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Basic approach to compliance

We believe that earning the trust of society is essential for us to contribute to the realization of a sustainable society and to continue to be a company needed by society. Accordingly, we are placing importance on compliance in our Management Policy. We formulated the Business Code of Conduct to specify the policy of actions which officers and employees should observe so that we can conduct business activities in accordance with laws and regulations and generally accepted standards and practices in each country, and our internal rules. We have also established and have been operating the compliance promotion structure that includes rules related to compliance, a whistle-blower system, the Compliance Committee, and the Fair Trade Monitoring Committee.

Promotion structure

We have established and have been operating the Compliance Committee and the Fair Trade Monitoring Committee to promote compliance through the activities of both committees. (See Overview of the Committees.)
Aside from the efforts made by the two committees, the Legal Department conducts the rank-based training and the topic-specific training for officers and employees as part of compliance-related educational and awareness-raising activities. In addition, we hold a group training session for Compliance Promotion Activity Supervisors in Japan once a year. By sharing information and exchanging opinions on important issues, we are enhancing the promotion activities at each business site and providing support for the initiatives at each business site. Furthermore, with regard to activities for global compliance risks such as corruption prevention, we regularly exchange information and opinions with the Administration & Internal Control Department at each Office of General Manager in five overseas regions and legal/compliance departments of overseas subsidiaries, thereby confirming each other’s ongoing activities and setting new agendas.
In addition, we have established the Fair Trade Promoting Group in Legal Department of an overall supervisory department for compliance with antimonopoly law. Under the direction of the Fair Trade Monitoring Committee, the Group conducts various activities (such as education, instruction and audit) for relevant divisions. Additionally, overseas subsidiaries are monitored for the implementation status of compliance with antimonopoly law in cooperation with the Administration & Internal Control Department at the Office of General Manager in each region.



Major actions to enhance compliance

Category Actions Commencement (YYYY/MM)
Development of Structures/Policies/Rules Internal rules on security trade control are established 1993/12
Helpline (whistle-blower system) is established and implemented 2003/04
“Business Code of Conduct” is established 2003/05
“Business Code of Conduct Guidebook” is distributed (revised in 2018) 2003/05
“Helpline Management Regulations” is established 2006/11
Fair Trade Promoting Department (currently the Fair Trade Promoting Group, Legal Dept.) is established 2012/04
Internal rules on antimonopoly law compliance such as “Fair Trade Management Rules” are established 2012/04
Fair Trade Monitoring Committee is held 2012/05
“Five Principles to Prevent Cartels” is formulated and its handy cards are distributed 2012/08
“Antimonopoly Law Compliance Handbook” is distributed (revised in July 2016) 2012/12
CSR Global Meeting is held 2015/01
Rules for management of compliance promotion activities are established 2015/04
Compliance promotion activity supervisors are appointed 2015/04
Compliance Committee is held (twice a year) 2015/04
“NTN CSR Procurement Guidelines” for business partners, including compliance contents are issued 2016/04
July 26 is designated as “Compliance Day” and a message from President is delivered to all NTN Group employees (once a year). 2016/07
Internal rules on bribery prevention are established 2017/04
Internal procedures on bribery prevention (management of provision of property or profit) are introduced 2017/04
Internal procedures on bribery prevention (intermediary control) are introduced 2019/04
Internal procedures on bribery prevention (management of receipt of property or profit) are introduced 2019/08
“Helpline Management Regulations” are revised in line with the implementation of the amended Whistleblower Protection Act 2022/06
Educational / Awareness-raising activities Legal Information Newsletter is issued 1997/01
Topic-specific training (such as antimonopoly law compliance, bribery prevention, security trade control and harassment prevention) for important departments which especially need to be familiar with by the Legal Dept., etc. is implemented (as needed) 2012/01
Topic-specific training (such as antimonopoly law compliance, bribery prevention, security trade control and harassment prevention) for Operating Officers is implemented (as needed) 2012/08
Rank-based compliance training for new managers, new employees, etc. by the Legal Dept. is implemented (as needed) 2015/04
Original compliance training for each business site by compliance promotion activity supervisors is implemented (as needed) 2015/04
Mass training meeting for compliance promotion activity supervisors, and persons in charge by the Legal Dept. is implemented (once a year) 2015/04
Compliance training programs by Legal Department for president of each subsidiary are conducted 2015/12
NTN’s Compliance, which is a database for sharing compliance related information, such as compliance-related incidents and introduction of compliance promotion structure is operated 2016/08
E-learning program about corruption prevention and antimonopoly law is implemented (once a year) 2017/04
Audit/Monitoring activities Self-audits and internal audits on security trade control are conducted 1995/10
Compliance awareness survey is conducted 2008/9
Audits on antimonopoly law compliance are implemented 2012/11
Survey of Compliance awareness toward president of each subsidiary is conducted 2017/04
Audits on rules for corruption prevention are implemented 2018/05

