Compliance

In NHK Spring Group, we regard compliance as an important foundation for contributing to the realization of a sustainable society through manufacturing. The NHK Spring Group's management policy begins with the statement, "We will maintain an upstanding attitude in business”. In addition to legal compliance, we believe that compliance includes adherence to our Employees Code of Conduct, Company Rules, and social norms (manners and morals) and fulfillment of our social responsibility (CSR) to our stakeholders, including customers, shareholders, business partners, and local residents, and we regard it as one of the major pillars of management. In promoting compliance, specifically, the President himself directly calls out the importance of compliance and high ethical standards in every dialog with the top management and employees of each Group company to foster awareness.
In addition, our Employees Code of Conduct stipulates that all officers and employees are to comply with laws, regulations, and corporate ethics. To raise awareness of this, we send out top management messages on compliance with antitrust laws, anti-bribery, etc. To instill compliance, we conduct compliance training by rank for new employees and promoted employees at all Group companies, as well as various training programs on themes such as compliance with antitrust laws, harassment, etc. Moreover, each month we select a familiar compliance theme and distribute the "Compliance Newsletter" to raise awareness among all employees of the NHK Spring Group, both in Japan and overseas, of the importance of compliance with laws, regulations, and corporate ethics. 

Under the supervision of the President & CEO, the Director of the CSR 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 CSR 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.

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 awareness survey in FY2022: 8,421)

 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 using AI (artificial intelligence) to check for problematic behavior before it occurs.

To realize the Group's management policy of "Build a safe and secure company and a rewarding and comfortable workplace”, we conducted harassment training throughout the Group in FY2021 and again in FY2022. This training was mainly intended to promote a correct understanding of harassment and to foster awareness of compliance with a view to creating a safe and secure Company and rewarding and comfortable workplaces.
We also conduct compliance training and e-learning using the "Guidebook for Prevention of the Abuse of Authority", which is distributed to all Group employees. In addition, the Company conducts educational activities to prevent harassment, such as disseminating information on good communication in the Compliance Newsletter.

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. Moreover, all employees receive a compliance card that states the Compliance Hotline number, and we are striving to ensure the reliability of the system through implementing various compliance training sessions and issuing the monthly Compliance Newsletter and internal magazines to inform employees about the operational flow of whistleblowing from the receipt of reports, the guarantee of anonymity, and the prohibition of prejudicial treatment against whistleblowers. 
In the event where a whistleblower makes a report, the Company reports the matter to the Compliance Promotion Manager and conducts an investigation to confirm the facts. If a problem is confirmed to exist, corrective measures are taken and the whistleblower is briefed on the response if he or she desires feedback.
In addition, the Company has a system in place for appropriately reporting to the Board of Directors on serious matters.
Overseas, similar systems have been introduced in North America, China, Thailand, Mexico, and other Group companies.
In addition, we have set up a "Partner 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 Reporting Desk reports: 0

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.

In response to a worldwide strengthening of laws and regulations concerning security export control, NHK Spring Group has formulated security export control regulations and detailed rules to ensure compliance with security export control-related legislation, and have appointed a person in charge of export control in each production division to provide training. In addition, the Company conducts compliance inspections for export transactions and takes steps toward realizing appropriate import/export control.