Compliance

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 Promotion Structure

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.

Compliance Structure
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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 Division 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 nine cases reported in 2018, 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.

Education and Raising Awareness

2018 Activities

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Activity Purpose Description
Training Preventing illegal and wrongful acts that would significantly impact operations
Establishing global compliance structure Global collaboration in compliance-related work
Compliance violation awareness Improving knowledge and awareness of compliance
THK Group Helpline awareness Improving familiarity with THK Group Helpline

Compliance subcommittee member seminar (July)

In July 2018, we held a regular seminar on deepening our understanding of compliance and promoting discussion in the workplace. The seminar was led by an external instructor and attended by 41 compliance subcommittee members selected from each THK office, department, and Japanese subsidiary.

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Subcommittee members listening to the speaker

New hire training (April)

In April 2018, we held a lecture for new THK Group employees in Japan (114 high school graduates and 66 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.

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Lecture aimed at high school graduates

Seminars at various THK locations (9 sessions)

Appropriate topics are selected for each office, and we broadly instill our employees with a broad understanding of the importance of compliance. At the Mie plant, 67 supervisors and managers participated in two seminars about power harassment prevention and human relations. At THK RHYTHM CO., LTD., a Japanese consolidated company, a total of 298 employees participated in seven seminars on the fundamentals of compliance.

Seminars at business partner locations (5 sessions)

In June 2018, a total of 101 attendees from business partners in the THK Association participated in five compliance seminars. The seminars were an excellent opportunity for participants to understand our activities and approach to compliance.

Seminars at overseas subsidiaries (3 European subsidiaries)

In December 2018, we shared our fundamental stance on compliance with a total of 31 executives from THK GmbH, TME (THK Manufacturing of Europe), and TMI (THK Manufacturing of Ireland) in a compliance seminar held at each location.

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Seminar at THK GmbH

Providing e-learning materials (2 topics)

In order to improve employees’ knowledge about compliance topics critical to their everyday work, we publish materials to our internal e-learning environment. In 2018, we added a narrated video and 5 test questions related to rules about handling personal information, and we also added 11 short-answer test questions with explanations on the topic of the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors.

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Added e-learning materials

Providing support to establish a compliance committee for Chinese subsidiaries

As part of our efforts to establish a global compliance structure, the THK headquarters helped THK’s Chinese subsidiaries establish a compliance committee.

Creating and posting materials to increase awareness via articles about scandals, etc. (12 postings)

Since 2009, we have continued to post examples of compliance violations committed at other companies to a message board on our internal network as case studies to help strengthen our compliance structure.

Introducing THK Group Helpline via internal newsletter (3 times)

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 in our internal newsletter.

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Helpline information in the newsletter

Information Security Audits

In 2018, an internal information security audit was conducted by the Information Security Committee Secretariat at four locations in Japan (two sales offices, one production facility, and our headquarters).

Major Legal Violations

There were no major legal violations in 2018.

In 2018 0 (Target: 0)
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