Sustainability-
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GovernanceCompliance
Expectations that companies will fulfill their social responsibilities are more significant than ever, and we fully understand the importance of ensuring compliance in conducting our business activities globally. We promote compliance activities in a Group-wide manner.
Basic Compliance Rules
We have established our Basic Compliance Rules, which define compliance with laws and regulations (including administrative notices and guidelines), internal rules, and corporate ethics. As a leader in surface modification, we recognize the social responsibilities that come with our corporate activities and have distributed a Code of Conduct for Executives and Regular Employees that defines the proper behaviors expected of executives and employees. In doing so, we ensure that all executives and employees in Japan and overseas are fully informed of the Code of Conduct.
Code of Conduct
of Officers and Employees
Executives and regular employees, which collectively refers to executives and those who work for the Nihon Parkerizing Group, which collectively refers to Nihon Parkerizing and its consolidated subsidiaries and equity method affiliates, shall comply with the following provisions:
- Code of conduct toward customers
- Confidentiality
Executives and regular employees shall respect customer confidentiality as one of the most basic rules. - Principles of accountability and fitness
Executives and regular employees shall provide an overview and explain risks in a way that allows the other party to understand them when providing products and services. If the products and services seem inappropriate, they shall refrain from soliciting them. - Sincerity
Executives and regular employees shall not give responses to customer consultations for which they cannot take responsibility. They shall also accurately investigate situations in response to complaints and sincerely respond from the customer’s point of view. - Elimination of collusion
Executives and regular employees shall not accept a request for any action that would obscure the difference between the customer’s and the company’s standpoint. - Elimination of favoritism
Executives and regular employees shall report to their immediate superior and ask for appropriate instructions before contracting a relative, friend, or another customer with whom they have a personal interest.
- Confidentiality
- Code of conduct with business partners other than customers and other organizations
- Fair selection of business partners
Executives and regular employees shall comprehensively assess quality, services, price, records, reliability, and other aspects to determine business partners based on them. - Prohibition of requests for kickbacks.
Executives and regular employees shall not ask business partners for money, goods, or entertainment. They shall refrain from any action that looks unnatural in the eyes of third parties and behavior that could cause misunderstanding, even if such action seems acceptable. - Prohibition against excessive gift-giving, entertainment, or similar actions
Executives and regular employees shall refrain from gift-giving and entertainment beyond common sense. - Prohibition of the bribery of public servants
Executives and regular employees shall not offer, promise, or give bribes or other similar unfair profits to public servants (including people deemed to be public servants and foreign public servants). They shall refrain from any action that causes such suspicion.
- Fair selection of business partners
- Code of conduct toward investors
- Information disclosure
Executives and regular employees shall accurately release critical information that affects investment decisions. - Accurate records
Information shall be properly recorded according to laws, regulations, and rules and stored for a defined period. - Emphasis on internal audits
An internal audit system shall be established to protect investors’ profits.
- Information disclosure
- Code of conduct toward society
- Compliance with applicable laws
Executives and regular employees shall correctly understand the laws, regulations, guidelines, and other provisions related to our business, comply with them and reliably implement licensing, reporting, and other procedures. - Compliance with the Antitrust Law
Executives and regular employees shall not form a cartel or make arrangements with competitors. They shall refrain from any behavior that causes such suspicion. - Compliance with insider trading regulations
Executives and regular employees shall not be involved in insider trading. Suppose they come to know material information about another company that has not been publicly disclosed. In that case, they shall not buy or sell that company’s stocks. Nor shall they buy or sell our stocks or a competitor’s stocks if they come to know material information about our company. If unsure whether their action is insider trading, they must carefully trade stocks. - Compliance with tax laws
Executives and regular employees shall prepare the paperwork required for tax payment in good faith. They shall not take any actions that could be considered tax evasion. - Respect for intellectual property rights
Executives and regular employees shall respect the intellectual property rights of others. In particular, they shall not illegally copy computer software and publications. - No relationships with antisocial forces
Executives and regular employees shall not have any relationships with antisocial forces such as crime syndicates and shall stand firm against them. (Do not fear them. Do not pay them. Do not use them.) - Action in case of disaster
Executives and regular employees shall take appropriate measures such as disaster prevention in preparation for disaster. If a disaster occurs, they shall attempt to adequately protect human lives, restore their business operations, and take other necessary actions promptly according to predefined rules (such as the disaster control manual).
- Compliance with applicable laws
- Code of conduct for better corporate culture
- Prohibition against discrimination
The company shall fairly evaluate employees according to job descriptions and business performance to determine employment or treatment. Discrimination based on gender, nationality, religion, ideology, physical difficulties, or any other reason is prohibited. - Prohibition against sexual harassment
- Executives and regular employees shall not make sexual remarks, behave in sexual ways, act similarly in the workplace, or force disadvantageous working conditions on people because of their reaction to their inappropriate behavior.
- For example, they should not worsen the work environment by repeating jokes that disgust people.
