ESG Policies

Our Founding Principles

1. The Management has to run the Company based on feelings of care and trust in its employees.
2. The Management has to run the Company while uniting to ensure full ventilation without forming any cliques.
3. The Management has to run the Company while making absolutely incredible efforts against all odds and risks.
4. The Management has to run the Company while pursuing dreams with management plan.

Management Policies

1. We are committed to be a strong and unique parts supplier while focusing its managerial resources on core business areas.
2. We are committed to be a profitable and robust company while fulfilling company-wide cost reduction programs ranging from front-line sales to manufacturing floor.
3. We are committed to continuously improving our quality while producing and selling our products that are proven to be technologically unique and socially useful, on a global scale.

Principles of Corporate Behavior

Environmental Management System

In order to promote environmental conservation and management smoothly and steadily, NOK is working on the following company-wide system. The Central Environmental Conservation Committee, chaired by the President and Representative Director, determines the risks and opportunities involved in environmental conservation and management, as well as company-wide business policies.
The ESG Committee also reports to the Board on important issues such as priorities and outcomes of identified risks and opportunities. Substantial environmental conservation activities are promoted mainly by the company-wide Environmental Secretariat and the Energy Conservation Subcommittee under the supervision of the company-wide Environmental Conservation Supervisor, and environmental conservation activities are carried out in accordance with environmental targets and policies at each business site.
In fiscal 2021, we set up a subcommittee to deal with carbon neutrality. We will study road maps to achieve carbon neutrality and specific methods to reduce CO₂ emissions, and promote measures to achieve carbon neutrality.

NOK Group Human Rights Statement

Human Rights Statement

In line with our management philosophy of fostering a company driven by love and trust in our employees, the NOK Group places utmost importance on the well-being and dignity of each individual within our organization.
We are committed to upholding human rights as protected in internationally recognized norms, including the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the Ten Principles of the UN Global Compact.
The NOK Group aligns with and supports the United Nations Guiding Principles on Business and Human Rights, and our company policy is founded upon these principles. Furthermore, through our Principles of Corporate Behavior, we recognize that compliance with local laws, adherence to international norms - including human rights, and consideration of cultural diversity, customs, and stakeholder interests - are integral to our operations, and we pledge to respect human rights across all countries and regions where we conduct business.

Scope of Application

This policy applies to all individuals within the NOK Group, including officers, employees, suppliers, and other relevant parties. We require the utmost respect for human rights throughout our supply chain, ensuring that no entity associated with the NOK Group is complicit in any human rights violations.

Human Rights Due Diligence

Based on this policy, the NOK Group will institute and execute essential mechanisms for human rights due diligence. In alignment with the NOK Group Procurement Policy and CSR Procurement Guidelines, we will require our suppliers to adhere to human rights standards. Additionally, we will request our other business partners to uphold human rights based on this policy.

Remediation & Correction

We have implemented a dedicated point of contact for reporting human rights compliance violations and seeking consultations. Upon identifying a breach that has resulted in or contributed to an adverse impact on human rights, we will take prompt action to address and rectify the situation.

Education & Training

To ensure a comprehensive understanding and consistent implementation of this policy among all officers and employees, we will continually foster awareness through educational initiatives, training programs, and ongoing efforts. These initiatives will specifically focus on enhancing knowledge and promoting a culture of respect for human rights and preventing harassment.

Priority Action Areas & Transparency

Following this policy, we will concentrate on the designated priority action areas outlined separately to uphold our commitment to human rights. To ensure transparency and accountability, we will diligently execute these initiatives and provide regular updates on our progress and outcomes through various channels, including our company website.

Established: December 16, 2021
Revised: May 24, 2023
Representative Director,
Chief Executive Officer,
NOK CORPORATION
Masao Tsuru

1. Procurement Policy

1. We comply with laws, regulations and social norms.
2. Based on the idea of free competition, we select suppliers in a stringent manner by providing fair and equal opportunities.
3. We share mutual interests and benefits with suppliers based on the idea of mutual prosperity.
4. We engage in open communication and build a relationship of trust with suppliers.
5. We conduct improvement activities proactively in collaboration with suppliers.

2. NOK Group Sustainability Procurement Guidelines

We, NOK Group, are committed to being an entity that fulfills the role of driving efforts toward the realization of a sustainable society while upholding the principle of fair and free competition, through creating added value that is socially useful, generating employment, and acting autonomously and responsibly.
We believe that if we are to achieve this goal, it is essential that our awareness is shared across suppliers and to work together throughout the supply chain to realize a sustainable society, and established NOK Group Sustainability Procurement Guidelines as our code of conduct.
We ask our suppliers, who are important business partners of the NOK Group, to understand the purpose of this guideline and to implement it on their own, and we also ask their own suppliers to implement it.

