Sustainability | GovernanceCorporate Ethics and Compliance

Basic Policy

The TDK Group bases its corporate ethics and compliance on top management demonstrating leadership in raising awareness among officers and employees and comprehensively ensuring proper action.
Specifically, to thoroughly disseminate the TDK Group’s corporate philosophy, the TDK Code of Conduct, and the TDK Charter of Corporate Behavior, we hold group education, e-learning, and other activities relating to corporate ethics in general every year for all employees of the TDK Group globally.
Global corporate ethics structures centered on the Business Ethics Subcommittee have been established to perform periodic monitoring regarding the status of compliance with corporate ethics, and reports are made to the Board of Directors via the Business Ethics Subcommittee every quarter regarding the status of compliance.

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.

Compliance

TDK will ensure that all members of the TDK Group conduct themselves in a compliant manner according to common standards worldwide, nurture a sincere, fair, and transparent corporate culture, and respond to the trust and expectations of customers and society.
With the aim of efficiently carrying out initiatives for this purpose, TDK will identify Group compliance risks that it deems to be especially important from the perspective of legal risk management and address them in a priority manner.
The TDK Group has appointed a Global Chief Compliance Officer and Regional Chief Compliance Officers for each of the five regions worldwide and established the Legal & Compliance HQ directly under the President.
In Japan, TDK has established items relating to compliance and the code of conduct in personnel evaluation, ensures opportunities for employees to conduct regular self-assessment, and motivates them to behave in a compliant manner.
Regarding compliance-related problems that do arise, the divisions responsible confirms the facts, takes appropriate action, and reports to the Board of Directors in a timely manner. In addition, the relevant division cooperates with the Legal & Compliance HQ to analyze the causes and takes measures to prevent reoccurrence at each Group company.

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.

As of April 1, 2022
Number of Consultations and Reports to Helplines (Global)
Fiscal 2016 300
Fiscal 2017 192
Fiscal 2018 121
Fiscal 2019 115
Fiscal 2020 46
Fiscal 2021 54
Fiscal 2022 79
  • The scope of figures includes the Ethics Councils of affiliates.

Spreading Awareness of Corporate Ethics

TDK provides every TDK Group employee with a copy of the TDK Code of Conduct Handbook, which they can use as a guide for their individual business activities, and also endeavors to spread awareness by, for example, displaying posters.
Also, in order to deepen employees’ understanding of corporate ethics, TDK implements training for specific ranks of employees and e-learning for all employees, as well as lectures for management by responsible directors and outside speakers.

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 are independent 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.
In addition, in order to promote appropriate conduct and prevent discrimination, harassment, unfair treatment and disadvantage from occurring, the companies provide training to employees and managers.
Business Ethics Supervisory Committee shall report on the execution and operation of the TDK Code of Conduct to the board of directors of TDK every quarter term.
TDK Corporation has established "Detailed Regulations on the Prevention of Harassment," which defines harassment and prohibited acts, and set up a harassment consultation desk in each workplace to provide an environment where employees can consult with appropriate representatives, including female counselors, regarding harassment. In addition, 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.

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