Business Code of Conduct

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.

  1. Compliance with laws and norms
  2. Pursuit of quality and safety
  3. Compliance with antimonopoly laws
  4. Fair trade with suppliers
  5. Honoring agreements
  6. Refusal to engage in improper conduct with business partners
  7. Proper labeling and specification
  8. Respect for intellectual property rights
  9. Proper control of confidential information
  10. Ensuring security by strengthening export controls
  11. Compliance with industrial laws
  12. Compliance with corporate accounting principles
  13. Compliance with international rules
  14. Promotion of environmental preservation
  15. Positive contribution to society
  16. Compliance with labor-related laws and company work rules
  17. Realization of a safe and positive work environment
  18. Respect for human rights
  19. Prohibition of sexual harassment
  20. Proper control of information about individuals
  21. Strict distinction between public and private matters
  22. Confronting harmful social forces
  23. Proper utilization of our information system
  24. Prohibition of insider trading
  25. Self-restraint regarding entertainment and gifts
  26. Lawful donations/political donations

Internal corporate culture survey

As part of its fraud prevention activities, the Group has investigated employee evaluations for the attitudes of the presidents of affiliated companies and their corporate culture related to compliance, since the fiscal year ended March 2018.
It is said that there is a high probability of occurrence of fraudulent acts in a company when motives/pressures, opportunities, and rationalization triangles are formed. While advancing the development of regulations, rules, and penalties, it is important to develop an internal corporate culture and environment. Therefore, we regularly confirm changes in the organizational culture of affiliated companies through employee evaluations.
By disclosing the results of this survey to the presidents of affiliated companies, we are making use of the results to create an internal corporate culture of not being motivated to conduct fraudulent acts, based on the awareness that fraudulent acts are constantly seen within the company and at the head office. Also, such results are used to create better relationships with employees.
In the fiscal year ended March 2023, we conducted a survey of approximately 680 employees of 12 affiliated companies (6 in Japan and overseas, respectively) where a change of the president or other event occurred.

Ratio of employees who evaluated the attitudes of the presidents of affiliated companies as “good” (average)

Ratio of employees who evaluated the attitudes of the presidents of affiliated companies as “good” (average)

Corruption prevention initiatives

Initiatives in Japan

We have established and have been applying in-house rules and regulations based on domestic and overseas anti-corruption laws and social norms. Our in-house rules and regulations not only prohibit bribery from and 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 rules and procedures to prevent bribery via our business partners. In addition, under the circumstance that some countries even impose restraints on the transfer of property or profit between private companies, we have established rules and procedures for the receipt of property or profit in order to prevent bribery by our officers and employees, to thoroughly ensure the conduct of fair trade, and to prevent our officers and employees from engaging in conflicts of interest. Furthermore, we have made it a policy to refuse to receive gifts and entertainment from our business partners in principle. We conduct in-house training and e-learning programs to raise awareness of the contents of our in-house rules and regulations, and conduct self-audits once a year to ensure thorough awareness of the anti-corruption rules and regulations. Domestic subsidiaries have also established and have been applying their own internal regulations that are consistent with the Company’s policies.

Overseas initiatives

Our overseas subsidiaries have developed and have been operating in-house rules and regulations that are localized to reflect relevant laws, regulations, and generally accepted standards and practices in each country. They also conduct audit activities related to these rules and regulations as needed. The Legal Department is regularly sharing information and exchanging views with the Administration & Internal Control Department at the Office of General Manager in each region on related initiatives, and maintaining and managing a structure in which the Group unites as one to prevent bribery.

