We build a sustainable future through transparent management,
shared growth with partners, and commitment to environmental safety.
As an affiliate of the Nissan Chemical Group, NCK Co., Ltd. has established the NCK Corporate Ethics Guidelines, anchored in the group’s Code of Conduct, Human Rights Policy, and Anti-Corruption Policy.
In accordance with our Compliance Basic Policy, we have formulated comprehensive compliance rules and manuals. To maintain, enhance, and promote high ethical standards, we have established a Compliance Committee and defined specific regulatory guidelines for all operations.
Furthermore, we operate an internal reporting system, the "Counseling Hotline," to prevent compliance violations and ensure prompt resolution of any issues.
Compliance is the cornerstone of our corporate activities. Recognizing its vital importance, all NCK employees act with the highest standards of integrity and sincerity. Together, we strive for sustainable growth and the realization of our vision: "A company that contributes to a more convenient and enriched life for humanity."
NCK supports international norms, including the UN Global Compact and the UN Guiding Principles on Business and Human Rights.
We are dedicated to upholding the human rights of all stakeholders, including our employees, through the implementation of this policy.
1. Prohibition of Forced and Child Labor
We strictly prohibit child labor below the legal minimum working age defined by the laws of each country and region. We do not tolerate forced labor, slave labor, or labor resulting from human trafficking. The same standards are required of our business partners.
We do not unreasonably restrict the freedom of movement for employees within company facilities. Furthermore, no unreasonable constraints are imposed on employees' temporary absence from their workstations or their right to terminate employment.
2. Sound Labor-Management Relations
We recognize and guarantee the freedom of association and the right to collective bargaining.
3. Fair and Equitable Compensation
We provide fair and equitable compensation in full compliance with all applicable wage laws, including minimum wage, overtime pay, and legally mandated benefits.
4. Non-Discrimination
We are committed to providing equal opportunities in recruitment, placement, promotion, and professional development.
NCK supports international norms, including the UN Global Compact, and has established the following Anti-Corruption Policy.
This policy supplements our corporate compliance framework and applies to all executives and employees.
Corruption: The abuse of professional authority for personal or corporate gain, including, but not limited to, bribery.
Bribery: In the course of business operations:
① Executives or employees provide improper benefits to a third party to induce illegal or fraudulent acts, or do so upon a third party's request.
② Executives or employees request or receive improper benefits from a third party.
We maintain a zero-tolerance policy toward all forms of corruption.
We strictly prohibit any involvement in corrupt practices with public officials, government entities, or other business partners.
Furthermore, we continuously urge our business partners to refrain from and prevent any involvement in corrupt activities.
We comply with all domestic and international anti-bribery laws—including the Unfair Competition Prevention Act, the U.S. Foreign Corrupt Practices Act (FCPA), and the Chinese Anti-Unfair Competition Law.
We ensure that all accounting books and transaction records are accurately maintained and preserved. Furthermore, we require our business partners to adhere to these global anti-bribery standards.
In the event of an incident that violates this policy, NCK will take prompt corrective action and cooperate fully with investigations conducted by relevant authorities.
NCK recognizes that minerals (Gold, Tin, Tantalum, Tungsten, and Cobalt) mined or traded in Conflict-Affected and High-Risk Areas (CAHRAs) can serve as a source of funding for conflict, human rights abuses (such as child and forced labor), environmental destruction, and corruption.
To ensure we are not complicit in such inhumane activities, NCK does not use minerals, raw materials, parts, or products mined or distributed under the influence of armed groups in these regions. Should the use of such minerals be identified within our supply chain, we will take immediate remedial measures.
We share this policy with all suppliers and business partners, requesting their full cooperation to ensure that all materials used in
NCK products remain conflict-free.
While compliance is often interpreted as mere adherence to laws and regulations, NCK Co., Ltd.
defines it more broadly to earn the highest level of public trust and social credibility. To us, compliance means "strictly complying with
all laws and internal regulations related to our business activities and adhering to social norms in every aspect of our operations."
Compliance with Business Laws and Regulations
We comply with all laws and regulations related to our products and services. We ensure that all necessary permits, licenses, and reporting procedures are strictly and accurately followed.
Regulation of Donations and Political Contributions
① All political contributions and donations to organizations shall comply with relevant laws, such as the Public Official Election Act and the Political Funds Act, and shall be executed through official and legal channels.
② Any donation or contribution shall receive prior internal approval in accordance with company regulations.
③ We strictly abstain from bribery, improper benefits, or illegal political contributions. We avoid any actions that could be perceived as collusive ties with political or administrative entities, striving instead to maintain healthy and transparent relationships.
Severing Ties with Anti-Social Forces
① We shall act with fundamental legal knowledge, social common sense, and a sense of justice to avoid involvement in any illegal or anti-social activities.
② We maintain a resolute stance against anti-social forces and strictly prohibit any association with them. We do not yield to unjust demands and never attempt to resolve issues through illicit monetary settlements.
