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Compliance and Intellectual Property
Basic Stance/Policy
To thoroughly instill compliance awareness, we maintain structures and conduct various programs with the aim of complying with laws, internal standards, and ethical norms.
Policy
Thoroughly instill compliance awareness and create a work environment that does not allow wrongful acts.
Compliance Committee
The Compliance Committee is headed by our CEO and convenes four times a year. This committee, which is attended by outside directors and a legal advisor, properly approves the annual activity plan and reports on the execution of those activities, as well as on the handling of compliance violations by employees and other matters reported internally.
Activities and Results (Including Goals)
THK Group Helpline (Internal Reporting System)
The THK Group Helpline was established to prevent compliance violations and to enable quick and appropriate action in the event of an employee committing a violation. There are two internal contacts (the Risk Management Department and Audit and Supervisory Committee) and one external contact (our legal advisor) for reporting. Reports can be made anonymously, and we faithfully enforce our rules ensuring confidentiality regarding their contents and prohibiting unfavorable treatment on the basis of having made a report. There were fourteen cases reported in 2021, and we worked with the necessary divisions to handle each case appropriately.
Distribution of the “Fundamentals for the THK Group Employees” Booklet
With the aim of helping employees always properly execute their duties without losing sight of our mission, “Fundamentals for the THK Group Employees” contains the materials that constitute our CSR policy: our Corporate Philosophy, Corporate Basic Policies (creating value and contributing to society, being customer-oriented, and compliance with laws and regulations), and The THK Group Action Charter (ten principles of behavior). This booklet is available in a total of 12 languages and is distributed to all employees.
Establishing the THK Group Anti-Bribery Policy
The THK Group has long worked in accordance with the THK Group Action Charter in order to prevent bribery. However, along with the principle of anti-corruption in the UN Global Compact, which was signed by THK in 2020, laws surrounding bribery and disclosures are becoming stricter around the world. Based on the fundamental principle of prioritizing legal compliance over short-term gains, we established the THK Group Anti-Bribery Policy in December to promote efforts aimed at preventing bribery.
THK Group Anti-Bribery Policy
- (Established December 21, 2021)
Based on the fundamental principle of prioritizing legal compliance over short-term gains, the THK Group adheres to the following provisions as it promotes efforts to prevent bribery.
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Prohibition of Bribery
- ⑴The THK Group does not directly or indirectly commit bribery, nor make offers or promises thereof to anyone.
- ⑵The THK Group does not make facilitation payments (small bribes for the purpose of expediting administrative procedures) to public officials or those in equivalent positions (hereinafter referred to as “Public Officials”).
- ⑶The THK Group pays heed to the particular laws of each country and region, including those that forbid bribery toward private enterprises in addition to Public Officials, and adheres to applicable anti-bribery laws in the execution of its business.
- ⑷In recognition that any bribery committed by a representative or business partner (hereinafter referred to as “Business Partners”) may be considered bribery on the part of the THK Group, the THK Group does not instruct its Business Partners to commit bribery. Furthermore, the THK Group does not tolerate any actual bribery on the part of any Business Partners, or indications thereof, of which the THK Group is aware.
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Establishment, Operation, and Internal Auditing of an Anti-Bribery Management Structure
In order to promote the anti-bribery efforts established in this Policy, the THK Group evaluates the risk of bribery within the Group and establishes rules related to the prevention of bribery at each Group company in accordance with the characteristics and risks present in each country and region, and the THK Group regularly monitors, inspects, and evaluates whether those rules are being correctly applied. Furthermore, the THK Group reevaluates the anti-bribery management structure in accordance with the results of the evaluation.
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Thorough Execution of Bribery Prevention and Dissemination of Information
The THK Group conducts training for executives and employees as well as utilizing other means to disseminate information and deepen understanding of bribery prevention.
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Exercise of Due Diligence and Introduction of Anti-Bribery Provisions
The THK Group exercises due diligence before engaging in business with the Business Partners of each Group company and strives to introduce anti-bribery provisions into agreements with such Business Partners.
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Thorough Management of Records
The THK Group accurately records all transactions in its accounting books and appropriately stores all related materials.
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Maintenance of a Helpline and the Obligation to Report
The THK Group maintains a helpline and reporting line in order to detect bribery and other such acts at an early stage. Furthermore, all THK Group executives and employees are required to quickly file a report if they have discovered bribery or another such act.
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Emergency Response
In the event that a major compliance violation related to bribery is made known, the THK Group promptly and appropriately conducts an investigation and takes other necessary actions. Furthermore, the THK Group earnestly handles any requests to cooperate with investigations conducted by law enforcement in each country.