Helpline (whistle-blower system) and educational activities

In Japan, the whistle-blower system called Helpline has been established within and outside the Company and has been operated as a contact point for providing consultation regarding violations of laws, Business Code of Conduct, and in-house regulations. Helpline provides consultation for cases such as suspected violations of labor-related laws, including harassment, as well as violations of in-house regulations, and conducts investigation in accordance with Helpline Management Rules that stipulate ensuring the confidentiality and prohibition of detrimental treatment against the whistle-blower and collaborators of the investigation. Through provision of information in various compliance training sessions and in the Code of Conduct Guidebook, we have established a structure where all employees can utilize Helpline, not only as a tool to report misconduct, but also as a means of raising questions and expressing opinions and complaints regarding the Business Code of Conduct, and maintaining satisfactory relationships between the company, officers, employees, and business partners. In 2022, we revised our Helpline Management Rules in line with the implementation of the amended Whistleblower Protection Act. According to the purpose of the act, we are performing proper operations, such as increasing persons eligible for protection and strengthening protection. Whistle-blower systems are being progressively created and operated also in overseas regions, where they are tailored to local needs and circumstances.

Helpline (whistle-blower system) and educational activities

Compliance awareness survey

We continuously survey compliance awareness once a year to evaluate the results of compliance-related educational and awareness-raising activities and the level of understanding of the Business Code of Conduct. We also extract issues in our activities to help enhancing compliance promotion activities for the next term.

Activities on “Compliance Day”

In 2016, we designated July 26 as “Compliance Day”, on which efforts are made to further raise employees’ awareness of compliance in the form of the President delivering a message about the importance of compliance in business activities to all NTN Group employees.

Antimonopoly law compliance initiatives

We regard any antimonopoly violations represent a potential risk for the whole Group and are engaged in various initiatives to ensure thorough antimonopoly compliance.

(1) Raise employee awareness routinely

Our “CSR Policy” and “Business Code of Conduct” specify our basic policies on compliance with the antimonopoly laws. In August 2012, we established the “Five Principles to Prevent Cartels” as conduct guidelines required to prevent antimonopoly violations as well as to protect employees therefrom. We seek to raise awareness of compliance among employees by distributing handy cards displaying these five principles. In December the same year, we distributed the “Antimonopoly Compliance Handbook” with the aim of helping employees better understand the various rules on antimonopoly compliance. In July 2016, we revised it adding a set of specific prohibited behaviors. In addition to being distributed to employees, this is used as a learning tool.

(2) Prevent and monitor contacts with competitors

Any officer or employee who might potentially contact competitors at an exhibition or meeting or any other event is obligated to apply for permission in advance and/or report it subsequently. This means we have in place a system with which we can identify the status of contact by officers and employees with competitors.

(3) Educate

We implement training programs continually for the purpose of further raising the awareness of officers and employees regarding compliance with antimonopoly law.
We will continue to enhance the content of training programs in order to ensure fair and free competition.

[Major training sessions on compliance with antimonopoly law for the fiscal year ended March 31, 2023]

  • Training programs on compliance with antimonopoly law for sales personnel
  • Rank-based training on compliance with antimonopoly law (provided to new managers and new employees regardless of job category and business unit)
  • Training programs on antimonopoly law in Overseas Regions

(4) Audit

Regular audits are conducted in order to ascertain and evaluate the situation to see if the antimonopoly laws are being complied with properly in the NTN Group pursuant to relevant laws and regulations as well as internal rules.
In Japan, “self-audits” by business unit heads under the instruction of the Legal Department and “internal audits” by the Internal Audit Department continue to be conducted. In the fiscal year ended March 31, 2023, 20 departments in Japan were audited. (For details of the Subcontracting Act compliance activities, see here.)
Turning to overseas regions, the Administration & Internal Control Department in each region instructs self-audits to be conducted, and conducts internal audits regularly.
Although no serious violation was detected by the audits, we will make improvements on the points cited in the audits in an effort to further enhancing our antimonopoly law compliance system.