Compliance/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 the Audit and Supervisory Committee) and one external contact (our legal advisor) for reporting, and reports can be made anonymously. We faithfully enforce our rules ensuring confidentiality regarding the contents of reports and prohibiting unfavorable treatment on the basis of having made a report. There were eight cases reported in 2022, and we worked with the necessary divisions to handle each case appropriately.
Distribution of the "Fundamentals for the THK Group Employees" Booklet
"Fundamentals for the THK Group Employees" contains 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. This booklet is distributed to all employees in an effort to ensure they always perform their work appropriately without losing sight of their mission, and it is available in a total of 12 languages (Japanese, English, Traditional and Simplified Chinese, German, French, Czech, Portuguese, Spanish, Thai, Malay, and Vietnamese).
Click here to learn more about the Fundamentals for the THK Group Employees booklet.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
- The THK Group does not directly or indirectly commit bribery, nor make offers or promises thereof to anyone.
- The 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").
- The 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.
- In 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. -
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. -
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. -
Thorough Management of Records
The THK Group accurately records all transactions in its accounting books and appropriately stores all related materials. -
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. -
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. -
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
2022 Activities
New Hire Training
Headquarters: New hire training was conducted in April for 160 participants.
THK NIIGATA plant: In April, four high school graduates and ten university graduates underwent new hire training to gain thorough compliance knowledge while maintaining social distancing to prevent the spread of the coronavirus.
Training for Mid-Career Hire
Headquarters: Training was held in April for one participant from overseas.
Training
Headquarters: In December, a compliance subcommittee member seminar was held for 44 participants on effective internal communication practices for preventing and correcting compliance violations.
THK Wuxi plant: In order to increase compliance awareness, an external environmental specialist was invited to teach a seminar on environmental regulations for 32 members of management (deputy managers and above) in June.
Major Legal Violations
There were no major legal violations related to compliance in 2022.
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2022 |
0 (Target: 0) |
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Security Export Control Structure
In order to maintain the peace and safety of the global community, THK conducts activities related to safety 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.
Next 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
This year, an online seminar was held 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.
Individual seminars are also held within the various departments of the engineering division.
Internal Audit
Departments that export items were given a paper audit, and several underwent a regular (virtual) in-person audit.
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.
THK is promoting its growth strategies and implementing activities conducive to the expansion of its business areas.
Our main activities involve adapting to an expanded sales framework and enhanced productivity, as well as securing a business advantage in overseas markets through an increase in overseas patent applications and early acquisition of patent rights. As we expand into new business fields, we are also reviewing the areas in which we have trademark rights and strengthening those areas with new patent applications.
As part of strengthening our brand, we are also asserting more control over imitation products and striving to mitigate the negative effects if customers purchase counterfeit products by mistake. With the ultimate aim of generating intellectual property rights connected to business continuity, we are working toward increasing the implementation rate of our intellectual property rights by determining evaluation criteria for when we apply for patents in Japan and abroad, and by continuing projects meant to promote the utilization of our currently unimplemented patents.
Responding to Counterfeit Products
To increase the brand strength of THK's products, with the aim of eliminating malicious manufacturers and sellers, we are performing a test installation of software for extracting and removing imitation and inauthentic products (counterfeit products) and testing its effectiveness at ascertaining how and in what quantities counterfeit products are distributed. Currently, we are using this software to identify companies putting THK's brand name on products that are not ours, sales of products that we cannot guarantee as our own, and manufacturers and sellers thought to be applying THK's brand to counterfeit products. We are gradually executing such countermeasures where possible.
