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Nabtesco Group’s Approach to CSR

Other sustainability-related policies

Nabtesco Group Quality and PL (Product Liability) Policy

To fulfill our corporate social responsibility (CSR) by delivering products with the highest levels of safety, comfort, security and reliability, we will:

  1. Give priority to safety over anything else, based on the principle of respect for people;
  2. Meet safety and other quality needs of products through the integration of business activities and quality and PL activities; and
  3. Realize product quality, which satisfies market demand, by conducting safety and other quality evaluations prior to the release of products to the market.
Corporate Communications Department

Nabtesco Group Human Rights Policy

Nabtesco Corporation has established this Nabtesco Group Human Rights Policy as follows for the purpose of ensuring that all officers and employees of Nabtesco Corporation and its group companies (collectively, the “Nabtesco Group”) act to promote respect for human rights.

1. Relationship with Other Regulations or Policies

This Policy, together with the Nabtesco Group CSR-Oriented Procurement Policy, complements the Nabtesco Group Code of Ethics.

2. International Rules Concerning Respect for Human Rights

The Nabtesco Group is committed to pursuing efforts to promote respect for human rights in accordance with the spirit indicated in the International Bill of Human Rights established by the United Nations (UN), the ILO Declaration on Fundamental Principles and Rights at Work established by the International Labour Organization (ILO), and all other international rules concerning human rights, as well as in conformity with applicable international guidelines including the UN Guiding Principles on Business and Human Rights.

3. Responsibility to Respect Human Rights

The Nabtesco Group respects human rights in every respect in the context of its business activities. Discrimination based on race, creed, gender, age, social class, national origin, ethnicity, religion, physical or mental disability or sexual orientation will not be tolerated, nor will any act that undermines individual dignity in any other way. The Nabtesco Group complies with human rights and labor laws of all relevant nations and makes efforts to ensure the safety and security of individuals and to avoid infringing upon human rights. The Nabtesco Group will not direct or utilize child labor or forced labor.

4. Human Rights Due Diligence

The Nabtesco Group carries out a human rights due diligence process to identify and assess impacts on human rights and endeavors to mitigate human rights risks. In order to address impacts on or risks to human rights, the Nabtesco Group will verify its human rights due diligence process and the effectiveness thereof on an ongoing basis.

5. Efforts to Address Human Rights Issues with Stakeholders

The Nabtesco Group will endeavor to encourage its customers, suppliers and other business partners to understand this Policy.
 
The Nabtesco Group respects the human rights of all of its officers and employees, treats each of them in a non-discriminatory manner and ensures impartiality in the context of employment, performance evaluation and all other aspects of human resources management, and develops a safe and secure work environment.
The Nabtesco Group will endeavor to keep shareholders and investors adequately informed of this Policy and the Nabtesco Group’s various efforts to respect human rights.
 
The Nabtesco Group acknowledges that its business activities may affect regional communities in some way and thus endeavors to identify and assess human rights risks. 

6. Reporting and Disclosure

The Nabtesco Group’s efforts to respect human rights will be publicly disclosed in the form of an integrated report or in some other appropriate way.

7. Redress and Remedy

If any infringement of human rights caused directly or indirectly by the Nabtesco Group’s business activities is recognized, the Nabtesco Group will promptly take steps to provide redress and remedy.

8. Introduction, Prevalence and Education

To ensure that this Policy is properly understood and reflected in business activities, the Nabtesco Group will provide education and training to all of its officers, employees and other personnel.


 
Corporate Communications Department

Basic Policy on Human Capital Development

Develop personnel who can think and learn on their own at all times as members of a global corporate group, and create a culture that values and supports learning.

Corporate Communications Department

ESH Basic Policy and Management Targets

Basic policy

  • Safety first: Always make safety the first priority based on the principle of respect for human life.
  • Safety is a responsibility of the entire production line: Each employee is responsible for him/herself and his/her co-workers.
  • Safety should be a built-in operation: ESH = your job.

Management targets

  • Environment: Zero cases of environmental problems
  • Safety: Zero cases of industrial accidents
  • Accident prevention: Zero cases of explosions or fire
  • Health: Zero cases of occupational diseases
Corporate Communications Department

Environment Policy

The Nabtesco Group formulated the Environmental Philosophy and Environmental Action Plan in May 2005 to promote activities reflecting our strong sense of social responsibility and to help realize a sustainable society.

Nabtesco Group Environmental Philosophy/Environmental Action Plan
Nabtesco Group Environmental Philosophy
  • At all times, we acknowledge the impact of our business activities on the global environment; we strive to create products and an environment which are both peoplefriendly and nature-friendly; and we aim to achieve a future society which is enriched and comfortable.
Nabtesco Group Environmental Action Plan
  • We acknowledge that the preservation of the global environment is a crucial issue that is common to humankind. With participation by all employees, we will actively promote the establishment of targets which aim to improve the results of our environmental preservation activities, and we will actively promote initiatives for sustainable improvements.
  • We will strive to improve energy, resource and recycling efficiency during the planning, development and design stages of each product by understanding the impact on the environment throughout the life cycle of the product.
  • We will strive to reduce the burden on the environment during the production, sales, distribution and servicing of each product by actively employing or engineering advanced environmental technology, such as for the conservation of energy, the effective use of resources and meeting the challenge of zero emissions.
  • We are committed to voluntary activities designed to realize environmental targets. We will comply with environment-related laws and regulations, as well as with social norms, and we will set independent control standards as necessary.
  • We will actively promote exchange and links with society, and strive to gain wider understanding and trust through such action as the disclosure of environment-related information and participation in social activities.
Corporate Communications Department

Nabtesco Group’s CSR-Oriented Procurement Policy

  1. Compliance with Laws and Regulations and the Establishment of Corporate Ethics
    1. (1) Compliance with the laws, regulations and social norms implemented in the countries and regions where the company conducts business activities
    2. (2) Transparent transactions, which are based on fair and free competition and in compliance with the antimonopoly-related laws and regulations
    3. (3) Appropriate export and import control based on the related laws and regulations
    4. (4) Prohibition of the inappropriate transfer of money and other benefits and of illegal political contribution and donation
    5. (5) Prohibition of the inappropriate treatment of confidential information, personal information and intellectual property rights in relation to business activities
    6. (6) Assurance of accountability and transparency to society through proactive disclosure of information
  2. Respect for Human Rights
    1. (1) Prohibition of inhumane labor, including forced labor and child labor
    2. (2) Elimination of all forms of discrimination based on race, nationality, religion, age, gender and others
  3. Consideration to Employees
    1. (1) Respect for workers’ rights, including the payment of appropriate salaries and proper management of working hours
    2. (2) Provision of safe and clean workplaces where employees can work healthily and with ease of mind
  4. Provision of Valuable Products and Services
    1. (1) Establishment of a business process to ensure the provision of safe and comfortable products and services that people can use with a sense of security
    2. (2) Establishment of a system to ensure the stable supply of products and services that are competitive in the market in terms of quality, pricing and delivery deadlines
  5. Consideration to the Environment
    1. (1) Establishment of an environmental management system to foster sustainable business activities
    2. (2) Reduction of environmental impact through the development of environmentally friendly products, contribution to the mitigation of climate change, reduction of waste and strict management of chemical substances
  6. Consideration to Local Communities and Society
    1. (1) Respect for cultures and customs of the regions and society where the company conducts business activities
    2. (2) Harmony with local communities and society and contribution to the communities and society
Guidelines for Nabtesco Group CSR-Oriented Procurement Policy
Requirements for Suppliers

