Compliance

As a company guided by the corporate mission, "Wave Motion Tech Moves Our Future!", we are sincerely committed to contributing to the realization of a comfortable, safe, and secure future society and to promoting world peace. To achieve this, we strive to comply not only with laws and regulations but also with ethical standards and other social norms.

Compliance

NDK has established the NDK Group CSR Guideline based on the Company's Code of Corporate Ethics. Under this guideline, we eliminate relationships with antisocial forces and conduct business activities in compliance with laws and regulations in areas such as labor, occupational health and safety, environment, and ethics.

The guideline is aligned with the Responsible Business Alliance (RBA) Code of Conduct and the ordinances for eliminating organized crime groups enacted by prefectural governments in Japan.

NDK defines compliance within the NDK Group as adherence to the NDK Group CSR Guideline, and we have established a framework to ensure compliance and monitor its status across the Group.

Implementation of Compliance Management

In response to recent human rights violation cases reported in the media, the Compliance Committee has taken steps to further strengthen compliance across the Company. These measures include the implementation of CSR training for all employees and the establishment of various related regulations to reinforce the compliance framework. In May 2025, the President and Representative Director issued a Compliance Management Declaration to the entire Group.

To promptly detect any deviations from the CSR Guideline and take corrective action, the Company has established an appropriate monitoring system in collaboration with the Internal Audit Office and the Audit & Supervisory Board.

Internal Reporting System

As part of our compliance monitoring framework, the NDK Group fundamentally restructured its internal reporting system in October 2025. This system is designed to collect internal information regarding acts that violate laws, raise compliance concerns, or constitute harassment, and to take corrective action. In addition, by analyzing and utilizing such information, we aim to further strengthen our compliance framework.

While the primary reporting route is through the standard reporting line to supervisors, we have established multiple channels to improve effectiveness. These include reporting to the General Manager of General Affairs & Personnel, the General Manager of Legal & Intellectual Property, the Standing Auditor, and external reporting contacts, making internal reporting easier and more accessible. Furthermore, the scope of reporting is not limited to violations of laws or compliance concerns and harassment but also includes complaints, consultations, and suggestions for improvement.

We strictly prohibit any attempt to identify whistleblowers or investigation collaborators, as well as any disadvantageous treatment of them (such as personnel evaluations or employment conditions). Measures are also in place to exclude interested parties from investigations to ensure fairness.

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