Initiatives to Ensure Thorough Compliance
Compliance with Competition Laws
Initiatives to ensure thorough compliance with competition laws
NGK ensures thorough compliance with applicable competition laws based on the NGK Group Corporate Business Principles and Code of Conduct.
At NGK and each Group company, the Company has established Competition Laws Compliance Rules aligned with international standards and requires the formulation and operation of an annual Competition Laws Compliance Program under those rules. The status of program implementation is reported to the Business Ethics Committee, which is composed mainly of outside officers, and NGK promotes these activities based on the committee’s recommendations to ensure effectiveness.
NGK also holds annual competition law compliance lectures led by outside attorneys. In addition, reflecting on past violations of competition law, we launched legacy training In FY2021 as a measure to prevent recurrence and has since expanded the scope of participants. Through these efforts, the entire NGK Group continues to work to ensure thorough compliance with competition laws.
Third-party review of the Competition Laws Compliance Program
NGK engaged external experts from FY2015 through FY2024 to review the operation of its Competition Laws Compliance Program under the Competition Laws Compliance Rules, as well as the NGK Group’s centralized oversight and reporting framework covering Group companies in Japan and overseas.
NGK also received recommendations on how to improve the Competition Laws Compliance Program. It reflected those recommendations in the FY2025 program and held discussions between the Chief Competition Law Compliance Officer and the heads of the business groups, among other actions.
Insights from these discussions, including enhanced training for mid-level employees on the Company’s past competition law violation case, were incorporated into the FY2026 Competition Laws Compliance Program. Through the operation of this program, NGK will continue to carry out even more effective activities.
Instances of Anticompetitive Behavior
In FY2025, the NGK Group had no incidents involving anti-competitive conduct.
Instances of Anticompetitive Behavior
Export/Import Transaction Management
Strict Adherence to Laws and Regulations Relating to Export/Import Management
As part of its efforts to ensure thorough compliance, NGK works to comply with laws and regulations related to imports and exports. In its NGK Group Corporate Business Principles and Code of Conduct, NGK stipulates compliance with relevant laws and regulations, including Security Export Control, and implements controls and training in accordance with its internal rules and Export/Import Handbook.
Using Export Control System to Conduct Comprehensive Inspections and Customs Management
NGK manages compliance with export control-related laws and regulations, including Japan’s Foreign Exchange and Foreign Trade Act. To do so, it uses its Security Export Control System (TTP)*1 to review each transaction and determine whether an export license is required. NGK also uses the AEO (authorized economic operator) Program for exports of certain products. Exports are managed through the shipment registration list in TTP, while imports are managed through the export/import cargo management ledger. Each department conducts annual self-inspections covering specified exports and imports. In addition, NGK uses NACCS*2 data to verify the completeness of both the shipment registration list and the export/import cargo management ledger, achieving almost 100% coverage for both exports and imports.
- *1An export control support system that conducts and records transaction reviews and related checks in compliance with export control-related laws and regulations, including the Foreign Exchange and Foreign Trade Act
- *2A system for online processing of procedures taken with customs and other relevant administrative authorities or related private-sector services for arriving/departing ships and aircraft or import/export cargo
Familiarization with the Export/Import Handbook
NGK posts its Export/Import Handbook, which summarizes compliance requirements for import and export customs clearance, on its internal portal site so that all employees can access it. In addition, each department uses study sessions on import/export management to raise awareness of the handbook’s purpose, and NGK provides training on specified exports and import/export management as needed for personnel in the responsible departments. The Company also posts videos on its internal portal site to help employees learn about imports, exports, and related systems, offering them as courses that employees can take in their spare time.
Anti-Harassment Prevention
NGK provides annual position-based anti-harassment training to prevent harassment. It has also introduced training in a group discussion format using case studies led by attorneys and other experts to deepen understanding of and awareness about preventing power harassment, sexual harassment, and customer harassment. In FY2025, 449 employees, mainly key personnel at domestic Group companies, completed the training. In addition, NGK distributes e-learning materials that employees can use for self-study and in department-led training, and the materials have been viewed more than 1,000 times. The Company is also improving the content based on post-training survey results. Going forward, NGK will continue working to prevent harassment before it occurs and improve the workplace environment through even more effective training.
Number of Harassment Prevention Training Sessions Held
Number of Participants in Harassment Prevention Training
Compliance Awareness Survey
NGK conducts a compliance awareness survey every two years for all people working at NGK and its domestic Group companies with the aim of strengthening its compliance framework. The survey is used to assess awareness of risks that have already emerged and their impact. Based on the results, each department and each company develops countermeasures and works to reduce risk.