These guidelines were made as a tool for suppliers to deepen their understanding of “Nabtesco Group CSR-Oriented Procurement Policy.” Nabtesco Group would like all suppliers to understand the purpose of these Guidelines and implement them internally. The Group also requests that your suppliers understand and implement the purpose of these Guidelines.

  1. Compliance with Laws and Regulations and the Establishment of Corporate Ethics
    1. (1) Compliance with the laws, regulations and social norms implemented in the countries and regions where the company conducts business activities
      • Suppliers are required to observe the laws and regulations of the countries and regions where they conduct their respective business activities and encourage fair and faithful business activities according to the social norms of the relevant countries and regions.
      • Suppliers are required to do a self-check on their observation of the laws, regulations and social norms and, if any failure in the observation is found, to make an improvement.
      Specific examples
      • The basic policy for compliance with the laws, regulations and social norms is established (for example, such basic policy is incorporated in the company’s guiding precepts/motto).
      • The basic policy is made thoroughly known to employees through career interviews and training, among others.
      • The manager obtains information relating to the provisions of the laws and regulations applied to his/her company and the establishment of/revision to them (for example, the president obtains the latest information on revised provisions of the Act Against Delay in Payment, etc. to Subcontractors from the Japan Fair Trade Commission).
      • A regular check is carried out for any violation of laws and regulations or any acts against the social norms through career interviews and training of employees, among others.
      • If any problem is found, the degree of impact and the facts are accurately grasped, the causes are investigated, and measures are taken for prevention of recurrence and other actions for improvement.
    2. (2) Transparent transactions, which are based on fair and free competition and in compliance with the antimonopoly-related laws and regulations
      • Suppliers are required to conduct a transparent transaction according to the antimonopoly-related laws, competition laws and other related laws and regulations of the respective countries and regions.
      • Suppliers are required not to engage in any bid-rigging or cartel under any circumstance and must conduct a transaction based on fair and free competition.
      Specific examples
      • The manuals for transactions, which reflect the antimonopoly acts, competition laws and other related laws and regulations are formulated and in place.
      • No agreements or information exchange on sales price and other important terms and conditions for a transaction is made with competitors.
    3. (3) Appropriate export and import control based on the related laws and regulations
      • Suppliers are required to properly conduct import/export transactions in accordance with the related laws and regulations.
      • Suppliers are required to establish a management system for and take appropriate procedures for import/export of cargoes/technologies regulated under the laws and regulations related to import/export to maintain international peace and safety.
      Specific examples
      • The manager obtains information relating to the provisions of the laws and regulations related to import/export applicable to his/her company and any establishment of/revision to them.
      • The procedures for import/export are followed with the recognition that not only products but also information on technologies and software are regulated under the laws and regulations related to import/export for the respective countries and regions.
    4. (4) Prohibition of the inappropriate transfer of money and other benefits and of illegal political contribution and donation
      • Suppliers are required not to bribe government officials, etc. nor provide entertainment or gifts to obtain illicit gains in business, either within or outside Japan. In addition, if they make a political contribution or other donation, suppliers are required to observe the related laws and regulations of the respective countries and regions and endeavor to maintain fair and transparent relations with the government and administrative organs.
      • Suppliers are required not to give or receive any money or services to or from their customers and suppliers beyond the scope allowed by laws and regulations as well as social courtesy and to keep good manners and behave faithfully within an appropriate boundary/distinction.
      Specific examples
      • The basic policy is established that prohibits the provision of entertainment and gifts to government officials.
      • The basic policy is made thoroughly known to employees through career interviews and training, among other means.
      • The manager of accounting checks for any payment not explicitly accounted for.
      • The company returns any money sent to homes or workplaces of employees to those who sent it without using it or takes any other appropriate actions.
    5. (5) Prohibition of the inappropriate treatment of confidential information, personal information and intellectual property rights in relation to business activities
      • Suppliers are required to strictly manage, appropriately use and protect trade secrets, technical information and other confidential information.
      • Suppliers are required to appropriately manage personal information relating to their employees, customers and suppliers, among others, to prevent any illegal or unauthorized acquisition, ownership, use, disclosure or leakage.
      • Suppliers are required to pay attention to the prevention of the infringement of their intellectual property rights and respect the intellectual property rights of other companies and shall not obtain or use such rights of other companies illegally or without authorization (including the illegal copying of software and works). Should they discover any act that infringes on the intellectual property rights of other companies, suppliers are required to take appropriate action.
      Specific examples
      • The rules for management of confidential information and personal information (such as the management of documents and electronic media by locking, security management for personal computers and restriction on access authority) are established.
      • The rules for management of confidential and personal information are made thoroughly known to employees through career interviews and training, among others.
      • The state of management of confidential and personal information is regularly checked.
      • Employees are obligated to affix their respective signatures on a pledge to maintain confidentiality.
      • If any problem is found, the degree of impact and the facts are accurately grasped, the causes are investigated, and measures for the prevention of recurrence and other actions for improvement are taken.
    6. (6) Assurance of accountability and transparency to society through proactive disclosure of information
      • Suppliers are required to endeavor to make a timely and appropriate disclosure of information in terms of business activities, management, financial position, as well as environmental and social aspects to perform the accountability required of a company.
      • Suppliers are required to place emphasis on close communication with various stakeholders (customers, suppliers, employees, shareholders/investors, communities/society, and others).
      Specific examples
      • Efforts are made for information exchange with stakeholders, such as launching a homepage.
      • The business plan and annual financial statements are explained to investors/contributors of funds to the company at least once a year.
      • In the case of great impact on the community or society of the environment as a result of business activities (such as air and water pollution), an immediate explanation is to be provided to customers, suppliers, administrative organs and residents of the local community.
  2. Respect for Human Rights
    1. (1) Prohibition of inhumane labor, including forced labor and child labor
      • Suppliers are required to legally hire employees and guarantee freedom to work and resign according to the will of the employees themselves.
      • Suppliers are required to prohibit the employment of persons below the minimum working age, which is stipulated by the treaties of the ILO (International Labour Organization) and the laws and regulations relating to labor in the respective countries and regions, namely child labor.
      • Suppliers are required to prohibit inhumane labor, such as forced labor under pressure caused by abuse, corporal punishment, harassment (sexual harassment, harassment by verbal abuse and other intimidating acts) and forced harsh labor involving physical risk under an environment without appropriate security measures.
      • Suppliers are required to investigate the place of origin and the distribution process of any minerals included in the materials and parts that they procure when they consist of conflict minerals* related to inhumane acts such as forced labor, child labor and abuse, whose use should be avoided.
        • * Conflict minerals refer to gold, tantalum, tin and tungsten produced in the Democratic Republic of the Congo and surrounding countries, which fund armed and rebel forces in that region.
      Specific examples
      • The basic policy for the prevention of forced labor, child labor, abuse, corporal punishment, harassment, harsh labor involving physical risk and other similar incidents is established.
      • The basic policy is made thoroughly known to employees through career interviews and training.
      • A regular check is made for any forced labor, child labor, abuse, corporal punishment, harassment, harsh labor involving physical risk or other similar incidents.
      • For any forced labor, child labor, abuse, corporal punishment, harassment, harsh labor involving physical risk or other similar incident discovered, the contact information of the internal desk for consultation and the desk for consultation provided by the administrative organs is available so that employees can make a consultation or report.
      • Investigations about whether materials and parts that the company procures include any conflict minerals are regularly conducted.
      • If any problem is found, the degree of impact and the facts are accurately grasped, the causes are investigated, and measures for prevention of recurrence and other actions for improvement are taken.
    2. (2) Elimination of all forms of discrimination based on race, ethnicity, nationality, religion, age, gender and others
      • Suppliers are required not to engage in any act of discrimination based on race, ethnicity, nationality, religion, age, gender and others in recruitment/employment, promotion, remuneration, punishment, and others, excluding capability, aptitude, achievements and other performance-related rationale for the relevant employees.
      • Suppliers are required to ensure an environment where any discriminatory behavior, threatening act or harassment, which hinders the business of or impairs the dignity of employees, are immediately reported and investigated.
