Compliance｜sustainability｜NDK - NIHON DEMPA KOGYO CO., LTD.

NDK sincerely abides by laws, regulations and social norm as business ethics, so that we could fulfill the NDK's philosophy, which is "being aware of its mission and responsibility as the top manufacturer in the world in the crystal products industry".
NDK prohibits illegal financial transactions and criminal act as corruption, extortion and embezzlement. Moreover, NDK establishes Internal Hotline System, acquires information in-house about breaches of laws, regulations, etc., then analyzes and utilizes such information. NDK entirely prohibits unfavorable treatment in personnel evaluation of whistleblowers and collaborators, and set a compliance hotline as the Compliance Committee (in-house) with a women-only contact point and an external hotline (lawyers), so as for all the employees to report or consult their problems.

1．Fair Business Activities

NDK makes sincere efforts to achieve free competition and fair trade, and takes steps to implement appropriate security measures on information that we obtain through business to protect from unauthorized computer access, loss, destruction, manipulation, leakage, so that we could fulfill the NDK's philosophy, which is "providing high-quality service to customers while staying ahead of the marketplace" and "contributing to the surrounding communities and recompensing its investors".

2．Export Control

NDK constructs a fast and reliable export system, obtaining and taking advantage of the following export certifications, so that we could fulfill the NDK's philosophy, which is "being aware of its mission and responsibility as the top manufacturer in the world in the crystal products industry".

（1）Japanese version of Authorized Economic Operator (AEO)
（2）General license by submission of export management compliance program to Ministry of Economy, Trade and Industry

3．Intellectual Property

NDK promotes research and development of highly-advanced technology and products, respecting others' intellectual property rights, so that we could fulfill the NDK's philosophy, which is "providing high-quality service to customers while staying ahead of the marketplace" and "seeking an easier-to-use and more stable oscillation source and creating higher added value".

4．Procurement Activities

In selecting suppliers, NDK makes efforts to evaluate their involvement in environmental activities, quality, price and capability of quality management, production and technique, considering their involvement in CSR (respect of human rights / involvement in health and safety, environment, ethics / exclusion of antisocial organizations, international terror organizations and armed groups). And NDK purchases materials from the suppliers that promote involvement in environmental activities positively, so that we could fulfill the NDK's philosophy, which is "being aware of its mission and responsibility as the top manufacturer in the world in the crystal products industry" and "contributing to the surrounding communities and recompensing its investors".

5．Public Disclosure

NDK discloses sufficient information to shareholders, investors and other stakeholders appropriately and on a timely basis, so that we could fulfill the NDK's philosophy, which is "contributing to the surrounding communities and recompensing its investors".
As widely known, NDK became the first company in Japan to adopt IFRS on May 13, 2010.

Promotion of compliance

We are actively focused on enhancing our policies, practices and trainings to deepen this commitment through establishing committees in each department such as General Affairs, Personnel, Quality Assurance, Sales Purchasing, Legal. Also, we established the Compliance committee in each group company.

NDK Group Code of Conducts

In December 2015, NDK established "NDK Group Code of Conducts" . In April 2019, NDK revised the Conducts. There are three languages version; Japanese, English and Chinese which was distributed to each group company. In NDK, all employees learn and test the contents of the Conducts every year in order to understand its importance.

Internal Reporting System

In all NDK group companies, we established internal reporting system for observing internal situation and regulating violation as well as improving the situation and protecting person who reported. Also, NDK provides three internal report desks superiors, the compliance committee and external law firm, and moreover recording the number of reporting in internal website every half a year. Furthermore, NDK has a system for raising an objection of the internal investigation results, and the report desk for the objection is not only compliance committee and internal report desk but also external law firm other than the one of internal report desk.

Export Control

Authorized Economic Operator (AEO)

An AEO (Authorized Economic Operator) registered company is an operator certified for its freight transportation security management and compliance system which receives the relaxation and simplification of customs procedures. WCO (World Customs Organization) has laid down world standard guideline of AEO, and in Japan AEO was introduced for exporters in March 2006.
NDK headquarters was certified as Authorized Exporter in March 26th, 2008.

AEO system was also introduced in China, and Suzhou NDK was certified General Certified Enterprise in 2009. In 2014, Chinese customs changed its AEO classification. Suzhou NDK took this opportunity to apply for the one rank higher level of AEO and succeeded to obtain the certification. This certification will enable Suzhou NDK to receive more preferential treatments at customs clearance.

