Sustainability

EXEDY Group's Sustainability Activities

Compliance

Our approach

Through our business activities in different regions around the world, we found it is essential to comply with laws of each country in an quick and reliable manner, and to have a transparent approach to management in order to gain the trust of all stakeholders.

With “fairness and transparency” as our keywords and thorough compliance management and a corporate governance system at basis of our operations, we organize our company in a way that enables us to quickly respond to changes in the business environment, improve internal checking functions and carry out business activities with an understanding of the laws relating to our work.

Excerpt of our CSR Policy

Compliance: Fairness and Transparency
- We will uphold a spirit of compliance with the laws of each country and region, and will conduct business recognizing that the fundamental rule for corporate activities is to ensure that competition is fair, transparent, and free.

Activities

Code of Conduct reading sessions

We distribute the Code of Conduct in the local language to all employees of the EXEDY Group, and read it during the morning meetings of each department and team to ensure that its contents are well understood.

Reference: EXEDY Code of Conduct（CSR page）

Below an excerpt of our Code of Conduct

EXEDY Code of Conduct - Detailed Conduct Regulations [Compliance]

Compliance (Fairness and Transparency)

We shall continue to develop business relationships based upon the fundamental rules of fair and transparent corporate activities, and, in order to strengthen society’s trust in us, we will always uphold the laws and spirit of each country and its subordinate regions.

1. Business Laws

1）: We shall not participate in cartels with competing companies as prohibited by antitrust laws.
2）: We shall conduct fair business practices with our business partners (suppliers, subcontractors etc.) in accordance with the regulations of all antitrust and subcontracting laws. Conducting fair business includes not abusing authority, refraining from unreasonable returns of goods, not driving down prices, and not breaching contracts.
3）: We shall be vigilant about our intellectual properties such as patents, trademarks, copyrights and know -how. We shall also not make illegal use of nor shall we infringe upon the intellectual properties owned by our competitors.
4）: We will not conduct insider trading using undisclosed information that was obtained through business activities.
5）: We shall adhere to all laws pertaining to the protection of private information and endeavor to protect such information as per our personal information protection policy.
6）: If a law is ever violated or an accident occurs, we shall report it immediately to management. We shall also act in accordance with all laws and regulations as a corporate entity.

2. Entertainment and Gift Offerings

1）: Employees of our corporation are expected to reject offers of entertainment or gifts given in exchange for unlawful transactions.
2）: Our employees are required to obtain the approval of their supervisors if they receive entertainment or gift offerings while attending to customers, and employees can receive them only once such matters are done openly.

3. Anti-corruption Procedures

1）: We carry out all political donations and contributions abiding by each country’s respective laws, and endeavor to build fair and transparent relationships with the governments and administrations of these countries.
2）: We will not provide money, entertainment, or gifts to customers, business partners etc., with the objective of gaining preferential treatment or profit in an unfair manner.

4. Upholding the Law Outside of Work

1）: We shall not associate ourselves with any organized crime syndicates, nor shall we perform any illegal acts, regardless of whether we are at work or not.
2）: When we see either organized crime activities or an unlawful act taking place, we will immediately file a report at the police station whose jurisdiction the area falls under.

EXEDY Code of Conduct - Detailed Conduct Regulations [Corporate Ethics]

Corporate Ethics

1. No Tolerance for Human Rights Violations or Discrimination

1）: As per the applicable laws of each country etc., it is strictly prohibited to discriminate against somebody due to his or her nationality, race, ethnicity, beliefs, religion, gender, age, disability, hobbies, educational background, sexual orientation or gender identity etc.
2）: It is also strictly prohibited to infringe upon one’ s human rights by bullying or intimidating them by use of violence, inappropriate language, slander or verbal abuse.

2. Sexual Harassment, Power Harassment

1）: It is strictly prohibited to force sexual relations upon someone by abusing your authority or position of power.
2）: It is strictly prohibited to comment suggestively on another person’ s appearance, including what they are wearing or how they look.
3）: We will refrain from sexually inappropriate actions and statements that could make others feel uncomfortable, and we will make sure to warn those who behave in such a way. Sexually explicit photographs, newspapers, posters, etc., must not be displayed in the workplace.
4）: We will not aggressively use our authority, be it through our speech, behavior, gestures or writing, to harass or emotionally wound others.
5）: We shall report instances of sexual or power harassment to our supervisor. In case there is an internal consultation desk or EXEDY hotline in your company, report it there.
*Actions from coworkers and from subordinates to superiors may also constitute power harassment, in any environment, regardless of working hours or location.