      Specific examples
      • The basic policy for the prohibition of all forms of discrimination based on race, ethnicity, nationality, religion, age, gender and others in recruitment/employment, promotion, remuneration, punishment, and others is established.
      • The basic policy is made thoroughly known to employees through career interviews and training.
      • A regular check is made for any discrimination in the recruitment/employment, promotion, remuneration, punishment, and others.
      • For any discrimination found, the contact information of the desk for consultation within and outside the company is available so that employees can make a consultation or report.
      • If any problem is found, the degree of impact and the facts are accurately grasped, the causes are investigated, and measures for the prevention of recurrence and other actions for improvement are taken.
  3. Consideration to Employees
    1. (1) Respect for workers’ rights, including the payment of appropriate salaries and proper management of working hours
      • Suppliers are required to observe the labor-related laws and regulations of the respective countries and regions and manage appropriate wage payment and working hours.
      • Suppliers are required to observe the laws and regulations regarding salary and other benefits as well as welfare of the respective countries and regions. In addition, suppliers are required to provide clear statements on details to their employees in a timely manner.
      Specific examples
      • The manager obtains information relating to the provision of the labor-related laws and regulations and the establishment of/revision to them.
      • The rules for the system of payment and welfare are established according to the laws and regulations.
      • A regular check is made for any violation of laws and regulations relating to salary payment, working hours’ management and welfare.
      • If any problem is found, the degree of impact and the facts are accurately grasped, the causes are investigated, and measures for the prevention of recurrence and other actions for improvement are taken.
    2. (2) Provision of safe and clean workplaces where employees can work healthily and with ease of mind
      • Suppliers are required to conduct regular inspections and maintenance of machinery and equipment and appropriately manage chemical substances, hazardous materials and others that are detrimental to the human body as safety measures to prevent accidents and disasters in the course of work.
      • Suppliers are required to endeavor to maintain the facilities that employees use (offices, toilets, cafeterias, company dormitories and others) clean and hygienic and ensure an environment of safety and hygiene, specifically securing of safe drinking water, management of room temperature, fire prevention measures, ventilation and emergency exits (for evacuation).
      • Suppliers are required to endeavor to give consideration to health improvement, prevention of illness, mental healthcare and other related matters for employees, not to mention health management and guidance for employees as stipulated in laws and regulations.
      Specific examples
      • The rules regarding the safety check of buildings and facilities (including machinery and equipment) and the state of maintenance of and appropriate use of protective gears are established.
      • Education and study sessions relating to safety and hygiene are provided and held regularly.
      • Safety patrols are regularly conducted and improvements are made as necessary.
      • Employees are provided medical examinations according to the laws and regulations.
  4. Provision of Valuable Products and Services
    1. (1) Establishment of a business process to ensure the provision of safe and comfortable products and services that people can use with a sense of security
      • Suppliers are required to build a process of business activities, considering “a sense of security” and “comfortableness” with the top priority on “safety” to provide high value-added products and services that meet the needs of customers.
      • Suppliers are required to endeavor to secure the safety of products in accordance with the safety standards and restrictions (regulations, requirements and others) that are stipulated by the related laws and regulations of the respective countries and regions.
      • Suppliers are required to provide accurate information concerning products and services (such as specifications, quality, handling method and contained materials).
      Specific examples
      • The manager obtains information relating to the provisions of the laws and regulations regarding the safety of products and services, which are applicable to his/her company and the establishment of/revision to them.
      • The safety standards that are stipulated by the related laws and regulations of the respective countries and regions and the design and other standards which conform to the restrictions (regulations, requirements and others) are created and made thoroughly known to the personnel engaging in the operations.
      • The rules for the explanation and indication of products and services to and for customers are established and education and study sessions for them are provided and held.
      • The process of handling any nonconforming quality, damages and injuries arising from products/services and other problems and the division of responsibilities and roles are established and the mechanism for the prevention of recurrence and improvement is constructed.
    2. (2) Establishment of a system to ensure the stable supply of products and services that are competitive in the market in terms of quality, pricing and delivery deadlines
      • Suppliers are required to endeavor to secure quality, price and delivery dates that are competitive in the market in cooperation with their suppliers to stably supply products and services to customers.
      • Suppliers are required to endeavor to continually improve technology development capabilities to supply products and services that are competitive in the market by anticipating the needs of customers.
      Specific examples
      • The basic policy for the continual improvement of quality, price and delivery dates and enhancement of the technology development capabilities is established.
      • The quality targets are established and continual improvements are made.
      • Education and study sessions for the continual improvement of quality, price and delivery dates and enhancement of the technology development capabilities are provided and held.
      • A desk for grasping the needs of customers and reflecting on them for the improvement of products and services is set up and otherwise the internal reporting system/line for such purpose is established.
  5. Consideration to the Environment
    1. (1) Establishment of an environmental management system to foster sustainable business activities
      • Suppliers are required to endeavor to reduce the impact of business activities on the environment to preserve the global environment as an important issue among humans.
      • Suppliers are required to actively push forward with the initiatives for environmental preservation based on the environmental management system in accordance with the environmental laws and regulations of the respective countries and regions.
      Specific examples
      • The basic policy for consideration of the environment and reduction of the environmental burden is established.
      • The manager obtains information relating to the environmental laws and regulations applicable to his/her company and its establishment.
      • Education and study sessions for consideration of the environment and reduction of the environmental burden are regularly provided and held.
      • Environmental objectives are established and continual improvement of environmental initiatives is made according to the environmental management
    2. (2) Reduction of environmental impact through the development of environmentally friendly products, contribution to the mitigation of climate change, reduction of waste and strict management of chemical substances
      • Suppliers are required to endeavor to reduce carbon dioxide and other greenhouse gases, waste, chemical substances that affect the air, water, land and other elements as well as other similar materials emitted and discharged through business activities.
      • Suppliers are required to endeavor to save energy and resources through the three R initiatives, Reduce/Reuse/Recycle; and push forward with eco-friendly business activities.
      • Suppliers are required to properly manage chemical substances used in or created from business activities or manufacturing processes or contained in products according to the related laws and regulations of the respective countries and regions.
      Specific examples
      • The company gasps its energy consumption.
      • The company sets objectives for the reduction of energy consumption and waste and makes specific action plans.
      • The company regularly checks whether waste and chemical substances are managed according to the laws and regulations.
      • The company provides notification and follows renewal procedures relating to the storage/disposal of waste and treatment of chemical substances, among other related matters, according to the laws and regulations.
      • The company makes lists of notifications and qualified persons relating to the storage/disposal of waste and treatment of chemical substances, among other related matters.
  6. Consideration to Local Communities and Society
    1. (1) Respect for cultures and customs of the regions and society where the company conducts business activities
      • Suppliers are required to endeavor to deepen their understanding of cultures and practices of the communities and society where they conduct business activities and create a culture of mutual respect.
      Specific examples
      • Efforts are made for active communication, such as participation in events and activities of the communities and society where business activities are conducted.
    2. (2) Harmony with local communities and society and contribution to the communities and society
      • Suppliers are required to endeavor to contribute to the communities and society on various occasions by making use of their business, technologies, human resources and facilities, including support for the development of children who will carry on in the future.
      Specific examples
      • The company provides opportunities for visits and tours of factories and experience at workplaces to students in elementary, junior high and senior high schools in the local communities.
      • The facilities of the company are open for events in the local communities.
      • The company provides support for environmental activities in the local communities, such as the planting of trees.
      • The company provides a place for emergency evacuation, participates in trainings for disaster prevention and communicates with and provides cooperation to the local communities in preparation against disasters.
      • The company provides support funds and aid supplies to disaster-stricken areas.
      • The company supports the activities for the development of the local communities.
Corporate Communications Department

