Basic Concept :
All employees exhibit correct judgment and conduct in line with corporate ethics

JTEKT positions compliance as the premise and foundation of corporate value, therefore essential to realizing JTEKT BASIC PRINCIPLE. JTEKT shows conduct guidelines of our directors and employees with "JTEKT Global Conduct Guidelines" and established the Compliance Program based on "Standards for Compliance Management". In addition to sharing with all group companies the "JTEKT Global Conduct Guidelines", JTEKT holds up a promotion activity of corporate compliance as one of the important items of "Corporate Management Guidelines for the JTEKT Group", and supports them while promoting the construction of the promotion system which balanced with the business content of each company.

Training and Awareness-Raising Activities for All JTEKT Group Companies

JTEKT conducts ongoing training and awareness-raising activities targeting its directors, employees and all group companies regarding compliance issues closely related to their operations. Among these, we conduct annual training targeting our key corporate compliance officers (directors, auditors, Senior Executive Officers, etc.). The theme for our FY2024 training was the responsibilities expected of leaders during this time of change. We invited experts to speak about the theme and held a workshop on important points for enhancing corporate value through compliance, and each director made a declaration of action.
Moreover, we have established every July as "Compliance Awareness Month", during which our president sends out a message to all JTEKT employees, including group companies both in Japan and overseas, and compliance training materials are distributed for e-learning and workplace reference and use in an effort to support compliance activities in each workplace. Additionally, we conducted psychological safety workshops for all middle managers, who are central to our operations, to promote an open and transparent workplace and proactively prevent compliance violations.

Compliance Self-Check by all JTEKT Group Companies and Compliance Anonymous Questionnaire

At JTEKT, we carry out regular checks targeting all departments of JTEKT and domestic/overseas JTEKT Group companies to assess the management status regarding compliance related to our operations, and plans and implements compliance promotion initiatives based on the results of the assessment and inspections. We conduct anonymous surveys regarding compliance violations not only within JTEKT but also throughout JTEKT Group starting this fiscal year, in an effort to prevent compliance violations through careful investigation.

Compliance with Competition Laws / Prevention of Corruption

１．Policy
With consideration to a global trend of placing importance on fairness in the transactions, features and transactions of JTEKT and JTEKT Group companies' businesses form and products, as well as the current trend of tightening of laws and regulations and their enforcement, JTEKT places particular importance on compliance with the Anti-Monopoly Act of Japan, the laws and regulations of various countries relating to competition and acts of corruption and bribery.
In concrete terms, JTEKT's President pledges that JTEKT and JTEKT Group companies respect fair trade practices and do not tolerate cartels, corruption and bribery (including offering money or other gifts to public officials, and offering or receiving excessive gifts and entertainment to/from private companies) as justifiable means to engage in business. JTEKT also prohibits facilitation payments (payments to facilitate or expedite regular administrative services by public officials) as conduct that could be suspected as non-compliant to laws and regulations of various countries.
In consideration with the industry-specific matters of JTEKT and JTEKT Group companies, JTEKT establishes, under the supervision of officers including directors, "Rules for Contact with a Competitor", "Anti-corruption Rules" and their guidelines as concepts to prevent non-compliance, codes of conduct and rules stipulating internal procedures. In addition, in order to prevent non-compliance with laws and regulations due to a lack of understanding of officers and employees, JTEKT's Legal Department takes a primary role in maintaining a system allowing them to consult on any doubts in their regular day-to-day tasks.
２．Communication and Training
JTEKT conducts regular communication and training for officers and all employees (meaning all employees regardless of employment status such as permanent employment or temporary employment) on an annual basis. While the laws and regulations relating to competition or corruption and bribery are based on the universal philosophy, they are regulated by the laws and regulations unique to each country, and uniform regulations may not be familiar to the actual conditions of each region. JTEKT shares the basic ideas with each JTEKT Group companies and promote optimization in accordance with the laws and regulations of each region and the actual situation.
In regards to the status of these implementations, independent items are established and confirmed in the annual compliance self-check and audited by the internal auditing department and company auditors, in addition to periodical oversight by the Management Meeting attended by board members.
３．Risk Assessment and Response
With support from JTEKT's Legal Department and other specific departments, the actions to reduce the risks on the elements or types of operations which are assessed as having high risks of cartels or corruption and bribery are taken in a systematic way.
Such behaviors breaching the laws are, by the Whistle Blowing Protection Act and internal rules, subject to the whistleblowing protection system, which ensures anonymity of whistleblowers and keeping the contents of the report confidential. The system also guarantees that whistleblowers are not given any disadvantageous treatments by their companies because of their report. In addition, we state prevention to corruption on the policy of procurement activities and, in our basic contracts, provisions for both parties that mutually declare avoidance to violate antitrust or competition laws, to commit corruption or bribery, and to be used for money laundering by antisocial forces. JTEKT also has a process to confirm that there are no violations of these laws and regulations by counter party when starting a new transactions. Similarly, in the case of corporate acquisitions involving JTEKT or JTEKT Group companies, JTEKT confirm that there are no violations of these laws and regulations as an independent item of due diligence.
４．Disclosure of Related Information
Over the past ten years, neither JTEKT nor any JTEKT Group companies have been exposed by the regulatory authorities of any country for violations with laws and regulations relating to corruption or bribery, and there is also no expenditure associated with violations. In addition, no officer or employee has been disciplined or retired for violating corruption or bribery policies in JTEKT and JTEKT Group companies.

Initiatives for Appropriate Tax Payment

At JTEKT and the JTEKT Group, we recognize that appropriate tax payment in the countries and regions where we conduct business is an important part of building mutually beneficial relationships as responsible members of those communities.
We have established the "JTEKT Group Tax Policy" to outline our basic stance and code of conduct regarding taxation. By adhering to this policy, we strive to maintain and enhance tax compliance, uphold our basic principles, and fulfill our corporate social responsibility.
JTEKT Group Tax Policy

1. The whistleblowing system of JTEKT and the JTEKT Group ensures that the identity of the whistleblower and the details of the whistleblowing are protected as confidential in accordance with relevant laws such as the Whistleblower Protection Act and internal regulations. It also guarantees that whistleblowers will not face any adverse treatment from the company as a result of their whistleblowing.