We incorporated compliance education into the training provided by the Human Resources Development Department to employees for each position.
This year, we provided online training in compliance education, which we have been providing since FY2011, with a focus on security trade control and the Subcontract Law. Training that we gave in FY2018 included two new e-learning training courses — one focusing on the prevention of bribery which was completed by 96% of participants (1,695 of 1,773), and the other highlighting insider transactions, which was completed by all of the participants (92 of 92). We will continue to provide e-learning training for in FY2019.
| Security Export Control, Applicability assessment | Security Export Control, Basics | Subcontract Law | Prevention of bribery | Prevention of Insider Trading | |
|---|---|---|---|---|---|
| Participants | 421 persons | 568 persons | 709 persons | 1,773 persons | 92 persons |
| Participants who have completed | 382 persons | 515 persons | 686 persons | 1,695 persons | 92 persons |
| Completion rate | 91％ | 91％ | 97％ | 96％ | 100％ |
Training for Mid-Career Employees
Training for Second-Year Employees by Staff Members of Specialized Units of the HeadquartersIn FY2018, we conducted a compliance awareness survey covering every employee working for Nabtesco or its domestic Group companies to understand the degree of compliance awareness across the Nabtesco Group. The awareness survey, which has been carried out every two years since FY2006, will be conducted every year, starting from FY2018.
As part of our risk assessment of overseas group companies, based on materials published by NGOs and governmental institutions, as well as questionnaires, we are working to identify high risk countries and regions, and to mitigate risks there via monitoring and other measures.
In FY2018, China’s regional headquarters organized a compliance training session. The session was attended by 346 employees from 10 Group and partner companies. In the session, the understanding and spread of the Nabtesco Group Code of Ethics were secured as well as thorough awareness of prevention of bribery, whose risk is high in China. We will continue to support compliance activities led by local companies. Moreover, we publish a bi-monthly newsletter on compliance in Chinese, and strive to foster employees’ awareness of compliance.
We publish newsletters on compliance in the Thai language on a monthly basis as we do in China to enhance the level of compliance awareness among Thai employees. In FY2019, we will visit local facilities in Southeast and South Asia in order to provide group-based training to ensure that the Nabtesco Group Code of Ethics and to deepen their understanding and to make the information shared by local employees, for the prevention of bribery which has high risk in these areas.
We provided compliance training for eight group companies in Europe. The training was attended by 70 employees. Through this training, we sought to ensure that the Nabtesco Group Code of Ethics are understood and shared by local employees, while also helping them understand the necessity of preventing bribery and updating them on the introduction of the Global Hot Line system. Going forward, we will continue to make efforts to facilitate employees’ understanding by utilizing e-learning, among other measures.
We provided compliance training for four group companies in the U.S. The training was attended by 402 employees. Through this training, we sought to ensure that the Nabtesco Group Code of Ethics are understood and shared by local employees, while also helping them understand the necessity of preventing bribery and updating them on the introduction of the Global Hot Line system. Going forward, we will continue to make efforts to facilitate employees’ understanding by utilizing e-learning, among other measures.
In coordination with the Human Resources Development Department, we provide employees preparing for overseas assignments with training on legal risks specific to the host country on an as-needed and individual basis. In FY2018, the training was provided to employees assigned to Italy, China and Switzerland.
Poster for Corporate Ethics Month in FY2018 (left) and Poster for Survey on Compliance Awareness in FY2018 (right)Since FY2011, we have designated every October as “Nabtesco Group Corporate Ethics Month” and have been conducting an intensive campaign, led by top management, to raise awareness of compliance among employees of Nabtesco Corporation and its Group companies in Japan.
In FY2018, we distributed CEO’s video message on compliance internally, including the subsidiaries in Japan and abroad, while at the same time conducting Compliance Awareness Survey covering employees companywide including those of the subsidiaries in Japan and abroad. (The number of employees who responded to Compliance Awareness Survey increased 990 from that in the previous survey, to 5,360 in total.)
To raise employees’ compliance awareness, we used the intranet as well as handouts to disseminate information to all employees. Going forward, we will continue to engage in educational activities.
To strengthen the Group-wide and global compliance system, the Nabtesco Group has established the Nabtesco Group Code of Ethics.
The Legal & Compliance Department, which is in charge of compliance issues, fulfills a central role by increasing employees’ compliance awareness in addition to fostering their compliance with laws and regulations in order to enhance the Group’s corporate value over the medium- to long-term. The Nabtesco Group Code of Ethics defines actions that each officer and employee should take to realize the corporate philosophy in his/her business activities from compliance perspectives.
In order to help each officer and employee deepen their understanding of this Code of Ethics and take actions that are in line with it, we have prepared a Compliance Handbook, which is used for compliance education and awareness-raising activities. The Code of Ethics and the Compliance Handbook is available in nine languages (Japanese, English, Simplified Chinese, Traditional Chinese, Korean, Thai, German, Italian and French) on Nabtesco’s website.
We also conducted education activities at all Nabtesco Group companies outside Japan to disseminate the Code of Ethics from FY2017 to FY2018. Going forward, we will ensure that the Code of Ethics is understood and embraced by employees through group-based on-site training in Japan and overseas, as well as programs for e-learning.
Implementation of the Nabtesco Group Code of Ethics
According to the Rules for the Group Compliance Promotion System, the Compliance Committee, which includes experts from outside the company, is in place as an advisory body to the Board of Directors.
In addition, by appointing Chief Compliance Officer and Compliance Officer to support supervisors for all corporate divisions, in-house companies and Group companies both in and outside Japan, we have a system in place to increase compliance system on a group-wide and global scale. Compliance meetings are held in Japan as necessary in which Chief Compliance Officer and Compliance Officer exchange information with respect to compliance. In FY2018, we took advantage of a meeting attended by managers from overseas local subsidiaries in China, Europe and Asia to provide information related to compliance and exchange opinions. We are in the process of making preparations to hold a compliance meeting in the United States in FY2019. Going forward, we will continue to organize such a meeting on a global basis.
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