Corporate Governance Basic Policy

Decision made by: Board of Directors
Person in charge of administration: General
Manager, General Administration Dept.
Enactment date: October 30, 2015
Effective date: October 30, 2015
Amendment date: October 31, 2018

Preface

Based on the resolution of the Board of Directors, Nabtesco has enacted the following basic policy (hereinafter referred to as the “Policy”) to set out its basic approach, framework and policy with regard to corporate governance.

Chapter 1: General Provisions

Basic Approach to Corporate Governance
Article 1:

Based on its corporate philosophy, which states, “The Nabtesco Group, with our unique motion control technology, will provide safety, comfort and a sense of security in daily lives as well as any form of transportation,” Nabtesco shall endeavor to enhance its corporate governance with the aim of realizing its sustainable growth, enhancing its medium- to long-term corporate value and earning the greater trust of its stakeholders through the implementation of “The Nabtesco Way”.

Chapter 2: Ensuring Shareholder Rights and Equality

General Meeting of Shareholders
Article 2:

(1) Nabtesco shall treat its shareholders equally in accordance with the class and number of shares which they hold and shall take appropriate action in order to substantially ensure equal shareholder rights including the exercise of voting rights at the General Meeting of Shareholders.

(2) Nabtesco shall endeavor to develop an environment in the following way, whereby its shareholders are ensured a sufficient period of time to consider proposals submitted to the General Meeting of Shareholders and can appropriately exercise their voting rights.

  • (i) Nabtesco shall send the notice of convocation of the Ordinary General Meeting of Shareholders three weeks prior to the Meeting.
  • (ii) Nabtesco shall make the content of the notice of convocation available at the Tokyo Stock Exchange its website and other places prior to sending it to shareholders.
  • (iii) Nabtesco shall develop an environment whereby it is ensured that all shareholders who cannot attend the General Meeting of Shareholders can appropriately exercise their voting rights through the online voting system and an electronic platform for exercising voting rights.
  • (iv) Nabtesco shall disclose English translations of the notice of convocation and reference materials for the General Meeting of Shareholders, business reports and financial statements available at the Tokyo Stock Exchange, its website and other places as a reference for its shareholders in Japan and overseas in exercising their voting rights.

(3) With regard to a proposal submitted by the company against which a considerable number of dissenting votes are cast at the General Meeting of Shareholders, Nabtesco shall analyze the cause of the voting trend and share the result of the analysis at its Board of Directors’ Meeting and shall consider the necessity of having a dialogue with its shareholders or taking other responses as necessary.

Basic Capital Policy
Article 3:

(1) Nabtesco shall engage in capital cost conscious business management in consideration of return on assets (ROA) and return on equity (ROE) targets in order to maintain and enhance shareholder value. In addition, to prepare for sudden changes in the economic environment, Nabtesco shall aim at keeping a capital-to-asset ratio whereby it can maintain a high credit rating so that it can raise capital irrespective of financial situations.

