Nidec Corporation has a Compliance Committee under its Board of Directors to set the Nidec Group’s compliance-related basic rules, and monitor and supervise its compliance with laws, rules, and regulations. The Compliance Committee holds a meeting on a quarterly basis to deliberate compliance activity plans, and individual compliance issues and measures. In addition, the Officer in charge of compliance annually reports the status of and plans on compliance activities to the Board of Directors and the Audit and Supervisory Committee.
Nidec Corporation’s Legal & Compliance Department, working in partnership with Regional Compliance Officers of the individual regions where the Nidec Group’s business bases operate (the Americas, China, and the Southeast Asia) and Compliance Managers and Promoters of individual business departments and group companies, builds and operates our group’s compliance-securing system (a global compliance system). Compliance Managers implement and operate compliance-related measures to raise the compliance awareness of the organizations under their supervision, and bear responsibility to prevent compliance violations. Compliance Promoters promote specific compliance measures of such organizations, while serving as a liaison with Legal & Compliance Department and Regional Compliance Officers, who provide support for individual regions’ Compliance Managers, while accepting whistle-blowing cases and consultations on compliance issues unique to their countries and regions.
The Nidec Group’s global compliance system
Regulations, code of conduct, and basic policy
Nidec has in place “Nidec Group 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 have in place a Nidec Group Compliance Code of Conduct, which is an action guideline for the company’s executives and employees, and a Nidec Compliance handbook, which explains the Code of Conduct in detail in Japanese, English, and Chinese, to ensure that all executives and employees understand it group-wide.
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 2016, we formulated “Anti-Bribery Policy” a group-wide rules on dealing with government officials, suppliers, agents and customers. This Policy, which covers business transactions in general with public officers, suppliers, customers, and agents, sets forth rules on, among others: providing public officers, customers, and others with cash, gifts, meals, and business entertainment; making donations in relations to public officers’ and others’ acts in the line of duty; receiving cash gifts, meals, business entertainment, and other benefit from suppliers; and selecting agencies and agents. The Anti-Bribery Policy makes it obligatory to report to, and obtain approval of, a Regional Compliance Officer any provision or reception of business entertainment that fails to meet any one of the (1) – (3) below, to ensure the proper operation of the Policy and control bribery-related risks.
- (1)The amount of money that the counterpart (Nidec) receives must not exceed US$100 per person;
- (2)The number of times of providing the same person with profit (or receiving profit from the same person) must not exceed twice; and
- (3)The number of the people in the organization to provide with such an amount of money (or receive such an amount of money from the organization) on the same occasion must not exceed four.
In addition, in M&A cases as well, we perform due diligence for bribery- and corruption-related risks in a company to purchase, to confirm that there are no such 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. A Regional Compliance Officer receives while-blowing reports, and launches investigations and corrective actions in cooperation with Nidec Corporation’s Legal & Compliance Department. Whistleblowers will be notified as much as possible of the findings of the report. Reports can be submitted anonymously so that no whistleblowers will be subject to any disadvantage after reporting an incident. Our business sites in the Americas and Europe have in place third-party-operated external consultation channels in addition to internal whistle-blowing consultation offices.
FY2019 saw a record total number of 142 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 Board of Directors and the Audit and Supervisory Committee on a regular basis.
|Number of cases||22||106||142|
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 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
As part of its compliance promotion activities, we hold compliance seminars for our group’s executives and employees to maintain and improve the level of their compliance awareness.
In those seminars, we use the Nidec Compliance Handbook as a teaching material, and have Regional Compliance Officer as lecturers for such topics as cartel, bribery and human rights issues including harassment, and host seminars, discussions, and other activities in and outside Japan. Thus, we work to share the same level of understanding on, for example, acts that constitute compliance violations, results expected from such violations, and actions to take when in doubt.
In addition, we invite an outside lecturer once a year for a compliance seminar for board directors, executives and others.
Compliance seminars held in Japan (the total number of participants)
*FY2020: Due to the spread of COVID-19 infections, some face-to-face seminars were cancelled or postponed.
|Compliance seminar||For executives and managerial employees (with an outside lecturer)||115||500|
|For employees of individual hierarchical levels||225||148|
|For newly hired employees||231||174|
|For mid-career employees||33||20|
|For those to move overseas||129||44|
|Export control seminar||348||74|
|Subcontract Act seminar||550||450|
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.