part of activities to prevent misconduct, we started a compliance awareness survey for employees of subsidiaries to confirm the stance of the president of each subsidiary on compliance.
In the fiscal year ended March 31, 2019, we conducted the survey for 2,100 employees in 48 domestic and overseas subsidiaries (an increase of 600 employees and two subsidiaries from the previous year). Also, we performed the survey for 1,300 employees in the manufacturing divisions of NTN Corporation, regarding the stance of each general manager of works and divisions on compliance.
Presidents and general managers who are subject to the survey are informed of the survey results so that they become aware of the fact that they are always monitored in the company, leading to create culture that does not tolerate any act of misconduct.
We also utilize these survey results of internal audit, and will continuously conduct these survey of prevent misconduct.

The whistle-blower system called Helpline is established in domestic business units 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. Issues raised through contact points will be investigated in accordance with Helpline Management Rules. Through the introduction in various types of compliance training, the Business Code of Conduct guidebook, and intranet, we have developed a structure where all employees can openly utilize the Helpline not only as a means of reporting of misconduct, but also as a means of raising questions, opinions, and complaints about the observance of the Business Code of Conduct, and maintaining satisfactory relationship between the Company, officers, employees, and business partners. Whistle-blower systems are being progressively created and operated also in overseas regions, where they are tailored to local needs and circumstances.

We enforce in-house regulations created to reflect domestic and overseas anti-corruption laws and generally accepted standards and practices. In our in-house rules and regulations, they not only prohibit bribery from/to domestic and overseas public officials and business partners, but also specify the rules and procedures regarding provision of property or profit by our officers or employees, and the rules and procedures to prevent bribery via our business partners. In various countries, regulations against bribery have been increasingly tightened and some countries even impose restraints on the transfer of property or profit between private companies. Under these circumstances, in order to thoroughly ensure fair trade and prevent officers and employees from giving rise to conflict of interest situations, we have established the rules and procedures regarding receipt of property or profit, and make it a policy to decline the provision of entertainment and gifts from our business partners that exceed the bounds of common sense. We develop a structure to prevent bribery by implementing awareness-raising activities, including internal training and e-learning program as well as conducting self-audit regarding rules for prevention of bribery once a year. Our domestic subsidiaries also develop and operate their own regulations while maintaining consistency with our company policies.
Our overseas subsidiaries have developed in-house rules and regulations localized to reflect overseas relevant laws and regulations and generally accepted standards and practices in each country, and started to enforce such rules and regulations in stages. On top of that, we have worked to audit the operational status of rules and regulations and internal procedures in each region.