TDK Code of Conduct specifically provides the standards and guidelines for compliance with all laws, regulations and social norms, to be followed by TDK and its consolidated subsidiaries (collectively “the TDK Group”), as well as all directors, officers, employees and company auditors 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 be commonly implemented by the TDK Group;
The fundamental philosophy stipulating universal matters to be implemented by all directors, officers, employees and company auditors of the TDK Group (“TDK Members”);
The guidelines for substantiating the Philosophy (2) in the business conduct of the TDK Group; and
The procedures for observance of the Philosophy (2) and the Standards (3).
Creation, revocation and/or amendment of the TDK Code of Conduct shall be subject to the approval of the board of directors of TDK Corporation (“TDK”). Violations of the TDK Code of Conduct may result in disciplinary action in accordance with applicable laws and regulations, the work rules and/or other applicable company rules.
For the purpose of implementing the TDK Code of Conduct, each member organization of the TDK Group will:
The TDK Group’s ethics organizations are organized as described in the following chart. We established the TDK Business Ethics & CSR Committee, which supervises all the organizations, at the TDK head office, and also formed the Ethics Councils at the respective subsidiaries.
In order for the TDK Group’s employees to make proposals or express their opinions and participate in consultations with respect to any issues concerning corporate ethics, we allocated the Consultations at the respective Ethics Councils and also set up Help Lines per region.
The Help Lines were established in and cover the Asia Region, the Americas Region and the Europe Region. Consultations can be held either locally through the Consultations at the Ethics Councils or regionally, through one of the three Help Lines. If any problems arise with respect to the matters set forth in the TDK Code of Conduct, please consult with these Consultations or Help Lines.
The Consultations and persons in charge of the Help Lines are obliged to protect confidential matters relating to possible violations of the Code of Conduct including, to the greatest extent practicable under the circumstances, the identity of the informants. In addition, persons associated with the TDK Business Ethics & CSR Committee and with the Ethics Councils will endeavor to consider the intentions of informants. At the time of the consultations, due consideration will be given in order to prevent informants from suffering any disadvantages.
If the TDK Code of Conduct is violated by any person, such person may be subject to disciplinary measures in accordance with the work rules and any other internal rules. If, reflecting on your own conduct, you believe that you may have violated the TDK Code of Conduct, please report this violation and request a consultation voluntarily. If persons involved in a violation report their involvement voluntarily, we may, given sufficient consideration of the background and circumstances of such violation, take extenuating circumstances into account when administering disciplinary measures against such persons. Whether or not sound corporate activities are performed depends on each individual. It is important to refrain from leaving any ethics issues unresolved, once you become aware of them. Please appreciate the purposes of the TDK Code of Conduct and bravely and proactively take necessary action to achieve improvement.