Sustainability | GovernanceCorporate Ethics and Compliance

Our Approach

The TDK Group’s top management takes the lead to ensure that all TDK Group directors, officers and employees are familiar with the Group’s Corporate Philosophy, the TDK Code of Conduct, and the TDK Charter of Corporate Behavior and that they are thoroughly aware of and committed to corporate ethics and compliance.
In addition, the TDK Group regularly monitors compliance with the TDK Code of Conduct and provides global annual training to employees, including e-learning and other educational activities relating to corporate ethics.
Furthermore, the TDK Group has built a global corporate ethics management structure centering on the Business Ethics Supervisory Committee, which regularly receives reports on TDK Group employees’ compliance with corporate ethics. In addition, the Business Ethics Supervisory Committee regularly reports on TDK Group compliance to the Board of Directors.

TDK Code of Conduct

The TDK Code of Conduct stipulates specific behavior guidelines for the TDK Group, and constituent officers and employees, to observe laws, regulations, social norms. Among them, items that should be shared and practiced by the TDK Group have been formulated as the TDK Charter of Corporate Behavior.

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Governance

Pursuant to a resolution of the Board of Directors, TDK appoints the Global Chief Compliance Officer (GCCO) from among the corporate officers and the GCCO heads the TDK Group Compliance Committee. Furthermore, the GCCO serves as chair of the Compliance Committee and appoints Regional Chief Compliance Officers for four regions around the world in addition to Japan.
Through these efforts, the TDK Group will further strengthen the company’s compliance structure to ensure that all employees act in accordance with compliance based on global common standards, and foster a corporate culture of integrity, fairness, and transparency in order to meet the trust and expectations of customers and society.
In addition, the Compliance Committee approves company-wide compliance activity policies and plans, evaluates and selects priority risks to be addressed by the Group, assigns individual risks to risk owner divisions, provides instructions to risk owner divisions, and monitors that status of their activities. Risk owner divisions take action to resolve compliance issues that arise and take measures that are necessary from the perspective of preventing recurrence. The GCCO reports the details of these activities to the president and periodically reports to the Board of Directors.

Spreading Awareness of Corporate Ethics

TDK provides every TDK Group employee with a copy of the TDK Code of Conduct Handbook and recommends them to carry it around with them. Employees can use the handbook as a guide in their individual business activities. We also endeavor to spread awareness of the Code of Conduct’s content through, for example, the display of posters.
In addition, the TDK Group conducts regular training on the TDK Code of Conduct and internal rules through e-learning, training, lectures by outside experts, and other means to ensure that the officers and employees who make up the TDK Group act in compliance with laws and regulations.
Furthermore, in Japan, the TDK Group has created items relating to compliance and the Code of Conduct in personnel evaluations and reflects them in employee compensation. Through these efforts, the Group provides employees with regular opportunities to reflect on their own conduct and motivates to act in accordance with compliance requirements.

Helplines

The TDK Group has established structures to enable employees to anonymously make internal reports and consult regarding issues of corporate ethics through channels other than their regular work chain of command. Each Ethics Council has a consultation hotline, and internal helplines have been established on a regional basis for the direct collection of information and opinions relating to corporate ethics and other issues within the Group. In addition to the regular reporting routes within the Group, alternate reporting routes that provide access to outside law firms and other third parties have also been established in the Americas, Europe, and Asia. As a result, employees and others making reports can select the reporting route that they believed to be the most appropriate.
Reports received via the helplines are investigated. In the event of a violation of the Code of Conduct being confirmed, the parties concerned may be subject to penalties in accordance with the work rules and other internal regulations.
The TDK Code of Conduct Program stipulates the protection of informants so that they do not suffer any unfair treatment or disadvantages.

Initiatives

Preventing Discrimination & Harassment

TDK Code of Conduct clearly states that the TDK Group will not engage in any discrimination based on including, but not limited to, race, belief or gender, or any offensive or degrading conduct, such as corporal punishment, mental or physical violence, abusive language, sexual harassment, power harassment, or moral harassment, and will take measures to prevent unjust treatment and discrimination in the workplace.
The TDK Group companies have established policies and procedures, in accordance with the TDK Code of Conduct and national and local laws and regulations, that define and strictly prohibit discrimination and harassment. Based on the policies and procedures, the companies seek to provide an environment in which employees can consult with appropriate representatives regarding their concerns, and have set up mechanisms and reporting structures for employees to use to file complaints of discrimination and harassment in the workplace. Specifically, the TDK Group has established a global whistle-blowing mechanism that allows employees of the TDK Group to consult and report through internal and external helplines that ensure independence from the business lines. If Business Ethics Supervisory Committee, Ethics Councils or the relevant department investigates a report received through the helplines and finds that the TDK Code of Conduct has been violated, the Company will take disciplinary action against the violator, while protecting the informant from any unfair treatment or disadvantage.
Business Ethics Supervisory Committee periodically reports on the execution and operation of the TDK Code of Conduct to the Board of Directors of TDK.
TDK Corporation established "Detailed Regulations on the Prevention of Harassment," which define harassment and prohibited acts, and set up helplines and a harassment consultation desk in each region to provide an environment that enables employees to easily consult on harassment. In an effort to prevent harassment from occurring, "Harassment Prevention Communication Training" is provided for managers to learn how to deepen communication while preventing harassment and harassment prevention training is conducted for all employees via e-learning.