③ Utilizing anti-social forces for the benefit of the company or oneself is strictly prohibited.
④ No transactions must be conducted with anti-social forces or business partners associated with them.
Compliance with the Monopoly Regulation and Fair Trade Act (hereinafter referred to as the "Fair Trade Act")
We promote fair and free competition. NCK prohibits any acts that violate fair trade laws, including cartels, collusion, resale price maintenance, and the abuse of a dominant market position.
① We refrain from unfair trade restrictions, such as discussing or deciding prices, quantities, or production facilities with competitors or industry associations, as well as bid-rigging.
② We prohibit unfair practices such as collective boycotts against specific operators (e.g., discount retailers) or new market entrants, and we do not impose restrictions on the resale prices of our distributors.
③ We must not engage in private monopolization by dominating or excluding the business activities of other entities, whether independently or in collusion with others.
Fair Transactions with Suppliers and Compliance with the Fair Transactions in Subcontracting Act (hereinafter referred to as the "Subcontracting Act")
We treat all suppliers with integrity and good faith, ensuring they are handled with fairness and equity.
① When selecting suppliers from multiple candidates, we determine the optimal partner by impartially evaluating various factors, including quality, price, delivery schedules, R&D capabilities, and supply stability.
② In the selection and evaluation of suppliers, we must not exert undue influence or grant preferential treatment to any specific supplier, regardless of our market position or influence.
③ When commissioning manufacturing, repairs, the creation of information work products, or service assignments to subcontractors, we shall conduct contracts and transactions with a thorough understanding of the Subcontracting Act to prevent unfair practices, such as payment delays.
Prevention of Unfair Competition
① Under no circumstances must we acquire or use the trade secrets of other companies through improper means, such as theft.
② We must not use any third-party trade secrets with the knowledge that they were acquired through improper means, or where there is a reasonable suspicion of such illicit acquisition.
Compliance with Security Export Control Laws and Regulations
① We strictly prohibit the export of weapons, armaments, or any products and technologies that may undermine the maintenance of international peace and security.
② For all export transactions, we shall thoroughly verify the partner's profile and business activities to ensure that exported goods or technologies are not utilized in the development or manufacture of weapons of mass destruction (WMD).
③ For export and service transactions regulated by law, we shall carefully evaluate the transaction considering international geopolitical situations and strictly follow all necessary legal procedures.
Compliance with Import and Export Regulations
① We ensure appropriate customs clearance procedures for the import and export of goods in accordance with all relevant laws and regulations.
② The export of prohibited goods and the import of banned products are strictly forbidden.
Prohibition of Excessive Entertainment and Gifts
① We strictly prohibit providing entertainment or gifts to public officials (or those in equivalent positions) that violate anti-corruption laws or the Public Service Ethics Act.
② Entertainment or gifts provided to business partners shall remain within the bounds of socially accepted norms.
③ If offered entertainment or gifts that exceed socially accepted norms, employees must consult with their supervisor to determine the appropriate response.
Prohibition of Bribery to Foreign Public Officials
We prohibit the provision, promise, or offer of money or any improper benefits to officials of foreign governments or local public entities for the purpose of obtaining unfair business advantages or in exchange for business favors.
Ethical Promotion and Advertising
Promotional materials and information must not contain defamatory or slanderous expressions, nor any terms associated with social discrimination.
Comparative advertisements shall be substantiated by facts and ensure that the information is complete and not misleading at the time of comparison.
Ensuring Product Safety
① We prioritize safety at every stage—including manufacturing, development, import, storage, sales, export, and maintenance. We shall fully understand and comply with all product safety laws and standards to ensure the highest level of product safety.
② Upon receiving any information regarding product safety, we must verify the facts immediately. If an issue is identified, we must notify the relevant departments and take swift, appropriate action.
Environmental Preservation
① In research, development, manufacturing, sales, and disposal, we recognize the vital importance of environmental protection and comply with all international treaties and environmental laws. In alignment with the principles of RESPONSIBLE CARE, we strive to minimize waste throughout the entire lifecycle of chemical substances, from development to disposal.
② We aim to enhance environmental awareness and ensure the efficient use of resources and energy.
Implementation of Safety and Disaster Prevention
We properly manage the manufacturing, storage, sales, transportation, and use of potentially hazardous substances to prevent accidents and disasters.
In the event of an incident, we commit to early containment to prevent the situation from escalating and to ensure public and workplace safety.
Furthermore, equipment handling substances typically considered non-hazardous (such as air or steam) must never be operated in a manner that deviates from its design specifications.
Disclosure of Management Information
We shall accurately disclose management information, including financial status and business activities, to our shareholders and stakeholders in a transparent manner.
Proper Accounting Practices
All bookkeeping and voucher entries shall be recorded accurately in accordance with relevant laws and internal company regulations.
We do not tolerate false or fictitious entries, nor the maintenance of off-book assets.
Compliance with Employment Regulations
Employees shall adhere to the company's employment regulations at all times.
