To effectively address diversifying risks, the NOK group promotes an organization-wide risk management system with the Risk Management Committee as its center.
Our Corporate Risk Management Office takes the initiative in building our crisis management system, setting the following basic policies:
- Give first priority to ensuring safety, protecting people and saving people's lives.
- In the event of a disaster in the local region, make proactive contributions to the reconstruction of the region as a member of the community.
- In an emergency, minimize the impact on our customers and other stakeholders by continuing business to the extent possible in order to fulfill our responsibilities.
To ensure quick information gathering in the event of a major disaster, we maintain a safety confirmation system and an emergency calling tree, and have emergency communication devices in place. We also store supplies necessary to resume business smoothly.
The Central BCM Committee was formed with the mission of establishing a more effective business continuity management (BCM) system based on our experience of past disasters. Under the initiative of the committee, we are planning and implementing group-wide measures in terms of facilities, systems and employee education, including reinforcing production facilities against earthquakes, strengthening product supply functions, reviewing the current business continuity plans and conducting projects that encourage the reform of employee awareness. Through all these endeavors, we maintain our robust business continuity system.
Information Security Measures
The NOK Group has established the NOK Group Basic Policy on Information Security to appropriately manage and utilize information received from customers, such as personal information and our company specific technologies. The Information Security Committee has been established across our group and is promoting activities systematically. In addition, we have established a system for identifying and responding to information security incidents involving leaks of important information, including customer and personal information.
In fiscal 2020, in response to the rapid expansion of telecommuting due to the declaration of a state of emergency, we took measures centering on the risk of information leakage when using systems from outside the company. We will place greater emphasis on responding to increasingly sophisticated and sophisticated cyber attacks and will continue to work to maintain and improve information security measures through the PDCA cycle.
Protection of Intellectual Property
Our Behavioral Guidelines Concerning Employee Compliance raise awareness among employees by providing precautions regarding adherence to laws related to intellectual property rights. This is one of our efforts to promote patent application and rights acquisition for our inventions. The Guidelines also advocate respect for intellectual property rights of third parties. The NOK Group endeavors to prevent infringement of other companies' patents through patent search.
To protect NOK's brands, we combat counterfeiting, even outside Japan, through our Anti-Counterfeit Committee. In FY2020, we uncovered 3 counterfeit factories in China and got 664 web pages selling imitation products taken down from online sales sites.
The NOK Group works to fight against bribery and corruption by stipulating the following in its Principles of Corporate Behavior: “We will engage in fair, transparent, and free competition and ensure appropriate transactions and responsible procurement. We also maintain a sound and proper relationship with political bodies and government agencies.”
Pursuant to the Principles, the Behavioral Guidelines Concerning Employee Compliance prohibit collusive relationships and corrupting behaviors involving business partners and public officials, including excessive entertainment and bribery. The guidelines also forbid embezzlement and misappropriation and other acts that may affect company profits. These rules are communicated to employees through providing education and distributing compliance handbooks to help them maintain a high level of awareness.
In the event of a violation of the Group's anti-corruption policy, the Risk Management Committee is primarily responsible for taking action. Information on violations of the anti-corruption rules can be shared via the whistle-blowing hotline.
The Internal Control Audit Committee conducts annual anticorruption audits and reports the results to the Board of Directors.
In FY2020, there were no violations across the Group.
The NOK Group established its Compliance Rules in 2006, based on the NOK Charter of Corporate Behavior, which stipulates the handling of compliance with laws and regulations as well as company rules and regulations. We have established the "Employee Compliance Action Guidelines" as a guideline to show the details of the guidelines in concrete terms. The guidelines are intended to ensure that all employees of the Group are fully aware of the matters that must be observed in their business activities.
Compliance education is provided for new employees and newly appointed managers. In addition, October of each year is designated as Compliance Promotion Month, and the company's compliance measures are regularly disseminated.
BEHAVIORAL GUIDELINES CONCERNING EMPLOYEE COMPLIANCE(Plan)
Respect for Human Rights, Prohibition against Discrimination and Harassment
- Diversity, character and personality must be respected, and there shall be no discrimination based on race, skin color, creed, religion, nationality, age, sex, sexual orientation, gender identity, place of origin, or bodily or mental handicaps. Moreover, such discrimination shall not be forgiven.
- There shall be no acts of harassment that negatively affect the workplace environment by impairing the dignity of, inconveniencing or threatening individuals, or the like. In addition, such harassment shall not be forgiven.
Fair and Appropriate Trade
- Attitudes toward agents and distributors
We should comply with laws including the Anti-monopoly Act, which regulates unfair transactions, in doing business with agents and distributors.
- Relationships with and attitudes toward competing companies
When we have contact and do business with competing companies, we shall comply with laws including the Anti-Monopoly Act, which prohibits unfair transaction methods. We should not criticize or defame competing companies and their products, nor illegally obtain confidential information about them.
- Relations with and attitudes toward vendors
When doing business with venders, we shall comply with laws including the Law on Subcontracting, and conduct fair and equal transactions with vendors.
