This statement (“Statement”) is made pursuant to Section 54 (Part 6) of the Modern Slavery Act 2015 of the United Kingdom to describe the policies and efforts of NGK Insulators, Ltd. and its affiliated companies (hereinafter, the “NGK Group”) to prevent the occurrence of modern slavery and human trafficking for the fiscal year ending March 31, 2024.
Among the entities in the NGK Group, NGK Insulators, Ltd. and NGK Europe GmbH are subject to the reporting obligations under the Modern Slavery Act 2015 (United Kingdom); NGK Insulators, Ltd., as the parent company of these reporting entities, discloses this Statement as a joint statement to cover both entities.
NGK Group engages mainly in the supply and development of products that support social infrastructure and contribute to environmental conservation, such as ceramic parts for automobiles, insulator products for electric power, electronic parts, and industrial equipment and devices with ceramic technology as its core technology.
The NGK Group is headquartered in Aichi Prefecture, Japan, and has 47 consolidated subsidiaries in 20 countries and regions (including the United Kingdom and the United States), doing business with about 20,000 employees.
In addition, materials and parts of NGK Group products are procured from procurement partners inside and outside the NGK Group around the world.
Please refer to the following URL for details on these companies and businesses.
NGK Group has established the “NGK Group Corporate Business Principles and Code of Conduct” and the “NGK Group Human Rights Policy”, which stipulate the attitudes and matters to be respected in conducting business activities. The code and policy, with the approval of the Board of Directors, declare that the NGKGroup excludes forced labor, child labor, human trafficking, and all other acts that lead to human rights violations.
With the “NGK Group’s Supply-Chain CSR Guideline”, the NGK Group requests its supply chain to understand and support the avoidance of the use of conflict minerals that can cause human rights violations and poverty, and the prohibition of forced labor and child labor. The NGK Group and its entire supply chain have made a clear commitment to prevent the occurrence of modern slavery and human trafficking. In addition, we are preparing to revise the current “NGK Group’s Supply-Chain CSR Guideline” into a “Supplier Code of Conduct”, which will specifically define the code of conduct for suppliers based on the NGK Group’s various policies, guidelines, and codes of conduct.
“NGK Group Corporate Business Principles and Code of Conduct”
NGK Group Code of Conduct
“NGK Group Human Rights Policy”
NGK Group Human Rights Policy
The NGK Group conducts surveys using a self-assessment questionnaire with reference to the RBA Code of Conduct. The assessment includes many aspects that are related to human rights, such as “identifying forced labor, child labor, and human trafficking,” “working hours, wages, and welfare,” “occupational safety and health,” and “responsible mineral procurement.” Through this survey, the NGK Group looks for, and could gather details on, any human rights risks in its business operations.
In the fiscal year ending March 31, 2024, based on the above due diligence process, we conducted surveys using a self-assessment questionnaire in NGK and its 39 Japan domestic and overseas group companies, to confirm the existence and level of risks.
Additionally, the NGK Group has been establishing whistleblowing systems effective to apply in accordance with circumstances of country or region where eachgroup company locates, such as reporting mechanism available to all employees at respective group companies.
The NGK Group found no cases of forced labor, child labor, or human trafficking in the survey for the fiscal year ending March 31, 2024, thorough the above surveys and whistleblowing systems.
In terms of supply chains, we annually request our suppliers, including new suppliers, agree to comply with “NGK Group’s Supply-Chain CSR Guideline”. In the fiscal year ending March 31, 2024, we newly conducted a self-assessment surveys of about 70 suppliers of overseas group companies, using a self-assessment questionnaire to ascertain their level of understanding of CSR procurement and status of their activities. The NGK Group also operates a supplier helpline, where the NGK Group can accept reports on risks of human rights violations, including slavery.
The NGK Group found no cases of forced labor, child labor, or human trafficking in the survey for the fiscal year ending March 31, 2024, thorough the above surveys and whistleblowing systems.
The NGK Group has set up an HR Committee chaired by the Director in charge of the Human Resources Management Department at NGK Insulators, Ltd. The committee manages, shares, and evaluates various human rights risks collected based on the due diligence process, and establishes countermeasures, if necessary.
The NGK Group will continuously improve the effectiveness of the survey by enhancing the assessment scope and contents to find and establish a fair performance indicator for the fiscal year ending March 31, 2025, and thereafter.
The NGK Group issues notifications, distributes guidebooks, posts posters, and conducts on-site education regarding the “NGK Group Corporate Business Principles”. In addition, in the fiscal year ending March 31, 2024, the NGK Group conducted e-learning for “NGK Group Human Rights Policy”.
Regarding its supply chain, the NGK Group requests its business partners to comply with the above-mentioned “NGK Group’s Supply-Chain CSR Guideline” and request them to submit written consent every year.
This statement was approved by ;
(i) the Board of Directors of NGK Insulators, Ltd. on September 24, 2024
(ii) all the directors of NGK Europe GmbH on September 24, 2024
NGK Insulators, Ltd.
President
NGK Europe GmbH
Managing Director