NSK regards compliance (observance of laws and corporate ethics) as crucial for the Group to remain deserving of the trust it has earned.
NSK Code of Corporate Ethics (Established: February 22, 2002, Revised: April 1, 2013)
NSK Code of Corporate Ethics, based on NSK Corporate Philosophy, lays down the fundamental principles that all officers and employees of NSK Ltd. and NSK Group Companies (“Personnel”) shall comply with when conducting various business activities.
 NSK Corporate Ethics Policies
- Personnel will strive to ensure that NSK Ltd. and its affiliates continue to prosper as a company that acts in a sincere and fair manner, and which is respected and trusted in international and regional society.
- Personnel will comply with all laws related to its business activities. Moreover, personnel will act in a highly ethical manner in order to ensure that NSK fulfils its responsibility as a corporate citizen.
 NSK Code of Conduct concerning Compliance
- 1. Compliance with Competition Laws
- Personnel will not make agreements with competitors to set selling price or territorial sales markets, restrict resale price, or perform other anticompetitive acts. Personnel will conduct legitimate trade through free and fair market competition.
- 2. Compliance with Import and Export Related Laws
- Compliance with international rules is essential for free and global corporate activities. Personnel will comply with all import and export related laws.
- 3. Prohibition of Commercial Bribery (handling of entertainment, gifts, etc.)
- In giving and receiving of entertainment and gifts, bribery, as well as acts deviating from social norms, is prohibited. Personnel will take great care especially regarding entertainment and gifts to officials and employees of public institutions.
- 4. Transactions with Public Institutions and Handling of Political Donations
- Personnel will comply with all laws related to transactions with public institutions. Personnel will also comply with all laws related to political donations and avoid paying unclear expenditures or providing unfair benefits.
- 5. Accurate Recording and Processing
- All business activities will be entered accurately in ledgers and records and processed appropriately in accordance with related laws. Honest responses must be given to enquiries from external and in-house auditors.
- 6. Prohibition of Insider Trading
- Personnel will not buy or sell stocks with knowledge of insider information or provide insider information to any third party, including family members.
- 7. Handling of Intellectual Property Rights
- Personnel will strive to create, protect, and utilize intellectual property such as inventions, and will handle intellectual property rights with great care. In addition, personnel will not infringe the intellectual property rights of others.
- 8. Prohibition of Illegal or Anti-social Conduct
- Personnel will adopt a resolute stance against illegal or anti-social acts and will avoid relationships with organizations that threaten social order and security.
- 9. Protection of Corporate Assets
- Personnel will use corporate assets for the purpose of corporate operations in a proper manner, and will strive to protect corporate assets. Personnel will avoid the misuse and waste of corporate facilities, tools, materials, spare parts and network systems.
- 10. Handling of Confidential and Personal Information
- Personnel will not obtain confidential information of companies, customers, suppliers, etc. through wrongful means, disclose such information to any third party, nor use such confidential information for private purposes (including after retirement). Personnel will also manage personal information appropriately in order to protect privacy.
- 11. Relations with Customers
- Personnel will always provide high-quality, safe, secure products and services. Personnel will always commit themselves to entering into fair trade practices, being sincere in attitude and making proactive proposals in order to enhance trust in the NSK brand.
- 12. Relations with Suppliers
- Selection of suppliers will be based on fair criteria. When conducting business with suppliers, personnel will comply with related laws and treat suppliers as an equal business partner. In addition, personnel will not seek nor receive personal profits using a dominant bargaining position.
- 13. Prohibition of Acts Discrediting Competitors
- Fair business activities will be performed based on the principles of free competition.
Personnel will not unfairly undermine competitors’ credibility by disseminating arbitrary information, including libel, slander, or defamation, about the products, etc. of competitors.
- 14. Prohibition of Discrimination and Cultivation of a Sound Workplace
- Personnel will respect the rights of individuals and will not unfairly discriminate on the basis of inappropriate reasons including race, appearance, belief, gender, lineage, ethnicity, nationality, age, marital status, or physical disability. In addition, Personnel will avoid acts that cause offense to the recipient.
- 15. Respect of Fundamental Rights at Work
- Personnel will not use forced labor nor use child labor. In addition, personnel will comply with all labor laws and will respect fundamental rights at work.
- 16. Global Environmental Protection
- Personnel will comply with environment-related laws and in-house rules. In addition, personnel will be conscious of the effects their work has to the environment, and will strive to prevent pollution as well as protect human health and the ecosystem in order to pass on a better environment to the next generation.
 Disciplinary Actions
Personnel who violate this Code will be subjected to disciplinary actions.
 Whistle Blower System
If personnel find acts against this Code being conducted or about to be conducted, the personnel will report the matter using the Whistle Blower System. Personnel who report violations of this Code will not suffer unreasonable loss or maltreatment, such as demotion, pay reduction, etc., in relation to the report. However, this will not apply to personnel who intentionally make false reports.
* NSK Code of Corporate Ethics applies to NSK Ltd., its consolidated Subsidiaries (unless they have established their own code independently), and NSK-Warner K.K.
We also participated in the formulation of and observe the standards
outlined in the “Charter of Corporate Behavior” and “Outline of the
Implementation Guidance for Charter of Corporate Behavior” of the Nippon
Keidanren (Japan Business Federation), an alliance of Japanese leading
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