Nidec has in place a Compliance Committee under Nidec Corporation’s Board of Directors to establish basic compliance policies and monitor the Nidec Group’s compliance. Compliance Office, which works with Regional Compliance Officers of individual regions where Nidec’s group companies operate (Americas, China, Europe, and Southeast Asia), builds and operates a system to secure compliance in the Nidec Group (a global compliance system).
Regulations, code of conduct, and basic policy
Nidec has in place “Compliance Regulations,” rules for compliance-related fundamental notions, organizations, operating methods, etc. for the entire Nidec Group’s compliance, and to build a group-wide compliance system and raise the compliance awareness of all employees.
In addition, we established a “Nidec Group Compliance Code of Conduct,” and a more detailed version of it, “Nidec Compliance Handbook,” to ensure that all executives and other employees understand compliance rules and regulations.
In addition, as a globally operating company, we make it a basic policy to comply with the RBA (Responsible Business Alliance, the former EICC).*
*RBA: A set of standards to ensure that the electronics industry’s supply chains provide a safe work environment, treat workers with respect and dignity, fulfill their environmental responsibilities, and execute their duties ethically. As an example, the “Business Integrity” part of the RBA Code of Conduct’s “Ethics” section stipulates that participating organizations “shall have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement.” For more detailed wordings, please click here.
Prevention of Bribery and Corruption
In FY2016, we formulated “Anti-Bribery Policy,” a group-wide rules on dealing with government officials, suppliers, agents and customers. As we try to educate all employees on this policy, we make sure to cover all business transactions with government officials, suppliers, customers, and agents. To ensure the proper use of this policy and control bribery-related risks, we use the policy to oblige Nidec employees to report to Compliance Office after accepting entertainment or a gift beyond a certain level, and when executing a contract with an agent in certain cases. In addition, we conduct due diligence on the companies to join the Nidec Group via M&A to confirm that they are free of bribery- and corruption-related risks.
Nidec Corporation has been a member of the United Nations Global Compact since August 2015, and upholds its ten principles in the four areas of human rights, labor standards, the environment, and anti-corruption. The problem of corruption, an issue the UN is promoting to prevent, greatly hampers sustainable development. This is why Nidec is committed to the principle, “Companies should engage in actions to prevent all forms of corruption, including extortion and bribery.”
Internal reporting system
As part of the comprehensive, group-wide compliance system, we established an internal reporting section (the Nidec Global Compliance Hotline) available for all board members, executives, and employees (including regular and part-time employees, those dispatched from outside agencies, and limited-term employees) to encourage them to report and raise issues on accounting fraud, bribery, labor safety-related cases, harassment, and other acts in violation of laws, regulations, internal rules, ethics, etc. The hotline, in place in Japan, Americas, China, Europe, and Southeast Asia, is available in multiple languages. Reports can be submitted anonymously so that no employees will be subject to any disadvantage after reporting an incident.
In FY2018, we received a total of 106 whistle-blowing reports and consultations on suspected cases of misconduct, harassment, etc. We believe that this total number, which is approximately five times the annual average, demonstrates that the compliance seminars that we held more actively than before by using the Nidec Compliance Handbook further cultivated our employees’ compliance awareness, and led to an early detection of latent compliance risks. In solving these cases, we respect whistleblowers’ intentions to the best extent, and examine and investigate facts in a form of interview with those concerned, etc., to execute proper actions and prevent such cases. Furthermore, we report the status of internal reports from our group’s executives and other employees to the members of our Audit & Supervisory Board on a regular basis.
|Number of cases||16||22||106|
Action on violations
If a whistleblowing or any other action reveals any violation of compliance rules by an executive or other employee, we will launch investigations to prevent its recurrence, while, based on applicable internal rules, punishing those involved in the violation based on deliberation by the Disciplinary Action Committee and the Board of Directors.
|Elimination order by the Fair Trade Commission or any other authorities concerned||0||0||0|
|Business shutdown or suspension due to misconduct, etc.||0||0||0|
|Criminal prosecution due to a compliance-related accident/incident||0||0||0|
|Outside Japan (including cases involving subsidiaries and affiliated companies such as local joint ventures)|
|Allegations of price cartel||0||0||0|
|Allegations of bribe-giving||0||0||0|
Education and actions
We have our Regional Compliance Officers use the Nidec Compliance Handbook to teach our employees on cartel, bribery, harassment, and other topics in and outside Japan in forms of seminar, discussion, etc. to enhance mutual understanding on what constitutes a compliance rule violation, possible effects of such a violation, and what to do when in doubt, among others. In addition, we invite an outside lecturer once a year for a compliance seminar for executives.
Every year, to manage their risks, all Nidec Group sites, including newly built ones and those that have newly joined the group via M&A, assess risks regarding bribery, corruption, human centers abuse, and many other social issues. Departments in charge prepare a plan to correct any risk identified in the assessment, and execute a PDCA cycle based on the level of the risk to reduce it.