- Prohibition against having a cozy relationship with business counterparts and bribery to public officers
We should not undertake any act that may bring an inappropriate relationship with business counterparts, such as giving/receipt of money, gifts, or entertainment, or other economic interests that are not in the range of socially accepted benefits, to/from business counterparts or their officers/staffs etc., or by asking them to stand surety for a debt.
Also, we should not bribe public officers or the like for the purpose of obtaining illicit gains in business.
- Attitudes toward agents and distributors
Regulations against Insider Trading
- If we learn of important unpublished facts about the Company (or its subsidiaries), the facts shall be strictly kept confidential until the facts are published, and stocks or the like of the Company shall not be traded.
- If we learn of important unpublished facts concerning competing companies or other entities such as customers (or its subsidiaries), the facts shall be strictly kept confidential until the facts are published, and stocks or the like of the competing companies and the customers etc. shall not be traded.
- When dealing in stocks of the Company, we must fully comply with all regulations, such as prior notification or the like stipulated in the “Regulations of Insider Trading.”
Export/Import Procedures (Security Trade Control)
- Exports and imports shall be conducted under proper procedures and declarations.
- We must not export or import contraband goods, or be involved in such activities.
- Exports and imports of regulated goods (goods or the like that require permission, approval, or notification) shall be conducted after undertaking the necessary procedures with the competent authorities.
Laws Related to Intellectual Property Rights
- When products are manufactured, sold, imported, or displayed, we much investigate whether the products infringe intellectual property rights owned by others, and confirm that such products do not infringe such rights.
- We must not undertake any act that infringes intellectual property rights owned by others, such as making copies of computer software without permission.
Severance of all relations with Antisocial Forces
- We shall not have any relation at all with antisocial activities and forces that threaten the lives of the public and business activities, or which interfere with economic activities.
- If we receive unlawful demands from antisocial forces, we must not make thoughtless compromises, such as by giving money.
Moreover, we must sever promptly the relationship, once it is found that the business counterparts are antisocial forces.
- We should not undertake any business with antisocial forces, even if the forces are legal.
- We should not make use of the influence of antisocial forces.
- We should comply with environmental ordinances and the Basic Policies on Environmental Conservation.
- We should recognize that efforts tackling environmental problems all have the common theme of working toward achieving a sustainable society, and we should proactively work on environmental conservation as a good corporate citizen.
Safety and Health
- We should comply with industrial safety and health ordinances and the NOK Group Safety Principles, and we should diligently ensure our actions are carried out with a full awareness of safety and health.
Provision of Useful and Safe Products
- We should carry out activities to develop and manufacture socially useful and safe products while working toward achieving a sustainable society.
- We should carry out development and manufacturing in ways that ensure the safety and quality of products by basing those activities on the quality management system while continuingly improving that system, and we should provide products that comply with related ordinances, pass the prescribed tests, and satisfy the demands of the customers.
Appropriate Management of Information
- Proper use of confidential information
We should not make use of confidential information belonging to the Company, such as disclosure to any third party without permission, or use such information for our own interests.
- Disclosure of confidential information
When it is necessary to disclose confidential information belonging to the Company to a third party, we should enter into a confidentiality agreement without fail.
- Confidential information belonging to a third party
We should not make inappropriate use of confidential information disclosed by a third party. If a confidentiality agreement is executed, we should observe the agreement.
- Management of information
For the preparation and receipt, and handling, such as custody, maintenance and disposal, etc. of confidential information, the person who prepared the information or the addressee shall personally carry out such actions, and must take every step not to leak confidential matters.
- Obligation to maintain confidentiality after resignation
Even after leaving the company, ex-employees should not undertake any act that impairs the Company’s interests, such as leaking the Company’s confidential information that may have come to a person’s knowledge in the performance of their duties, or use such for their own or a third party’s interests.
- Proper use of confidential information
Prohibition against Acts that may Damage the Company’s Interests
- We should not undertake any act that may damage the Company’s reputation or credit status.
- We should not undertake any illegal acts that may lose or impair the tangible or intangible assets of the Company.
- If we resign from the Company, we must return all things that rightfully belong to the Company. We should not illegally use such things after resignation.
- If we have to undertake an act that may conflict with the interests of the Company, we should do so only after obtaining the required approval or permission as provided in the ordinances or rules.
- For any act undertaken in connection with business affairs, we must be conscious that the responsibility may extend to the Company, even if such act is not within the province of the Company’s authority, and we should not undertake any act that is beyond the authority provided.
Giving Report of Violations of Ordinances etc.
If we become aware of conduct that violates the ordinances and/or the in-house rules/regulations, we should immediately report it to the persons designated to receive such reports as prescribed in the Compliance Rules.
If the violating conduct is not rectified despite having reported it as described above, or if it is difficult to report such conduct to the persons designated to receive such reports, we should report the matter to the whistle-blowing hotline (hotline inside the Company or outside the Company).
Established on August 1, 2006
Revised on July 1, 2011
Revised on July 1, 2011