3. Moral Harassment

We will use neither our words nor our actions to make others feel uncomfortable with the intention of disrespecting or insulting them.

4. Harassment Concerning Pregnancy, Childbirth, Childcare or Nursing Care Leave etc.

We will not physically or mentally harass others by reason of pregnancy, childbirth, childcare and nursing care leave etc., and we will not treat them disadvantageously or obstruct the use of any systems.

5. Child Labor

1）: We will never engage in child labor.
2）: The minimum age for employment will be based upon the laws and regulations of each country.
3）: We shall not allow employees under the age of 18 to perform potentially dangerous or harmful work, nor shall they be allowed to work during night shifts.

6. Forced Labor

1）: We will never force anyone to work for our corporation.
2）: We will never demand that employees hand over their passports, identification cards or work permits as a condition of employment.

Employee rights protection

Dialogue and consultation with employees

We will discuss and interact with employees' representatives or employees in good faith and always try to achieve mutual understanding.
We recognize the right of employees to freely associate or not associate, based on the applicable laws of the country in which they operate.
We assure our employees the right to open and direct dialogue with management without fear of retaliation, intimidation or harassment.

Working Hours

We comply with the applicable laws and regulations of each country that regulate the working hours (including overtime) of employees.
We are working to reduce working hours by promoting QC circle activities and supporting the improvement of work efficiency by introducing RPA.

Wages

We pay employees salaries in compliance with applicable laws and regulations regarding minimum wages, overtime, wage deductions, work wages and other benefits.
We pay the legally required benefits.
The Company will inform employees of salaries and other benefits and deductions in a timely and clear manner, in compliance with applicable laws in each country.

Prevention of child labor

At the time of employment we confirm that a person is of the minimum working age.
We will not have employees under the age of 18 carry out hazardous or late night work.

Harassment prevention measures

Harassment prevention training for managers

We invited specialized instructors from outside the company to provide harassment prevention training to all managers and supervisors. In FY2019 421 people attended.

In order to improve the quality and productivity of subordinates and members, we created an environment where people can work with peace of mind. Managers and supervisors acquire knowledge regarding harassment, do not infringe on human rights of employees, assuming their obligation to provide security for our employees, including mental health.

Our response to compliance violations

In the unlikely event of a serious compliance violation, we will report it to the Board of Directors and consider measures.
The whistleblowing desk also collects information from employees and outside the company and promptly responds to any problems.

In-house consultation/internal reporting reception system

In addition to the whistleblowing desk, we have established a consultation desk regarding behavioral ethics for the entire EXEDY Group. We have also set up an "EXEDY Hotline", a contact point for employees to directly contact an outside lawyer for consultation, in an effort to prevent and early detect fraud.
In order to thoroughly disseminate this information and raise compliance awareness, the consultation desk is clearly mentioned in the "EXEDY Code of Conduct", which is distributed to all group members.

EXEDY Code of Conduct - Regarding consultation on behavioral ethics

Regarding consultation on behavioral ethics

If you have any questions about the Code of Conduct, ethical issues, working environment, etc., or have any other problems, please feel free to contact us. The consultation desk is available for all people working in the EXEDY Group in Japan (regular employees, associate employees, temporary employees, dispatched employees, temporary workers, etc.) and their families.

*To avoid insults and slander and to be able to clarify the facts, we ask you to use your real name for consultation.

*Privacy is protected and those who make use of the consultation desk will not receive unfavorably treatment.

Internal consultation desk: Handles any matters regarding the Code of Conduct, ethical issues, working environment, etc.
Phone number and email address can be found in the Code of Conduct.
Internal reporting reception desk: Handles violations of laws and company regulations.
Phone and fax number and email address can be found in the Code of Conduct.
External consultation and whistleblowing contact "EXEDY Hotline": An external lawyer office can be contacted by telephone, email, or letter.
Phone number, address and email address can be found in the Code of Conduct.