  • (2) With regard to capital policies that may result in a change of control or significant dilution, Nabtesco shall make rational decisions in sufficient consideration of their effects on the above-mentioned targets at the Board of Directors.
  • (3) In implementing capital raising that may result in significant dilution, Nabtesco shall make resolutions after sufficient deliberation by the Board of Directors on the use of capital and collection programs and shall provide explanations to its investors and shareholders.
  • (4) Nabtesco shall pay out dividends by setting a certain consolidated dividend payout ratio. Nabtesco shall acquire its treasury shares at an appropriate time with the aim of enhancing its capital efficiency in view of comprehensive circumstances such as the market environment and its financial performance.
Basic Policy on Strategic Shareholdings and Exercising of Voting Rights Concerning Strategically-held Shares
Article 4:

(1) “Strategically-held shares” provided in paragraphs (2) and (3) of this Article shall mean listed shares which Nabtesco strategically holds with the aim of maintaining and strengthening business relationships with its business partners etc. (excluding its affiliated companies).

  • (2) Nabtesco shall hold strategically-held shares only in cases where such shareholdings contribute to maintaining and enhancing its corporate value.
    Under a basic policy under which it shall as soon as possible dispose of and reduce strategically-held shares which it finds little significance to holding in light of circumstances as of the end of an immediate fiscal year, Nabtesco shall verify various points concerning each individual stocks, such as whether the purpose of holding the stock is appropriate and whether the benefits and risks accompanied with holding the stock are balanced with capital costs, based on a certain criterion and shall review whether it should continue to hold the stock and the number of shares of the stock which it holds at the Board of Directors’ Meeting every year. Nabtesco shall without delay sell a stock which it finds it inappropriate to continue to hold as a result of the verification in consideration of the stock price, market trends, etc.
  • (3) With regard to voting rights concerning its strategically-held shares, Nabtesco shall examine the details of proposals and shall exercise its voting rights after making decisions comprehensively from the viewpoint of whether or not such proposals contribute to the enhancement of the corporate value of the issuers and Nabtesco.
    With regard to a proposal which has a great influence on the corporate value and shareholders’ common benefits (for example, (i) a proposal to elect an officer when a major scandal occurs or a deficit consecutively continues for a certain period, (ii) a proposal for organizational restructuring including merger, (iii) a proposal for takeover defense measures, etc.), Nabtesco shall confirm its purpose and view for enhancing the corporate value and shall decide whether it votes for the proposal or not; provided, however, that it shall vote against a proposal which would clearly damage the corporate value of Nabtesco as a shareholder.
  • (4) Nabtesco shall not conduct economically irrational transactions with business partners which strategically hold Nabtesco shares. If those business partners indicate their intention to sell Nabtesco shares, Nabtesco shall not engage in acts designed to prevent their sales, such as suggesting a possible reduction of its transactions with them.
Related Party Transactions
Article 5:

(1) Nabtesco shall obtain the approval of the Board of Directors when conducting competing transactions and transactions involving any conflict of interest, which are stipulated in laws and regulations, with its Officers (Directors and Executive Officers). In addition, when conducting such transactions, Nabtesco shall disclose material facts pursuant to laws and regulations.

  • (2) In order to prevent insider trading of Nabtesco shares etc. by its related parties, Nabtesco shall specify matters that shall be adhered to with regard to the management of its material facts as well as the trading etc. of Nabtesco shares etc. by its officers and employees etc. and shall ensure strict compliance with them.
Takeover Defense Measures
Article 6:

(1) Nabtesco has not adopted takeover defense measures.

  • (2) In cases where Nabtesco shares become the target of a tender offer, the Board of Directors shall request such tender offerors etc. to provide explanations on measures to realize sustainable growth of the company as well as to enhance its medium- to long-term corporate value.

Chapter 3: Appropriate Collaboration with Stakeholders

Collaboration with Stakeholders
Article 7:

(1) Nabtesco shall endeavor to engage in appropriate collaboration with its stakeholders by fully recognizing that its sustainable growth and the generation of medium- to long-term corporate value are the results of resources provided by and contributions made by various stakeholders (customers, employees, business partners, local communities, etc.).

  • (2) Nabtesco shall proactively deal with challenges concerning sustainability including social and environmental issues in accordance with the “Nabtesco Group’s CSR Basic Policy,” the “Nabtesco Group Environmental Philosophy/Environmental Action Plan,” the “Nabtesco Group Human Rights Policy,” etc.
Code of Ethics
Article 8:

Having formulated the “Nabtesco Group Code of Ethics” with the objective of ensuring that corporate activities are conducted in accordance with even higher ethical standards, Nabtesco shall strictly implement corporate ethics.

Integrated Reporting
Article 9:

Nabtesco shall issue an integrated report once a year as a means of reporting in a multifaceted manner to its stakeholders its initiatives for solving ESG challenges and activities for achieving sustainable development in addition to information on its management strategies, business situation, management system and financial performance.

Promotion of Diversity
Article 10:

(1) Nabtesco shall endeavor to attain a diverse workforce through non-discriminatory hiring in terms of sex, nationality and disability.

  • (2) Nabtesco shall make efforts to develop an environment where each individual employee can fully demonstrate his/her capabilities and unique personal characteristics.

Chapter 4: Adequate Information Disclosure and Securing Transparency

Criteria for Information Disclosure
Article 11:

Nabtesco shall disclose information pursuant to the Companies Act, the Financial Instruments and Exchange Act and other laws and regulations as well as the Timely Disclosure Rules stipulated by the Tokyo Stock Exchange, on which Nabtesco shares are listed. In addition, Nabtesco shall endeavor to disclose both financial and non-financial information that is not necessarily subject to the above-mentioned disclosure in cases where such information is deemed to be useful in helping investors make decisions.

External Accounting Auditors
Article 12:

Nabtesco shall have the Board of Corporate Auditors and the accounting and finance department cooperate with each other in securing an audit schedule and audit structure in order to ensure that audits by the Accounting Auditors are adequately conducted.

Chapter 5: Enhancement of Corporate Governance System

Organizational Structure
Article 13:

Nabtesco shall choose the Company with Board of Corporate Auditors as its organizational structure under the Companies Act.

Roles and Responsibilities of the Board of Directors
Article 14:

To recognize fiduciary responsibilities to shareholders and enhance its sustainable medium- to long-term corporate value as well as its earnings power, capital efficiency, etc., the Board of Directors shall have the roles and responsibilities specified in the following items:

  • (i) to establish the corporate philosophy, corporate strategy, etc. and determine its strategic directions;
  • (ii) to develop an environment to support adequate risk-taking by management; and
  • (iii) to supervise the Directors, the Executive Officers, etc. effectively from an independent and objective standpoint.
Delegation to Management Personnel
Article 15:

Nabtesco shall establish the “Group Regulations for Responsibility and Authority” and shall specify matters to be resolved, deliberated and reported at the Board of Directors’ Meeting as well as matters to be delegated to management personnel. Specifically, matters that require resolutions by the Board of Directors and significant management-related matters pursuant to the provisions of laws and regulations and the Articles of Incorporation shall be determined by the Board of Directors and all other matters shall be delegated to management personnel.

