Anti-Corruption
Approach
The NGK Group respects human rights and conducts fair, transparent, and sincere business activities to help realize a sustainable society, based on the NGK Group Corporate Business Principles and Code of Conduct. The NGK Group Code of Conduct also states that the Group will work to comprehensively prevent corruption. The NGK Group does not tolerate corruption because it hinders the realization of a sustainable society and leads to human rights abuses.
The NGK Group complies with applicable laws and prohibits any direct or indirect involvement in corruption, while working to prevent corruption across all of its business activities. To respond to the trust of stakeholders and help realize a sustainable society, the NGK Group has established the NGK Group Anti-Corruption Policy.
Corruption and Bribery Incidents
In FY2025, the NGK Group had no corruption or bribery incidents.
Corruption and Bribery Incidents
Prohibition of Corrupt Practices
The NGK Group prohibits its executives and employees from engaging in corrupt acts, including bribery, embezzlement, conflicts of interest, money laundering, insider trading, and obstruction of justice, in which they abuse their authority or position for the benefit of themselves, a third party, or an organization. The NGK Group also does not permit any involvement in such acts. It also prohibits executives and employees from engaging in corruption through third parties such as agents and consultants.
Bribery
The NGK Group prohibits its executives and employees from directly or indirectly offering or providing money, gifts, entertainment, or other tangible or intangible benefits to another person with the intent to influence that person’s actions in the performance of their duties for the purpose of obtaining an improper benefit (bribery), or from accepting such benefits in connection with their own duties (acceptance of bribes).
The NGK Group also prohibits its executives and employees from engaging in corruption through third parties such as agents and consultants.
Conflict of Interest
The NGK Group prohibits conflicts of interest, including selecting business partners based on personal interests, engaging in businesses that compete with the Company’s business, obtaining personal gain at the expense of the Company’s interests, and providing benefits to third parties such as relatives and friends.
Money Laundering
The NGK Group prohibits executives and employees from engaging in money laundering, including concealing or disguising funds obtained through illegal acts such as tax evasion and fraudulent accounting.
Insider Trading
The NGK Group prohibits insider trading by executives and employees using material non-public information about the Company, its business partners, or other parties to trade securities.
As part of these efforts, the NGK Group distributes an annual educational video on the latest developments in insider trading regulations to help deepen understanding of insider trading.
Anti-Corruption Initiatives
The NGK Group takes anti-corruption measures not only for employees but also for business partners such as consultants, agents, and distributors, based on a risk-based approach and to ensure thorough compliance with applicable laws and regulations.
First, the NGK Group has established Anti-Bribery Rules that set out legal compliance requirements and ethical standards for preventing bribery. These rules prohibit bribery, including entertainment and gifts of money and goods, when carried out to obtain an improper benefit, regardless of whether the other party is a public official and including acts conducted through a third party such as an agent.
To reduce bribery risk, the rules require due diligence, including checks for red flags, when appointing new business partners such as agents. They also require contracts and related documents to include compliance clauses covering anti-corruption.
In addition, the NGK Group conducts regular audits of transactions with high corruption risk, such as overseas remittances, entertainment, and commission payments to agents and similar parties. It also carries out regular audits and training mainly at higher-risk Group companies, using indicators such as the CPI (Corruption Perceptions Index) as references.
The NGK Group also accepts consultations and reports through its hotline regarding acts that violate, or may violate, anti-corruption laws or the Anti-Bribery Rules. It investigates and responds to such matters with advice from outside attorneys. During the investigation process, the Business Ethics Committee, centered on outside officers, is involved to ensure appropriateness and independence.
Anti-Corruption Training
The NGK Group prohibits involvement in any form of corruption, including bribery, conflicts of interest, and money laundering, based on the NGK Group Corporate Business Principles, the NGK Group Code of Conduct, and the NGK Group Anti-Corruption Policy. The Group reinforces these policies among all employees working in the NGK Group through regular compliance training and distribution of the NGK Group Code of Conduct Guidebook.
At NGK, anti-corruption training is provided every year, including rank-based training led by internal instructors and small-group sessions led by attorneys. In addition, NGK conducts a Compliance Awareness Survey every two years for all employees working at NGK and its domestic Group companies to check for corruption or signs of corruption in the workplace. Based on the results, each department and each company develops countermeasures to reduce risk and prevent corruption before it occurs.
Number of Sessions and Participants in Anti-corruption Training by Lawyers
Responsible Political Involvement
Donations to Political Parties and Political Fund Raising Organizations
The NGK Group strives to maintain sound and transparent relationships with political and administrative bodies. Political contributions and donations are made in accordance with the laws and regulations of each country and region, and the Group does not engage in any conduct that could create suspicion or distrust in society.
When making political donations, NGK follows procedures based on its internal rules and complies with applicable laws and regulations, including the Political Funds Control Act and the Public Offices Election Act.
No expenditures for political contributions were made in FY2025.