Compliance

We established our Compliance Committee as a specialized body that ensures our Group members continue to comply with laws and regulations. The Committee also provides information on corporate ethics and is primarily focused on the items listed below.

A whistleblowing system called the NEG Hotline has been established to help prevent any illegal violations, wrongdoings, or unethical acts and to promote early detection and quick resolution should such acts occur. We have established two consultation hotlines, one that connects employees to the Compliance Committee (internal contact point) and another that connects to an attorney’s office (outside contact point). The confidentiality of the informants is strictly protected at both contact points, so that no unfair treatment will occur.

This whistleblowing system has been set up at all of our subsidiaries, including those outside of Japan, and we are working to ensure that our stakeholders know about the system and that it functions properly.

To raise compliance awareness (for example, for high ethical standards and respect for human rights) throughout our Group, each year we carry out compliance training as a part of an education program for newly hired employees and antitrust seminars for employees engaged in sales activities. We also ensure awareness among management by holding workshops for directors and executive officers. At these sessions, participants take the opportunity to discuss themes such as governance and compliance. In addition, we have designated.

To ensure that all employees are informed on compliance matters, we have established the Group Code of Conduct and Principles of Activities. Wallet-sized cards printed with the Corporate Philosophy Structure, Code of Conduct, Principles of Activities, and an introduction to the NEG Hotline are distributed to employees of group companies in Japan.

With increasing globalization, the importance of preventing corrupt actions such as bribery in international transactions is being recognized worldwide.

Our Group Code of Conduct prohibits the bribery of public officials or others in positions of public service in Japan or any other country. The issue of preventing corruption is addressed in compliance training at our group companies both in Japan and abroad, held during Compliance Awareness Month.

As part of our commitment to maintaining the highest ethical standards, the NEG Group Code of Conduct enforces a strict policy of "taking a firm stance against antisocial forces." This principle is further detailed in the NEG Group Principles of Activities, which provide clear guidelines on expected behavior. To ensure widespread understanding, these principles are distributed to all executives and employees as portable reference cards.

In line with this policy, our General Affairs Division leads efforts in gathering relevant information and, when necessary, coordinates with legal experts, law enforcement, and other organizations to handle such matters systematically.

We recognize the importance of adhering to antitrust laws in promoting fair international dealings.

Our Group Principles of Activities prohibits actions such as price-fixing or cartel agreements, and based on the internal rules at our group companies inside and outside Japan, any contact with a director and an employee of a competitor must be requested ahead of time and reported on afterwards. Adherence to the antitrust laws is covered in our annual group company compliance training, and we also hold seminars on the antitrust laws for employees who work in sales.

We have established a Trade Control Committee as part of efforts to ensure thorough implementation of export controls and compliance with various export-related legal requirements, such as the Foreign Exchange and Foreign Trade Act. Among other things, the Trade Control Committee scrutinizes the implementation of export control procedures, facilitates Foreign Exchange and Foreign Trade Act-related training, and develops internal rules and regulations.

Also, in order to ensure appropriate compliance with import/export customs procedures and tax reporting, we have established the Specified Export Declaration Office and Special Import Declaration Office to facilitate the implementation of trade-related business according to the requirements of the Customs Act and other tariff-related laws. To ensure thorough compliance and greater awareness, we conduct regular Group-wide auditing and employee training in the execution of our operations. These and other initiatives have earned us certification as an Authorized Economic Operator (AEO) by Kobe Customs for both exports and imports. This is a status conferred on those economic operators that have well-developed cargo security controls and legal compliance structures in place. Thanks to this, not only the company but also its overseas subsidiaries are conferred AEO mutual recognition, thereby expediting smoother import/export customs procedures. In addition, we are the only Japanese glass manufacturer to be certified as an AEO for both imports and exports (Current as of March 5, 2024).

Electric Glass (Guangzhou) Co., Ltd. earned recognition as an Advanced Certified Enterprise, the highest status under the Chinese AEO classification system from the local customs.

The NEG Group complies with the tax-related laws and regulations of each country and region to ensure appropriate payment of taxes. We recognize this as a means of contributing to the socio-economic stability and development of these countries and regions, as well as of contributing to the stability of NEG Group business. The NEG Group does not make use of any tax havens for the purpose of tax avoidance.

Responsibility for tax accounting governance of the NEG Group is assumed on a tax item-by-item basis by the executive officers of the departments to which said tax item are assigned. In addition, each department is in charge of supervising the appropriateness of tax accounting.

The NEG Group utilizes a transfer pricing calculation method based on the OECD Transfer Pricing Guidelines, as well as the transfer pricing taxation systems of each country, to determine transaction prices between group companies according to an analysis of respective group company functions, assets, and risks. Also, in order to maintain the predictability of transfer pricing taxation, we utilize advance pricing agreements (APA) when called for to ensure appropriate payment of taxes.