① Prohibited acts defined in the employment regulations are strictly forbidden.
② Any dishonest or unethical conduct that violates company rules is prohibited.
Respect for Human Rights and Non-Discrimination
① We strive to maintain a healthy workplace environment and respect the human rights of every individual.
② We prohibit all forms of irrational discrimination based on birth, nationality, race, ethnicity, beliefs, religion, gender, age, disability, hobbies, education, or any other personal background.
Prohibition of Sexual Harassment
① Any acts of sexual harassment or behaviors that could be misconstrued as such are strictly prohibited.
② Efforts shall be made to prevent such behaviors from occurring in the workplace.
Prohibition of Workplace Harassment
① Employees shall not use their superiority in position or relationships to inflict physical or mental suffering on others or degrade the working environment beyond the appropriate scope of business.
② The use of violence, verbal abuse, slander, or threats to force work is strictly forbidden.
③ Harassment against external personnel, including business partners and contractors, is also prohibited.
Protection of Privacy
Personal information of employees and external parties acquired during the course of business shall be used solely for business purposes and managed strictly to prevent unauthorized disclosure.
Ensuring Workplace Health and Safety
Ensuring health and safety is our top priority. We maintain a safe and healthy working environment and comply with all related occupational health and safety regulations.
In the event of an occupational accident, we follow all reporting procedures immediately to minimize damage and prevent recurrence.
Prohibition of Political and Religious Activities
Political or religious activities are prohibited during working hours.
① Solicitation for political organizations, requesting votes during elections, or engaging in electioneering within the company or in connection with company business is prohibited.
② Solicitation for religious groups, forcing beliefs, requesting donations, or distributing religious pamphlets within the company or in connection with company business is strictly forbidden.
Prohibition of Conflicts of Interest
Employees shall avoid any activities that create a conflict of interest with the company.
① Employees must not serve as executives, employees, or consultants for competitors or business partners, nor may they maintain any unauthorized financial relationships with them.
② Employees must not conduct private business as a supplier or service provider to the company.
Proper Use of Corporate Assets
We shall recognize that company assets should be utilized efficiently and maintained in a ready-to-use state. All assets, whether tangible or intangible,
shall be properly managed to prevent theft or loss. The use of company assets or funds for personal purposes is strictly prohibited.
Prohibition of Insider Trading
If you acquire inside information regarding NCK, our affiliates, or business partners during the course of your duties, you must not trade the stocks or bonds of those companies until such information is officially made public. This restriction applies even if the trade is performed through a third party or is not intended for personal gain.
Proper Management of Confidential Information
Corporate secrets shall be managed appropriately and never disclosed or leaked outside the company without authorization.
① Proprietary and third-party trade secrets shall be strictly managed and never leaked or used for purposes other than authorized business duties.
② When disclosing confidential information to external parties, measures such as signing a Non-Disclosure Agreement (NDA) must be taken to prevent unauthorized leaks.
③ We shall not misappropriate the trade secrets of other companies or use them for purposes beyond those permitted by the other party.
④ Even after retirement, employees shall not disclose or use the company's confidential information or any confidential information acquired from external sources.
Appropriate Use of Information Systems
① Company information systems shall be used solely for business purposes and never for personal gain or private use.
② IDs and passwords related to the company’s information systems must be managed with strict care and never shared with unauthorized external parties.
③ Misappropriating others' IDs and passwords or infiltrating other computer systems is strictly prohibited.
④ In using information and communication tools, employees shall comply with the Act on Promotion of Information and Communications Network Utilization and Information Protection, etc. and all other relevant laws.
Proper Management of Personal Information
① Personal information shall not be used for any purpose other than its intended and authorized use.
② Personal information shall be strictly managed to prevent unauthorized external leakage.
Protection of Intellectual Property (IP) Rights
Company intellectual property is a vital corporate asset. It shall be utilized appropriately, and its rights shall be preserved.
① We shall protect our IP rights by promptly filing patent applications for inventions resulting from manufacturing and development activities.
② Any act infringing on others' IP rights, such as unauthorized reproduction of computer programs, is strictly prohibited.
③ The intellectual property of business partners may only be used after signing an appropriate agreement and must never be used improperly.
In principle, when a compliance violation or a potential risk is identified, it should be addressed through the normal reporting lines,
including reporting to supervisors. However, if a prompt and effective response is deemed difficult,
NCK operates the "Counseling Hotline" to prevent violations and ensure early resolution.
Whistleblowers may choose between designated internal and external channels. Reports can be submitted via email, mail, or telephone.
Upon receiving a report, the details are reported to the Statutory Auditor.
The Board of Directors regularly receives and oversees reports from the Compliance Secretariat regarding the operation of the internal reporting system.
We accept anonymous consultations and have clearly established rules to prohibit interference with investigations, attempts to identify whistleblowers,
and any form of retaliation or harassment. This ensures a safe environment for all to seek consultation.