NOK Group Sustainability Procurement Guidelines (941KB)

3. Declaration for Building Partnerships

NOK joined the "Declaration for Building Partnerships" by the Cabinet Office and the Ministry of Economy, Trade and Industry, which was announced on April 1, 2022.

• Website of Declaration for Building Partnerships

4. Requests to Our Suppliers

5. Consultation Desk

We have a consultation desk to address compliance issues regarding transactions with NOK Group companies.
(Legal Affairs Section, Legal Affairs Department, Corporate Administration Office, NOK CORPORATION)

NOK's production activities are centered on industrial components made from polymeric materials, such as synthetic rubber and resin. We are committed to environmental conservation activities such as managing environmentally hazardous substances used in production processes, saving energy and resources, and reducing waste.
To extend these controls beyond production processes to procurement activities, we have established the NOK Group Green Procurement Guideline. Controlling environmentally hazardous substances and building a system to guarantee the non-inclusion of these substances throughout the supply chain are our priorities.

6. Green Procurement Guidelines

• NOK Group Green Procurement Guideline (Ver.5.2) (222KB)
• Attachment-1_Substances Impacting on Environment Managed by NOK Group (Ver.5.2) (368KB)
• Attachment-2_Applied Companies List (Ver.5) (152KB)

7. Supplier

We are looking for business partners, not only within Japan but across the globe, who can supply materials for NOK products in a stable and sustainable manner. We welcome suppliers of the materials and metal parts used for our main products, such as seals and flexible printed circuits (FPC).
We hope this page will also help you understand our procurement activities and look forward to hearing from you.

We are particularly interested in the following materials.

Please click here to send your proposal.

For Polyimide, please click the link in the table to send your proposal.

1. Respect for Human Rights, Prohibition against Discrimination and Harassment

1. Diversity, character and personality must be respected, and there shall be no discrimination based on race, skin color, creed, religion, nationality, age, sex, sexual orientation, gender identity, place of origin, or bodily or mental handicaps. Moreover, such discrimination shall not be forgiven.
2. There shall be no acts of harassment that negatively affect the workplace environment by impairing the dignity of, inconveniencing or threatening individuals, or the like. In addition, such harassment shall not be forgiven.

2. Fair and Appropriate Trade

Attitudes toward agents and distributors

We should comply with laws including the Anti-monopoly Act, which regulates unfair transactions, in doing business with agents and distributors.

Relationships with and attitudes toward competing companies

When we have contact and do business with competing companies, we shall comply with laws including the Anti-Monopoly Act, which prohibits unfair transaction methods. We should not criticize or defame competing companies and their products, nor illegally obtain confidential information about them.

Relations with and attitudes toward vendors

When doing business with venders, we shall comply with laws including the Law on Subcontracting, and conduct fair and equal transactions with vendors.

Prohibition against having a cozy relationship with business counterparts and bribery to public officers

We should not undertake any act that may bring an inappropriate relationship with business counterparts, such as giving/receipt of money, gifts, or entertainment, or other economic interests that are not in the range of socially accepted benefits, to/from business counterparts or their officers/staffs etc., or by asking them to stand surety for a debt.
Also, we should not bribe public officers or the like for the purpose of obtaining illicit gains in business.

3. Regulations against Insider Trading

1. If we learn of important unpublished facts about the Company (or its subsidiaries), the facts shall be strictly kept confidential until the facts are published, and stocks or the like of the Company shall not be traded.
2. If we learn of important unpublished facts concerning competing companies or other entities such as customers (or its subsidiaries), the facts shall be strictly kept confidential until the facts are published, and stocks or the like of the competing companies and the customers etc. shall not be traded.
3. When dealing in stocks of the Company, we must fully comply with all regulations, such as prior notification or the like stipulated in the "Regulations of Insider Trading".

4. Export/Import Procedures (Security Trade Control)

1. Exports and imports shall be conducted under proper procedures and declarations.
2. We must not export or import contraband goods, or be involved in such activities.
3. Exports and imports of regulated goods (goods or the like that require permission, approval, or notification) shall be conducted after undertaking the necessary procedures with the competent authorities.

5. Laws Related to Intellectual Property Rights

1. When products are manufactured, sold, imported, or displayed, we much investigate whether the products infringe intellectual property rights owned by others, and confirm that such products do not infringe such rights.
2. We must not undertake any act that infringes intellectual property rights owned by others, such as making copies of computer software without permission.

6. Severance of all relations with Antisocial Forces

1. We shall not have any relation at all with antisocial activities and forces that threaten the lives of the public and business activities, or which interfere with economic activities.
2. If we receive unlawful demands from antisocial forces, we must not make thoughtless compromises, such as by giving money.
   Moreover, we must sever promptly the relationship, once it is found that the business counterparts are antisocial forces.
3. We should not undertake any business with antisocial forces, even if the forces are legal.
4. We should not make use of the influence of antisocial forces.

