The TDK Code of Conduct (Charter of Corporate Behavior) states that âThe TDK Group will continue to respect human rights, comply with relevant laws and regulations and international rules, and will discharge its social responsibility with a strong sense of ethical values for the purpose of creating a sustainable society.â
Since the UN Human Rights Council adopted âprotect, respect, and remedyâ framework, known as the Ruggie Framework, with regards to business and human rights in 2008, a series of international CSR guidelines and UN and EU policies have been introduced in accordance with the framework, and several jurisdictions around the world have enacted laws addressing human rights in the context of international business. Specifically, these include the conflict minerals clause in the US Dodd-Frank Wall Street Reform and Consumer Protection Act enacted in 2010, the Transparency in Supply Chains Act enacted in the US state of California in 2010, the UN Guiding Principles on Business and Human Rights in 2011, and the Modern Slavery Act in the United Kingdom in 2015. This trend represents a strong appeal to companies to specifically identify human rights issues in their business activities and take appropriate actions.
The TDK Group Policy on Human Rights was formulated in 2016. TDK promotes the correct understanding, awareness, and improvement of human rights issues, including social issues, not only in business activities within the Group itself but also in the value chain.
We strive to identify and engage with human rights issues by acquiring information from many sources.
TDK implements annual CSR self-assessments and labor and human rights/corporate ethics related risk assessments based on the Electronic Industry Citizenship Coalition (EICC) Code of Conduct at all Group manufacturing sites. In addition, in high-risk regions and production sites, internal audits by third-party organizations are conducted once every two years and more frequently as may be indicated, as well as CSR audits by customers.
In order to promote CSR procurement, TDK implements annual CSR self-assessments of its suppliers on the basis of items required by the EICC. Furthermore, TDK has been conducting CSR audits of its suppliers, selecting targeted suppliers in consideration of their importance in the delivery of products to customers and its reliance on them.
The TDK Code of Conduct strictly prohibits child labor and forced labor* and demands the same commitment from suppliers. For example, in our manufacturing sites in China, we adhere to strict age check procedures to prevent any use of child labor and implement monitoring by headquarters. In fiscal 2015, no case of child labor was discovered.
Foreign workers are susceptible to becoming victims of forced labor and human trafficking, due to their low social and economic position. Measures are being implemented to protect the human rights of and provide relief to such individuals. In Malaysia, the problem of forced labor involving foreign workers became a social issue. Since fiscal 2013, we have been assessing the problem and we have devised and implemented countermeasures based on the results. During fiscal 2015 we accepted audits by third-party organizations at four relevant manufacturing sites and made improvements based on the findings. In Singapore in fiscal 2015, we also accepted an audit by a customer at one manufacturing site. We will continue our efforts to monitor for and correct any instances of forced labor through our supply chain.
We use dedicated labor management systems at each of our sites and pay wages based on appropriate work performance management. In China, where extended continuous working hours of employees have become a problem, we began in 2015 to strengthen the monitoring of production sites by headquarters.
We ensure equal opportunities for all employees by avoiding direct or indirect discrimination among our employees in respect of employment, treatment (compensation, opportunities to participate in training sessions, advancement opportunities, etc.) or any other similar matters based on race, beliefs, gender, religion, nationality, ethnicity, age, marital status, disability, sexual orientation, or social status. Our purchasing transactions (including contracts and subcontracting) are carried out not only on the basis of economic rationales, but in an effort to fulfill our social responsibility in complying with laws and regulations, and respecting human rights and labor rights.
TDK and some of our subsidiaries have labor unions.
In addition, in countries where labor unions are not permitted under local laws, regulations, and labor customs, TDK holds sincere dialogue directly with employees or employee representatives based on the TDK Code of Conduct. In this manner we work to build sound relationships and resolve issues regardless of the circumstances.
In the Democratic Republic of the Congo (DRC) and adjoining countries, sometimes the proceeds from the mining and sale of minerals have been used to fund armed groups. These actions serve to further conflict and violations of human rights treatment of local people.
TDK began its response to the problem of conflict minerals following the enactment of the US Dodd-Frank Wall Street Reform and Consumer Protection Act in 2010. A conflict minerals policy* for the TDK Group was formulated in April 2013.
TDK raises awareness of human rights issues through e-learning training of all of our employees on CSR issues. Through training of internal auditors based on the EICC, we have been able to identify problems where they arise, including in China, Malaysia and Japan. In the supply chain, meanwhile, TDK provides educational tools to promote awareness at the time of CSR self-assessments.