Composition of the Board of Directors
Article 16:

(1) The Board of Directors shall comprise no more than ten Directors, two or more of who shall be Independent Outside Directors.

  • (2) With the aim of maximizing the functions to fulfill the roles and responsibilities of the Board of Directors, Nabtesco shall have it comprised of highly diverse members in terms of business backgrounds, areas of expertise, gender, international experience and shall, from both inside and outside of the company, elect candidates who have superior character, insights, capabilities, a high level of expertise and ethics as well as ample experience as Directors.
Operations of the Board of Directors
Article 17:

The Board of Directors shall endeavor to foster a culture that respects free and open-minded constructive discussions and opinion exchange. Details of its operations shall be specified in the “Regulations of the Board of Directors”. In order to ensure that Outside Directors can participate actively in discussions, the Secretariat for the Board of Directors shall provide sufficient information by determining handouts, deliberation matters, the annual schedule, etc. in advance while ensuring appropriateness in terms of frequency of meetings, deliberation time, the number of items to be deliberated, etc.

Independent Outside Directors
Article 18:

(1) Nabtesco shall elect two or more Independent Outside Directors who can provide advice that contributes to the enhancement of its sustainable medium- to long-term corporate value as well as supervise management etc.

  • (2) All Independent Outside Directors shall be those who have ample experience, broad insights and diverse stakeholder perspectives as well as shall meet all of the in-house “Criteria for the Impartiality of Outside Officers”.
  • (3) Independent Outside Directors shall convene and hold meetings comprising only Independent Outside Officers as required and shall endeavor to exchange information and share awareness through free discussions based on their objective standpoints, which are independent from business execution.
Roles and Responsibilities of the Board of Corporate Auditors
Article 19:

(1) The Board of Corporate Auditors shall recognize fiduciary responsibilities to shareholders, shall proactively exercise its authority concerning audits on the execution of Directors’ duties, election and dismissal of External Accounting Auditors and remuneration for audit services from an independent and objective standpoint and shall adequately express opinions at the Board of Directors’ Meeting etc.

  • (2) The Board of Corporate Auditors shall aim to collaborate with the Group’s internal audit department through the “Audit Council”, and shall collaborate with Independent Outside Directors to share information and exchange opinions as required.
  • (3) The Board of Corporate Auditors shall fulfill its roles and responsibilities in accordance with procedures, audit criteria, etc. stipulated in the “Regulations of the Board of Corporate Auditors” and the “Criteria for Audits by Corporate Auditors”.
Composition of the Board of Corporate Auditors
Article 20:

(1) The Board of Corporate Auditors comprises five and fewer Corporate Auditors, more than half of whom shall be Independent Outside Corporate Auditors.

  • (2) With the aim of maximizing the functions of Corporate Auditors to fulfill the roles and responsibilities of the Board of Corporate Auditors, Nabtesco shall, from both inside and outside of the company, elect candidates who have excellent characters, insights, capabilities, financial, accounting and legal knowledge necessary for audit, a high level of expertise and ethics as well as ample experience; one or more of whom shall have a sufficient degree of knowledge and experience in the fields of finance and accounting.
  • (3) The Board of Corporate Auditors shall ensures its effectiveness by organically combining the strong independence of Independent Outside Corporate Auditors with the advanced information-gathering capability of Corporate Auditors in order to fulfill the roles and responsibilities of the Board of Corporate Auditors specified in the preceding paragraph.
  • (4) All Independent Outside Corporate Auditors shall meet all of the in-house “Criteria for the impartiality of Outside Directors and Outside Corporate Auditors” (Appendix).
Nomination Committee
Article 21:

(1) Nabtesco shall establish the Nomination Committee as a consultative body of the Board of Directors to deliberate the nomination of candidates for Director, Corporate Auditor, CEO and Representative Director positions as well as a plan for successor to the CEO etc., and to report to the Board of Directors.

  • (2) The Nomination Committee shall comprise three to five members, with a majority being Independent Outside Officers.
  • (3) The Nomination Committee shall establish fair and transparent basic policies and rules in order to execute its duties.
Remuneration Committee
Article 22:

Nabtesco shall establish the Remuneration Committee as a consultative body of the Board of Directors to deliberate the remuneration etc. of management personnel and to report to the Board of Directors.

  • (2) The Remuneration Committee shall comprise three to five members, with a majority being Independent Outside Officers.
  • (3) The Remuneration Committee shall establish fair and transparent basic policies and rules in order to execute its duties.
Nomination of Directors, Corporate Auditors and CEO
Article 23:

(1) In nominating candidates for Director positions and electing the CEO and appointing the Representative Director, the Board of Directors shall, in accordance with Articles 16 and 18, nominate, elect and appoint those who can contribute to the growth of the entire Nabtesco Group and the enhancement of its management as members of the management team in light of their experience and capabilities. The Board of Directors shall nominate candidates for Corporate Auditors upon the approval of the Board of Corporate Auditors in accordance with Article 20.

  • (2) The Board of Directors shall receive reports from the Nomination Committee in order to strengthen the independence, objectivity and accountability of the election etc. specified in the preceding paragraph.

  • (3) The Board of Directors shall develop a plan for a successor to the CEO considering the reports from the Nomination Committee and shall supervise its implementation.

  • (4) If the CEO or Representative Director commits any wrongdoing such as a violation of laws and regulations or finds it difficult to execute his/her duties due to mental or physical disability or if there is any reasonable ground to believe that he/she is disqualified as CEO or Representative Director, the Board of Directors shall make a decision on his/her dismissal or removal after deliberation by the Nomination Committee.
Remuneration of Management Personnel
Article 24:

(1) In deciding the remuneration etc. of management personnel, the Board of Directors shall receive reports from the Remuneration Committee and shall make concrete decisions at its meetings in order to strengthen independence, objectivity and accountability.

  • (2) In order to ensure that remuneration etc. of management personnel functions as a sound incentive toward the its sustainable growth, the following policies have been set out:
    (i) The compensation structure of management personnel shall comprise “monthly compensation,” which is made up of fixed compensation and performance-linked compensation that reflects short-term performance, and a “stock compensation,” which are offered in consideration of medium- to long-term performance. ROIC and current income for improving ROE shall be key indicators as performance indicators. With regard to the operating divisions, the amount of remuneration to be paid shall be decided according to the degree of achievement of targets, such as net sales, operating profit, R&D indicators, environmental indicators, etc. However, the compensation standard and its configuration shall be reviewed as necessary and as appropriate according to changes in the business environment.
    (ii) Remuneration of Independent Outside Directors shall be fixed compensation only, due to their roles and from the perspective of upholding independence.
  • (3) Remuneration etc. of Corporate Auditors shall be decided in consultation with Corporate Auditors. The compensation structure of Corporate Auditors shall be fixed compensation only, with no performance-based compensation, due to the nature of the audit functions.
Assessment of Effectiveness of the Board of Directors
Article 25:

The Board of Directors shall conduct analysis and assessment of the effectiveness of the Board of Directors every year based on the self-assessment etc. of each Director and shall disclose a summary of the results of such analysis and assessment.