7. Environmental Conservation

1. We should comply with environmental ordinances and the Basic Policies on Environmental Conservation.
2. We should recognize that efforts tackling environmental problems all have the common theme of working toward achieving a sustainable society, and we should proactively work on environmental conservation as a good corporate citizen.

8. Safety and Health

1. We should comply with industrial safety and health ordinances and the NOK Group Safety Principles, and we should diligently ensure our actions are carried out with a full awareness of safety and health.

9. Provision of Useful and Safe Products

1. We should carry out activities to develop and manufacture socially useful and safe products while working toward achieving a sustainable society.
2. We should carry out development and manufacturing in ways that ensure the safety and quality of products by basing those activities on the quality management system while continuingly improving that system, and we should provide products that comply with related ordinances, pass the prescribed tests, and satisfy the demands of the customers.

10. Appropriate Management of Information

Proper use of confidential information

We should not make use of confidential information belonging to the Company, such as disclosure to any third party without permission, or use such information for our own interests.

Disclosure of confidential information

When it is necessary to disclose confidential information belonging to the Company to a third party, we should enter into a confidentiality agreement without fail.

Confidential information belonging to a third party

We should not make inappropriate use of confidential information disclosed by a third party. If a confidentiality agreement is executed, we should observe the agreement.

Management of information

For the preparation and receipt, and handling, such as custody, maintenance and disposal, etc. of confidential information, the person who prepared the information or the addressee shall personally carry out such actions, and must take every step not to leak confidential matters.

Obligation to maintain confidentiality after resignation

Even after leaving the company, ex-employees should not undertake any act that impairs the Company's interests, such as leaking the Company's confidential information that may have come to a person's knowledge in the performance of their duties, or use such for their own or a third party's interests.

11. Prohibition against Acts that may Damage the Company's Interests

1. We should not undertake any act that may damage the Company's reputation or credit status.
2. We should not undertake any illegal acts that may lose or impair the tangible or intangible assets of the Company.
3. If we resign from the Company, we must return all things that rightfully belong to the Company. We should not illegally use such things after resignation.
4. If we have to undertake an act that may conflict with the interests of the Company, we should do so only after obtaining the required approval or permission as provided in the ordinances or rules.
5. For any act undertaken in connection with business affairs, we must be conscious that the responsibility may extend to the Company, even if such act is not within the province of the Company's authority, and we should not undertake any act that is beyond the authority provided.

12. Giving Report of Violations of Ordinances etc.

If we become aware of conduct that violates the ordinances and/or the in-house rules/regulations, we should immediately report it to the persons designated to receive such reports as prescribed in the Compliance Rules.
If the violating conduct is not rectified despite having reported it as described above, or if it is difficult to report such conduct to the persons designated to receive such reports, we should report the matter to the whistle-blowing hotline (hotline inside the Company or outside the Company).

Basic Concept

The NOK Group operates worldwide. We regard fulfilling tax obligations in each country and region as a fundamental and crucial social responsibility for any company. Based on this view, we have established a tax policy and are working to ensure transparency in tax matters.

Basic Policy

We conduct fair and appropriate business activities globally based on the NOK Charter of Corporate Behavior and our Behavioral Guidelines on Employee Compliance. Regarding taxes, our tax department leads information sharing with related department and engages external experts like tax accountants for support. Through these efforts, we ensure our compliance with tax laws and regulations in all countries and regions where we operate. Should there ever arise any actions that deviate from tax laws or any issues that suggest tax avoidance, we will promptly correct them and ensure proper tax payments.

Appropriate Tax Payment

The countries and regions where the Group operates are chosen based on business needs. Tax burden is just one factor among many. We do not choose locations mainly for their low tax rates. We base our tax planning on the intent of tax laws and regulations in each country and region. While we consider and implement plans that benefit cash flow and optimize tax costs, we do not adopt abnormal tax structures that use entities without substance for tax avoidance.

Complying with the Transfer Pricing Taxation

Transactions between overseas affiliates of the Group are conducted based on arm's length price based on the functions and risks of each site, based on the OECD guidelines and the transfer pricing taxation of each country.
In addition, we are preparing transfer pricing documents in accordance with the tax systems of each country. We are also working to reduce transfer price risks through a system that verifies and corrects transaction prices after the fact.

Complying with Anti-Tax Haven Rules

The Group does not use tax havens for the purpose of tax avoidance. We properly file and pay taxes in the countries and regions where we operate. When we need to operate in low-tax countries for legitimate business reasons, we accurately calculate the tax burden and assess economic rationality based on economic activity standards. We reflect these assessments in our tax filings as needed.

Relationships with Tax Authorities

The NOK Group responds earnestly to requests from tax authorities in each country and region where we operate. By providing accurate tax information, we strive to build healthy relationships with these authorities. We also implement measures to prevent recurrence of any issues identified by the tax authorities.