Utilization of the open general licensing system on notification of CP to Ministry of Economy, Trade and Industry

A CP (Compliance Program) is a set of internal policies and procedures of a company prescribing a series of export procedures to comply with laws and regulations on security trade management such as the Foreign Exchange and Foreign Trade Act, and to prevent violations. Notification of CP to Ministry of Economy, Trade and Industry will enable NDK to engage in exports exempted from individual review of application for the export license when exporting the restricted items (technologies) which require permission under the Foreign Exchange, and Foreign Trade Control Law.

Privacy Statement

Representative Director and President
Hiromi Katoh
Nihon Dempa Kogyo Co., Ltd.

Nihon Dempa Kogyo Co., Ltd. ("NDK") has been diligent in responding to the trust placed upon NDK by our guests, our trading partners, our shareholders and those who are interested to join NDK, and also NDK has made efforts to fulfill social responsibilities of a corporation.

NDK shall observe the Law concerning the Protection of Personal Information in Japan and other International Regulations, and protect any personally identifiable information such as your name, address, telephone number, and email address ("Personal Information").

The following statement explains how we handle any Personal Information you share with us.

1．Personal Information shall be used for purposes such as the following, and shall not be used exceeding the scope of this purpose.

See the general purpose shown below for example.

[For our guests and trading partners]

To contact and propose on business
To offer information relative to new products
To ship and deliver products

[For our shareholders]

To contact and offer the information corresponding to the shareholders' right to know

[For those interested to join NDK]

To recruit and select for employment

NDK shall not use your Personal Information exceeding the scope of the purpose without receiving your agreements.

2．In principle, any of your Personal Information shall not be provided to the third person/party, except for the cases below.

ⅰ.When we use it cooperating with our affiliates within the scope of Clause 1. In this case NDK shall be responsible for control over Personal Information.
ⅱ.When we obtain your permission.

3．Appropriate security measures shall be taken to protect Personal Information in storage against being lost, damaged, altered, or leaked, etc.

4．NDK shall endeavor to enlighten personnel handling Personal Information by promoting activities including regular training and education on Personal Information protection.

5．NDK shall promptly respond along with our procedures when you request us to disclose your own Personal Information.

6．NDK shall continue to work for improvements in relation to protection of Personal Information. The contents of the improvements shall be reflected from time to time in the basic policy.

[Supplement]

If you have any requests regarding Clause 5 and the others, or any questions regarding our privacy policy, contact us in writing to the following office.

Person in charge of Personal Information protection,
Administration Division
Nihon Dempa Kogyo Co., Ltd.
Merkmal Keio Sasazuka Bldg., 1-47-1,
Sasazuka, Shibuya-ku, Tokyo, 151-8569, Japan

Basic Information Security Policy

Senior Corporate Officer and General Manager of Administration Division
Yuzuru Takeuchi
Nihon Dempa Kogyo Co., Ltd.

NDK Group aims to create a safe, secure, and comfortable future of digital society by delivering highly reliable and high-precision products based on our Corporate Philosophy. To achieve this vision, we have established the Basic Information Security Policy towards improvement of information security, which is one of the vital challenges in our business activities. We will carry out and conduct our business in accordance with this policy and strive to maintain information security.

1．Scope of Application

This policy applies to all information assets managed by NDK Group, including information about customers and business partners, information about our technology, production, sales, etc., and information systems for using such information. Furthermore, this policy applies to all members of NDK Group who handle information assets, including directors, full-time employees, contract employees, part-time employees, temporary employees, etc.

2. Compliance with Laws and Regulations

NDK Group will comply with laws and regulations pertaining to information security, as well as contractual obligations with our customers and business partners.

3. Protection of Information Assets

NDK Group will ensure the confidentiality, integrity, and availability of our information assets by protecting them from all threats through organizational information security measures from human, physical, and technical perspectives. We also require the external and former parties who have dealt with our information assets to action in accordance with this section.

4. Information Security Management System

NDK Group has established an Information Security Committee to maintain and improve the information security measures. The Committee supervises the NDK Group's information security management and promotes initiatives to identify and address the issues concerning information security.

5. Education and Training

NDK Group will provide continuous education and training to all the members to raise awareness of the importance of information security and to ensure proper use of information assets.

6. Continuous Improvement

NDK Group will evaluate whether this policy is complied with, and information assets are handled properly on a regular basis and work to improve the information security management system continuously.

7. Response to Information Security Incidents

NDK Group will take prompt action if an information security incident including violation of laws and regulations should occur, we will try to minimize the impact. We will also investigate the cause of the incident to prevent its recurrence.