NSK Code of Corporate Ethics (Established: February 22, 2002, Revised: June 23, 2017)
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 must 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 freedom of global business activities. Personnel must comply with all import- and export-related laws.
- 3. Prohibition of Commercial Bribery (handling of entertainment, gifts, etc.)
- When giving and receiving gifts and entertainment, bribery and any acts deviating from socially-accepted norms - is prohibited. Personnel must not provide entertainment and gifts to officials and employees of public institutions unless there are special reasons for doing so.
- 4. Transactions with Public Institutions and Handling of Political Donations
- Personnel must comply with all laws related to transactions with public institutions. Personnel must also comply with all laws related to political donations and must avoid questionable expenditures/provision of benefits.
- 5. Accurate Recording and Processing
- All business activities must be accurately recorded, archived, and processed appropriately in accordance with related laws and regulations. In the event of an audit, whether internal or external, personnel must cooperate fully and provide honest information.
- 6. Prohibition of Insider Trading
- Personnel must not trade in stock or other securities with the knowledge of nonpublic insider information or provide said information to any third party, including family members.
- 7. Handling of Intellectual Property Rights
- Personnel must strive to create, protect, and utilize intellectual property, such as inventions, and must handle intellectual property rights with great care. In addition, personnel must not infringe the intellectual property rights of others.
- 8. Prohibition of Illegal and Criminal Conduct
- Personnel must adopt a resolute stance against illegal conduct and must not interact with organizations that are engaged in criminal operations.
- 9. Protection of Corporate Assets
- Personnel must use corporate assets in an appropriate manner, solely for the purpose of corporate operations, and endeavor to protect such assets. Personnel must avoid the misuse and waste of corporate facilities, equipment, tools, materials, spare parts, and network systems.
- 10. Handling of Confidential and Personal Information
- Personnel must not obtain confidential information of companies, customers, suppliers, etc. through wrongful means, disclose such information to any third party, nor use for private purposes, including after retirement. Personnel must also manage personal information appropriately in order to protect privacy.
- 11. Relations with Customers
- Personnel must always provide high-quality, safe, and secure products and services. Personnel must 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 must be based on fair criteria. When conducting business with suppliers, personnel must comply with related laws and treat suppliers as an equal business partner. In addition, personnel shall not seek nor receive personal profits using a dominant bargaining position.
- 13. Prohibition of Acts Discrediting Competitors
- Fair business activities must be performed based on the principles of free competition. Personnel must not unfairly undermine competitors' credibility by disseminating arbitrary information about competitors or their products, including libel, slander, or defamation.
- 14. Prohibition of Discrimination, Cultivation of a Sound Workplace
- Personnel must respect the rights of individuals and must not unfairly discriminate on the basis of race, appearance, belief, gender, lineage, ethnicity, nationality, age, marital status, physical disability, or other inappropriate reason. In addition, personnel must avoid engaging in acts that cause offense to the recipient.
- 15. Respect of Fundamental Rights at Work
- Personnel must not use forced or child labor. In addition, personnel must comply with all labor laws and respect fundamental rights at work.
- 16. Global Environmental Protection
- Personnel must comply with environment-related laws and internal rules. In addition, personnel must be conscious of the effect their work has on the environment, and 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.
NSK Compliance Guidebook 2018 (Published March 2018)
To ensure thorough compliance throughout the Group, NSK published NSK Compliance Guidebook 2018 to explain the NSK Code of Corporate Ethics in detail, and distributed it to all officers and employees of the NSK Group in Japan.
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 corporations.