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 team members (employees) are familiar with the Group’s Corporate Philosophy and the TDK Group Code of Conduct 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 Group Code of Conduct and provides annual training on corporate ethics, prohibition of bribery and corruption, competition laws, and other topics to team members not only in Japan but also at overseas business locations, including both classroom-style instruction and e-learning.
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 team members’ compliance with corporate ethics. In addition, the Business Ethics Supervisory Committee regularly reports on TDK Group compliance to the Board of Directors.

TDK Group Code of Conduct

The TDK Group Code of Conduct stipulates specific behavior guidelines for the TDK Group, and constituent officers and team members, to observe laws, regulations, and social norms.

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Governance

Compliance Structure

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 team members 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, selects priority risks to be addressed by the Group, assigns and evaluates individual risks to risk owner divisions, provides instructions to risk owner divisions, and monitors the 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.

Risk Management

The TDK Group has established structures to enable team members 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, team members and others making reports can select the reporting route that they believe to be the most appropriate.
Reports received via the helplines are investigated. In the event of a violation of the Group Code of Conduct being confirmed, the parties concerned may be subject to penalties in accordance with the work rules and other internal regulations.
The Group Code of Conduct stipulates the protection of informants so that they do not suffer any unfair treatment or disadvantages.

Initiatives

Spreading Awareness of Corporate Ethics

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

Preventing Discrimination & Harassment

TDK Corporation has established "Detailed Regulations on the Prevention of Harassment," which define harassment and prohibited acts, and has set up helplines to which people can submit complaints and a harassment consultation desk in each region to provide an environment that enables team members to easily consult on harassment.
When a report has been received, if the results of an investigation conducted by the Business Ethics Supervisory Committee, the Ethics Council or a related division confirm that harassment has occurred, disciplinary action (which may include dismissal, demotion, suspension, reduction of salary, or the issuing of a formal warning) will be taken against the infringing party, while safeguarding the person who submitted the report to ensure that they do not suffer adverse treatment or harm. TDK will also strive to ensure that no similar incident occurs again in the future. Even if the case is not serious enough to warrant formal disciplinary action, guidance may be provided on how to improve one's behavior. Where necessary, counseling is provided to the individual whose conduct was the subject of the complaint, in order to improve the way in which they interact with team members, and to bring about a change in their behavior so that their future words and actions will not constitute harassment.
As part of its initiatives to prevent harassment, TDK provides harassment prevention education for all team members that makes extensive use of e-learning. Besides introducing case studies of incidents that have actually occurred at TDK, this e-learning also includes learning content that should be of widespread use in preventing harassment from occurring.
TDK also provides training for these team members with human resources functions (including managers), covering harassment case studies, how to handle requests for consultation regarding harassment, and how to deal with cases of harassment when they occur.

Initiatives to prevent harassment are being implemented globally, and in the ASEAN region in particular, efforts are being made to prevent harassment by conducting training based on specific case studies.

Educating Employees on How to Use Helplines

Information on how to use consultation helplines is disseminated through education and training (including e-learning), posters, intranet postings, and distribution of cards with helpline contact information.