Compliance

GovernanceCompliance

To maintain public trust and to achieve sustainable growth, every employee and executive of our Group is expected to comply with laws and international rules, and consistently act in accordance with our organization’s high ethical standards.

Compliance System

We established our Compliance Committee as a specialized body that ensures our Group members continues to comply with laws and regulations. The Committee also provides information on corporate ethics and is primarily focused on the items listed at right.

  • Drafting revisions to the Group Code of Conduct and Principles of Activities
  • Collecting and analyzing information on compliance and providing compliance training
  • Managing an internal whistleblowing system (NEG Hotline)

Compliance Program

Group Code of Conduct and Principles of Activities

To ensure that all employees are informed on compliance matters, we have established the Group Code of Conduct and Principles of Activities. Wallet-sized cards printed with the Corporate Philosophy Structure, Code of Conduct, Principles of Activities, and an introduction to the NEG Hotline are distributed to employees of group companies in Japan.

Full Text of the Group Code of Conduct

Internal Whistleblowing System

An internal whistleblowing system called the NEG Hotline has been established to help prevent any illegal violations, wrongdoings, or unethical acts and to promote early detection and quick resolution should such acts occur. We have established two consultation hotlines, one that connects employees to the Compliance Committee (internal contact point) and another that connects to an attorney’s office (outside contact point). The confidentiality of the informants is strictly protected at both contact points, so that no unfair treatment will occur.
This whistleblowing system has been set up at all of our subsidiaries, including those outside of Japan, and we are working to ensure that our stakeholders know about the system and that it functions properly.

Internal Whistleblowing System “NEG Hotline”
Note: Flow diagram is for the Company and its group companies in Japan.
Number of exposures or claims within the Group
2018 2019 2020 2021 2022
6 11 11 12 25

Note: Figures for 2017 and 2018 are for the Company and its group companies in Japan only.

Ensuring Compliance

To raise compliance awareness (for example, for high ethical standards and respect for human rights) throughout our Group, each year we carry out compliance training as a part of an education program for newly hired employees and antitrust seminars for employees engaged in sales activities. We also ensure awareness among management by holding workshops for directors and executive officers. At these sessions, participants take the opportunity to discuss themes such as governance and compliance. In addition, we have designated October as the month for strengthening compliance. We conduct compliance- related lectures and workshops throughout our Group companies both in Japan and overseas, and also put up compliance awareness posters throughout our facilities. Moreover, we ask all executives and employees in Japan and overseas to provide the Company with signed declarations each year promising that they will abide by the Principles of Activities. This gives them the opportunity to reflect on how they carry out their work in terms of compliance.

Measures to Prevent Corruption

With increasing globalization, the importance of preventing corrupt actions such as bribery in international transactions is being recognized in various countries.
Our Group Code of Conduct prohibits the bribery of public officials or others in positions of public service in Japan or any other country. The issue of preventing corruption is addressed in compliance training at our group companies both in Japan and abroad, held during Compliance Awareness Month.

Measures to Maintain Fair Business Dealings

We recognize the importance of adhering to antitrust laws in promoting fair international dealings.
Our Group Code of Conduct prohibits actions such as price-fixing or cartel agreements, and based on the internal rules at our group companies inside and outside Japan, any contact with a director and an employee of a competitor must be requested ahead of time and reported on afterwards. Adherence to the antitrust laws is covered in our annual group company compliance training, and we also hold seminars on the antitrust laws for employees who work in sales.

Response to the UK Modern Slavery Act

In developing its business globally, the NEG Group recognizes the importance of respecting human rights in each country and region, including those in supply chains. Electric Glass Fiber UK, Ltd., an overseas group company based in the United Kingdom, has issued a statement in response to the UK Modern Slavery Act, enacted in 2015.

Modern Slavery Act Transparency Statement for Fiscal Year 2022PDF: 163KB

Import/Export Control Initiatives

We have established a Trade Control Committee as part of efforts to ensure thorough implementation of export controls and compliance with various export-related legal requirements, such as the Foreign Exchange and Foreign Trade Act. Among other things, the Trade Control Committee scrutinizes the implementation of export control procedures, facilitates Foreign Exchange and Foreign Trade Act-related training, and develops internal rules and regulations.

Also, in order to ensure appropriate compliance with import/ export customs procedures and tax reporting, we have established the Specified Export Declaration Office and Special Import Declaration Office to facilitate the implementation of trade- related business according to the requirements of the Customs Act and other tariff-related laws. As part of their efforts to ensure thorough compliance and greater awareness, both of these offices conduct regular Group-wide auditing and employee training.

These and other initiatives have earned us certification as an Authorized Economic Operator (AEO) by Kobe Customs for both exports and imports. This is a status conferred on those economic operators that have well-developed cargo security controls and legal compliance structures in place.

Thanks to this, not only the Company but also its overseas subsidiaries are conferred AEO mutual recognition, thereby expediting smoother import/export customs procedures. In addition, we are the only Japanese glass manufacturer to be certified as an AEO for both imports and exports.

Implementing BCP

To be prepared for disasters such as earthquakes, typhoons, floods, fires, and mass infections, we created a disaster management manual based on the company’s disaster preparedness regulations, and we carry out emergency drills periodically. In the wake of the 2011 Great East Japan Earthquake, we reviewed our disaster management measures and implemented seismic reinforcement to our buildings, production facilities, and equipment.

In 2015, we began using Business Continuity Planning (BCP), which replaced the previous disaster preparedness regulations. To facilitate the processes necessary for BCP, a manual providing information on detailed preparation procedures and actions that should be taken when an emergency or disaster strikes was created. In accordance with the implementation of BCP, we have also introduced a system that will efficiently confirm the whereabouts of all domestic employees and their families in case of an emergency. Moreover, in order to resume production and continue to supply our customers in the aftermath of a disaster, we are working to strengthen our risk management system of procurement.

Basic Policy of BCP

  1. To protect each employee and their families and to secure their safety
  2. To protect production equipment, to prevent the spread of damage as well as secondary disasters from occurring within the company and the adjacent communities, and to help with rescue efforts
  3. To resume providing customers with products and services as rapidly as possible
BCP Activation Structure
BCP Response Training

At our BCP response training carried out in November 2022, employees took part in an earthquake simulation drill, which made use of VR goggles in combination with a simulator to recreate past earthquake data. They also took part in classes run by disaster preparedness experts. This training and instruction served to reinforce employee understanding of business continuity and resumption procedures.

BCP response training