Information-gathering by Directors and Corporate Auditors and Support System
Article 26:

(1) Nabtesco shall proactively develop a support system for Directors and Corporate Auditors in order to ensure that Directors and Corporate Auditors can fulfill their roles and responsibilities effectively.

  • (2) Directors and Corporate Auditors shall proactively obtain information in the form of information provided by the company and advice etc. from external specialists in order to fulfill their roles and responsibilities effectively.
Self-improvement and Training for Directors and Corporate Auditors
Article 27:

(1) Prior to joining the Group, newly appointed Directors and Corporate Auditors shall receive training provided by the company’s legal and compliance officers or external training organizations with regard to their roles and responsibilities including corporate governance and legal responsibilities. However, Independent Outside Directors shall receive such training as necessary in light of their own knowledge, capabilities, expertise, etc.

  • (2) When joining the company, newly appointed Independent Outside Directors and Independent Outside Corporate Auditors shall be provided with explanations on the Nabtesco Group’s corporate philosophy, businesses, finance, organization, etc. in order to deepen their understanding of the Group’s business operations. In addition, Nabtesco shall provide newly appointed Independent Outside Directors and Independent Outside Corporate Auditors with opportunities to visit and inspect its plants or offices as necessary.
  • (3) All Directors and Corporate Auditors shall participate in training sessions that are held regularly in order to update their knowledge.
Internal Control
Article 28:

(1) Nabtesco shall develop the “Basic Policies for the Construction of an Internal Control System” pursuant to the Companies Act. The Board of Directors shall regularly check whether such policies are implemented effectively.

(2) Nabtesco shall establish the Compliance Committee as a consultative body of the Board of Directors and shall have such body formulate and amend the “Nabtesco Group Code of Ethics”, deliberate on key issues concerning the Nabtesco Group's compliance system and report to the Board of Directors. The Compliance Committee shall comprise members including Independent Outside Officers and external experts.

(3) Nabtesco shall develop and appropriately operate a whistle-blower system with the aim of discovering and correcting violation of laws and regulations by the Nabtesco Group at an early stage.

Chapter 6: Constructive Dialogue with Shareholders

Constructive Dialogue
Article 29:

(1) Nabtesco shall, from among management personnel, appoint a person who oversees and is responsible for the entirety of communications with shareholders and investors and shall endeavor to realize constructive dialogue with its shareholders and investors, which contributes to its sustainable growth and the enhancement of medium- to long-term corporate value, through collaboration among relevant departments led by an IR department. As efforts to increase a means of dialogues other than individual interviews, Nabtesco shall proactively offer opportunities for dialogues with shareholders and investors through the issuance of a range of publications, which complements timely information disclosure, or the holding of explanatory meetings on performance and business.

  • (2) In holding dialogues with shareholders and investors, Nabtesco shall not only disclose information in a timely, appropriate and fair manner but also shall announce the its efforts to enhance shareholder value, while aiming to understand the views of shareholders and investors about the company and share them internally through feedback to management personnel and relevant departments.
  • (3) Nabtesco shall appropriately manage insider information in accordance with the internal regulations.

Chapter 7: Amendments and Abolition of the Policy

Amendments and Abolition of the Policy
Article 30:

Amendments and abolition of the Policy shall require a resolution by the Board of Directors.

The Nabtesco Way

Nabtesco has been conducting business across a number of sectors, capitalizing on its motion control technology to make significant advances within the areas of transportation (railroad vehicles, aircraft, automobiles, etc.), industry, livelihood-related fields and the environment (robots, construction machinery, automatic doors, etc.).

We contribute to the creation of a safe and comfortable society through the provision of highly reliable products, many of which enjoy large market shares.

We have established The Nabtesco Way in October 2012. The Nabtesco Way is a collective term that means our Corporate Philosophy, Our Promises, and Action Guidelines. We have set these Guidelines by examining the uniqueness of the Nabtesco Group, borne by our predecessors from their efforts and wisdom in developing the Group, and also by incorporating new values to be implemented by Group members toward the future, in order to clearly show the management approach to be taken by our top executives and general managers as well as our strong commitment to quality manufacturing.

「Corporate Philosophy」

The Nabtesco Group, with our unique motion control technology, will provide safety, comfort and a sense of security in daily lives as well as any form of transportation.

「Our Promises」
  • 1 .Value close communications with our customers worldwide
  • 2. Value each individual's spirit of challenge and innovation
  • 3. Continue to expand our business and profit
  • 4. Continue to reinforce our sense of ethics and highly transparent business activities
  • 5.Value the environment and promote harmony with local communities and cultures
「Action Guidelines」
【〜Action Guidelines for Top Management〜】

We shall manage the Nabtesco Group, focusing on the following four points to ensure its sustainable growth as a global corporate group.

  1. Communicate the Present Situation and Future Vision of the Company (Organization) to Employees.
  2. Encourage Active Discussions and Align All Members to a Common Direction.
  3. Ensure Succession.
  4. Manage in a Manner that Increases the Nabtesco Brand and Corporate Value.
【〜Action Guidelines for All Group Members〜】
  • ・Build Trust:Work diligently (kotsukotsu) and expeditiously
  • ・Provide Value:Think ahead from customer's perspectives
  • ・Take on Challenges:Enhance our skills
  • ・Develop Human Resources:Employees are essential assets
  • ・Foster Teamwork:Discuss fully (tokoton) among all members
  • ・Realize our Dreams:Pursue higher reliability and quality
  • ・Make Daily Improvement:Step forward for future growth
  • ・Ensure Transparency:Be open, fair and honest
  • ・Hold a High Work Ethic:Make individual conscientious effort
  • ・Be Considerate of the Global Environment:Do not waste (mottainai)
  • ・Keep Harmony with Local Communities and Cultures:Engage in local activities

By implementing these promises, we will realize "All Stakeholders' Dreams.'

Criteria for the Impartiality of Outside Officers

Nabtesco considers an Outside Officer (Outside Director and Outside Corporate Auditor) to be impartial if all of the following requirements are met in addition to the criteria for independent officers set by the Tokyo Stock Exchange.