- Prohibition against power harassment
Executives and regular employees shall not mentally or physically hurt those who work in the same workplace or worsen the work environment beyond the proper scope of work by taking advantage of their superiority in the workplace, such as job title or personal connections. - Privacy protection
The company shall strictly manage the personal information of the executives and regular employees. It shall not be used for purposes other than the original purpose. The company shall not disclose it to outside parties without the approval of the relevant person.
- Prohibition against discrimination
- Code of conduct as a member of the organization
- Compliance with internal provisions, etc.
Executives and regular employees shall comply with the matters defined in the Employment Regulations and other rules, observe internal provisions, consider whether their actions align with the company's profit, and fulfill their duties faithfully. - Workplace safety and health
Executives and regular employees shall understand and comply with the laws, regulations, and other rules related to safety and health and attempt to establish a safe and sanitary workplace environment. - Prohibition against acts of conflict of interest
Executives and regular employees shall act so that their profit does not conflict with the company's profit. They shall not pursue personal interests by taking advantage of opportunities gained through their work. - Respect for company property
Executives and regular employees shall draw a line between public and private and respect company property. They shall not use company property, such as consumables and equipment, including PCs and cell phones, for personal use. They should also refrain from transmitting emails or other messages not related to their work. - Fair expenditure processing
Executives and regular employees shall accurately report travel expenses, transportation expenses, working hours, and holidays. - Handling of nonpublic information
Executives and regular employees shall comply with the laws, regulations, guidelines, and internal rules related to information security and protect the confidentiality of nonpublic information obtained through their work. They shall also pay due attention not to let such details be leaked to outsiders. - External affairs
The company shall disclose information through the public relations department. If asked for an interview by a third party, such as an external media or analyst, they shall report to their supervisor or the public relations department and ask for appropriate instructions.
- Compliance with internal provisions, etc.
Compliance Committee
Under “the Basic Compliance Rules”, we have established a Compliance Committee to establish, maintain, and review our compliance system.
Compliance Initiatives (including activities for preventing corruption and harassment)
The Nihon Parkerizing Group has established Employment and Anti-Harassment Regulations to prevent any and all discrimination and harassment. We have also established a Compliance Whistleblowing System to avoid corruption and harassment. We have distributed the compliance handbook to all employees, regularly held compliance training sessions, and provided e-learning. We also engage in activities to train employees and raise their awareness through new manager training.
Compliance Whistleblowing System
The Nihon Parkerizing Group has established a reporting desk where employees can report and seek advice about incompliance and facts suspected of non-compliance under our Compliance Whistleblowing Rules. To protect whistleblowers, we have established a system that maintains the confidentiality of whistleblowing information, accepts anonymous whistleblowing, and otherwise complies with the Whistleblower Protection Act.
Training and awareness-raising activities
The Nihon Parkerizing Group distributes the Code of Conduct for Executives and Regular Employees, which provides overall guidance on compliance matters in booklets in multiple languages to all executives and employees in Japan and overseas to increase their awareness of compliance. In addition, we distribute the compliance handbook and periodically provide training through workshops, e-learning programs, and other initiatives.
For the Sound Maintenance and Development of the Labor-Management Relationship
Nihon Parkerizing has signed a labor agreement with the labor union concerning union activities, collective bargaining, and labor conditions under the principle of labor-management equality for a peaceful labor-management relationship and its sound development and maintenance.
The labor agreement stipulates that the company shall allow union members to freely engage in union activities unless they violate the provisions of the labor agreement. They shall not treat employees unfavorably regarding labor conditions and other matters based on their union activities.
In this context, the company and the labor union regularly hold labor-management consultation meetings and work to reform union members’ work styles and improve their labor conditions and treatment.
The Nihon Parkerizing Labor Union has adopted a union shop system, and all employees permitted to join the labor union are members.
Fines for Corruption
As of March 31, 2023, no fines have been imposed for corruption.
Tax Transparency
At Nihon Parkerizing, we believe that paying taxes is an essential duty that a company should fulfill and pay taxes appropriately in compliance with tax laws.
- Compliance with laws and regulations
In addition to observing the laws, regulations, and rules of the countries and regions where we conduct business activities, we will also comply with standards released by an international organization (Organization for Economic Co-operation and Development, or OECD) and strive to pay taxes appropriately by respecting the spirit of the standards. - Tax-related corporate governance
We provide internal and external training to improve employees’ tax-related knowledge. At the same time, we execute businesses appropriately under the taxation system and internal regulations, thus enhancing the quality of accounting and tax processing. - Tax risks
We will manage tax risks appropriately, use external specialists, seek advance rulings from tax authorities, and take other measures necessary to minimize tax risks. - Relationship with tax authorities
We will strive to build, maintain, and develop sincere, sound, and cooperative relationships with the tax authorities of the respective countries and regions where we operate businesses. We will also appropriately disclose information requested under applicable laws and regulations, ensuring transparency.
System
Our Accounting Dept. operates appropriately and takes improvement measures as necessary.