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Penalties
The THK Group deals severely with any executive or employee that has violated anti-bribery laws or this Policy in accordance with the internal regulations of each Group company.
Education and Raising Awareness
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| Activity | Purpose | Description |
|---|---|---|
| Training | Preventing illegal and wrongful acts that would significantly impact operations | |
| Compliance readiness self-audit | Identifying and improving compliance readiness issues | |
| Raising awareness of compliance violations | Improving knowledge and awareness of compliance |
|
| Spreading THK Group Helpline awareness | Improving familiarity with and utilization of the THK Group Helpline |
Compliance Subcommittee Seminar
In November 2021, we held a regular online seminar about the THK Group Helpline. The seminar was attended by 41 compliance subcommittee members selected from each THK office, department, and Japanese subsidiary. In addition to providing an overview of the THK Group Helpline, the seminar also presented actual reports made to the hotline (with the details altered for purposes of anonymization) to examine how the THK Group has addressed compliance violations and other relevant cases and discuss how compliance subcommittee members should respond when a violation occurs.
New Hire Training
In April 2021, we held an online lecture for new THK Group employees in Japan (62 high school graduates and 56 college graduates) covering our CSR and compliance activities.
It was an opportunity for those employees to learn what a corporation’s social responsibilities are, along with the basics of compliance, before being assigned to their respective branches.
Conducting Compliance Training
In April, THK NIIGATA performed comprehensive compliance training for nine new staff members (two high school graduates and seven college graduates).
Compliance Training
In order to increase compliance awareness, the Wuxi plant invited an external instructor to hold a seminar for management on the topic of safety regulations in October. Forty members of management (deputy managers and above) participated.
Compliance Seminar (THK Taiwan)
We share our fundamental stance on compliance through seminars held at our overseas subsidiaries. In December 2021, all 47 employees of THK Taiwan participated in this seminar.
Compliance readiness self-audit
While we are working to improve compliance awareness through training, we conduct an annual compliance survey in order to verify how well those concepts have been realized across the company and to investigate what measures will be needed in the future. This survey was conducted in October 2021, and the aggregated answers of the 3,454 respondents were reported to the Compliance Committee.
Improving Knowledge and Awareness of Compliance
For the purpose of establishing and fostering employees' awareness of compliance, we release a quarterly publication that uses four-frame comic and quiz formats to discuss examples of easily recognizable legal violations and common unintentional misbehavior.
Spreading THK Group Helpline Awareness
To make more employees aware of the existence of the THK Group Helpline, we have provided an overview of how to use our internal reporting system on our internal message board and three times annually in our internal newsletter.
Major Legal Violations
There were no major legal violations related to compliance in 2021.
| 2021 | 0 (Target: 0) |
|---|
Security Export Control Structure
In order to maintain the peace and safety of the global community, THK conducts activities related to security export controls based on the Foreign Exchange and Foreign Trade Act of Japan. THK has established security export control regulations as part of its internal rules, with the CEO being the chief party responsible for export controls and the Risk Management Department's Security Export Control Section functioning as the managing department. The Security Export Control Section gathers information on changes to security export control regulations, notifies internal parties of updates, and conducts employee training to build a compliance framework. This group also coordinates with the relevant departments in order to promptly and appropriately classify products and examine transactions.
This year, they will continue to participate in seminars held by organizations such as CISTEC and the Ministry of Economy, Trade and Industry in addition to gathering information by purchasing publications related to security exports in order to handle these matters. Furthermore, THK will establish an even more appropriate and efficient security export control structure through the promotion of digital transformation.
Training
A seminar was held online for sales office employees who had joined the company within the past three years in order to impart basic knowledge of security exports and train them on the classification of THK products.
・ Security export seminar: 33 employees (who joined the company in the past three years)
Internal Audit
Departments that export items were given a paper audit, and several underwent an in-person audit (conducted virtually).
・ Paper audits: 46 departments
・ In-person (virtual) audits: 11 departments
Intellectual Property
Policy
- THK values and promotes the creation and full utilization of its intellectual property to continue contributing to the creation of an affluent society through the development of innovative products.
This year, as THK actively promoted R&D related to new business exemplified by our “
” service for digital transformation, we took appropriate measures to preserve intellectual property, including acquiring rights in accordance with our business strategies and conducting various surveys and analyses. Furthermore, in order to respond to the increasing number of imitation products and unauthorized uses of our brand, we continuously implemented measures such as prohibiting infringing products at the border through customs, further expanding our rights on a global scale, and working to prevent the acquisition of rights by others in order to prevent unauthorized use.
During the next year and beyond, we will work to maintain and strengthen our brand in addition to expanding our intellectual property rights for new business from an intellectual property investment perspective.