  • (1) The Outside Officer is not a current major shareholder*1 or an executive of the Group;
    *1 Person who directly or indirectly holds more than 5% of all voting rights or a person who is listed among the top 10 shareholders in the most recent shareholder registry
  • (2) The Outside Officer is not an executive of a major lender*2 of the Group;
    *2 A financial institution group (person who belongs to the consolidated group to which the Group’s direct lender belongs) from which the Group borrows funds, and from which the Group’s total amount of borrowing exceeds 2% of the Group’s consolidated total assets as of the end of the previous fiscal year
  • (3) The Outside Officer is not a major business partner of the Group (defined by a yearly transaction amount that exceeds 1% of consolidated net sales) or its executive;
  • (4) The Outside Officer is not a person for whom the Group is a major business partner (defined by a yearly transaction amount that exceeds 1% of the counterparty’s consolidated net sales) or its executive;
  • (5) The Outside Officer is not a consultant, accounting professional, or legal professional who receives a large amount of remuneration (more than \6 million yearly) from the Group other than officers’ remuneration (including a case where an organization such as a corporation or an association to which the Outside Officer belongs receives remuneration);
  • (6) The Outside Officer is not an executive of an organization such as a corporation or an association that receives a large amount of donations (more than \6 million yearly) from the Group;
  • (7) The Outside Officer is not a spouse or a relative within the second degree of consanguinity of the Group’s executive; and
  • (8) The Outside Officer does not fall under any of the above-mentioned items from (1) through (6) for the past three years.
  • (9) The Outside Officer holds his/her office as an outside officer of Nabtesco for a period not exceeding eight years in total.
Corporate Communications Department

Nabtesco Group Global Anti-Bribery Policy

1. Scope

This Policy applies to Nabtesco Group and all of its directors, officers and employees.

2. Compliance with Anti-Bribery Laws and Regulations

Directors, officers and employees shall observe and comply with the anti-bribery laws and regulations of all countries (including the Japan Unfair Competition Prevention Act, the US Foreign Corrupt Practices Act, the UK Bribery Act 2010, the anti-bribery laws of China, etc.) in which the relevant business is being conducted or is planned to be conducted, and with all applicable internal rules and regulations including this Policy and the Nabtesco Group Code of Ethics (hereinafter collectively referred to as the “Anti-Bribery Rules”).

3. Prohibition of Bribery

Directors, officers and employees shall not, directly or indirectly, give, offer or promise to give any bribe to any public official or person in the private sector, whether at the expense of the company or of the individual directors, officers and employees.
A “bribe” is defined as any benefit (including entertainment, gift, cash, loan, guaranty, service, invitation, donation, contribution, gratuity, rebate, discount, employment opportunity, etc.) given for the purpose of obtaining an improper advantage in business (hereinafter referred to as a "Bribe").
In addition, payments to public officials which are intended to expedite or facilitate non-discretionary administrative processes or services (Facilitation Payments) are also prohibited under this Policy.

4. Gifts and Entertainment

Nabtesco Group shall enact internal rules and guidelines regarding the provision of gift, entertainment, etc., in order to prevent bribery and ensure the appropriateness of business operations of Nabtesco Group.

5. Engagement of Third Parties

Nabtesco Group shall not engage any individual or organization to provide information, perform services or otherwise assist in carrying out transactions or operations for Nabtesco Group (including a consultant, agent, distributor, customs broker, etc.; hereinafter collectively referred to as a “Third Party”) where said Third Party offers or is likely to offer a Bribe.

6. Record Keeping

Directors, officers and employees shall maintain and update in a timely fashion complete and accurate records of all expenses and payments (including payments to Third Parties) in Nabtesco Group's books, records and accounts to ensure compliance with the Anti-Bribery Rules.

7. Training

Nabtesco Group shall provide periodic education and training for directors, officers and employees to improve awareness of the Anti-Bribery Rules.

8. Reporting

  1. Where a director, officer or employee has questions or concerns about whether a transaction or operation is prohibited under the Anti-Bribery Rules, he/she shall consult with the departments responsible for compliance at his/her company regarding said questions or concerns.
  2. Nabtesco Group shall implement an internal whistleblowing system and encourage directors, officers and employees to report any conduct that violates or may violate the Anti-Bribery Rules. Directors, officers and employees shall not be subject to retaliation, dismissal or any other disadvantageous treatment for whistleblowing.

9. Disciplinary measure

Directors, officers and employees acknowledge and understand that a violation of the Anti-Bribery Rules may subject them to disciplinary action in accordance with internal company rules.

10. Revision

When necessary, this Policy shall be appropriately revised at the Board of Directors meeting of Nabtesco Corporation based on the discussions of its Compliance Committee in response to changes in Nabtesco Group's business or in the applicable laws and regulations.

Corporate Communications Department

Nabtesco Group Community Investment Policy

Policy The Nabtesco Group promises to protect the global environment and promotes harmony with local communities and cultures by practicing The Nabtesco Way. In each region where it conducts business, the Nabtesco Group will proactively engage in exchange and cooperate with local communities in those fields closely related to its business.
Targets
  • To contribute to solving global social challenges
  • To contribute to solving social challenges faced by local communities in each region where the Group conducts business
  • To encourage employees’ spirit of challenge and their innovative way of thinking by contributing to solving social challenges in those fields related to the Group’s business
  • To increase the Group's brand value by contributing to solving social challenges
  • By achieving these targets, to foster the growth of both the Nabtesco Group and local communities and to build long-term relationships of mutual trust
Priority Areas
of activity
Relevance to the Group's
business
Corresponding material CSR issues (materiality) Corresponding
SDGs
Environment
  • Contribution to reducing environmental impact through manufacturing
  • Commitment to addressing global and local environmental issues in each region where the Group conducts business
  • Countermeasures for climate change
  • Environment-friendly manufacturing
  • Reduction of environmental impact through products and services
  • Recycling, reuse and remanufacture of products
7,11,12,13
Education
  • Development of next-generation human resources by using the Group’s expertise and resources gained through business
  • Enhancement of the value chain in collaboration with suppliers
  • Development of human capital and promotion of workplace diversity
  • Local community development
  • Fair, proper and transparent procurement activities
4,5,8,9
Welfare
  • Revitalization of local communities through welfare equipment business
  • Support for diversity and social inclusion in each region where the Group conducts business
  • Local community development
  • Development of human capital and promotion of workplace diversity
  • Provision of safe and comfortable workplaces
5,8,9,10
Corporate Communications Department, 2
Nabtesco Group’s Approach to CSR
Top Message

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Katsuhiro TERAMOTO Representative Director, Presidents and CEO, Nabte...

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