TDK Code of Conduct specifically provides the standards andăguidelines for compliance with all laws, regulations and social norms, toăbe followed by TDK and its consolidated subsidiaries (collectively âtheăTDK Groupâ), as well as all directors, officers, employees and companyăauditors who are the members of the TDK Group.
The TDK Code of Conduct consists of the following four elements:
The fundamental charter stipulating universal matters to beăcommonly implemented by the TDK Group;
The fundamental philosophy stipulating universal matters to beăimplemented by all directors, officers, employees and companyăauditors of the TDK Group (âTDK Membersâ);
The guidelines for substantiating the Philosophy (2) in the businessăconduct of the TDK Group; and
The procedures for observance of the Philosophy (2) and theăStandards (3).
Creation, revocation and/or amendment of the TDK Code ofăConduct shall be subject to the approval of the board of directorsăof TDK Corporation (âTDKâ). Violations of the TDK Code of Conductămay result in disciplinary action in accordance with applicable lawsăand regulations, the work rules and/or other applicable companyărules.
For the purpose of implementing the TDK Code of Conduct, eachămember organization of the TDK Group will:
The TDK Groupâs ethics organizations are organized as describedăin the following chart. We established the TDK Business Ethics &ăCSR Committee, which supervises all the organizations, at the TDKăhead office, and also formed the Ethics Councils at the respectiveăsubsidiaries.
In order for the TDK Groupâs employees to make proposals or expressătheir opinions and participate in consultations with respect to anyăissues concerning corporate ethics, we allocated the Consultations atăthe respective Ethics Councils and also set up Help Lines per region.
The Help Lines were established in and cover the Asia Region, theăAmericas Region and the Europe Region. Consultations can be heldăeither locally through the Consultations at the Ethics Councils orăregionally, through one of the three Help Lines. If any problems ariseăwith respect to the matters set forth in the TDK Code of Conduct,ăplease consult with these Consultations or Help Lines.
The Consultations and persons in charge of the Help Lines are obligedăto protect confidential matters relating to possible violations of theăCode of Conduct including, to the greatest extent practicable underăthe circumstances, the identity of the informants. In addition, personsăassociated with the TDK Business Ethics & CSR Committee andăwith the Ethics Councils will endeavor to consider the intentions ofăinformants. At the time of the consultations, due consideration will beăgiven in order to prevent informants from suffering any disadvantages.
If the TDK Code of Conduct is violated by any person, such personămay be subject to disciplinary measures in accordance with theăwork rules and any other internal rules. If, reflecting on your ownăconduct, you believe that you may have violated the TDK Code ofăConduct, please report this violation and request a consultationăvoluntarily. If persons involved in a violation report their involvementăvoluntarily, we may, given sufficient consideration of the backgroundăand circumstances of such violation, take extenuating circumstancesăinto account when administering disciplinary measures against suchăpersons. Whether or not sound corporate activities are performedădepends on each individual. It is important to refrain from leaving anyăethics issues unresolved, once you become aware of them. Pleaseăappreciate the purposes of the TDK Code of Conduct and bravely andăproactively take necessary action to achieve improvement.