Minebea Group Code of Conduct

Minebea Group of Companies (Thailand)
Code of Conduct

I. DECLARATION

Our parent company, Minebea Co., Ltd., is committed to be not only an organization that pursues profits through free and fair competitions but also an entity that broadly provides usefulness to the society. Under these circumstances, compliance (observance of laws and ethical principles) is regarded as an important element of business management. In addition, our parent company is conducting business transactions in a fair and sincere manner towards its stakeholders from the viewpoint of corporate governance. In other words, Minebea Co., Ltd. has duties to fulfill its social responsibility and improve its corporate value not only by complying with laws and regulations but also, as a corporate citizen, by conducting appropriate and fair business management based on corporate ethics.

Minebea Group has upheld five rules as basic management principles: “Be a company of which employees are proud to be a part”, “Gain the trust of customers”, “Meet the expectation of shareholders”, “Be welcomed by the local community”, and “Contribute to the international community”. It has been clarified that an earnest and serious attitude toward stakeholders such as shareholders, customers, business partners, employees, government agencies, and the society is a fundamental building block of Minebea business. Minebea Group has also strived to achieve highly transparent management.

Since the foundation in 1951, Minebea Co., Ltd., has been one of the most active forerunners in promoting global operation presence. Through that period, compliance with laws has been implemented as a matter of course in our group both domestically and internationally. Minebea Groupโ€™s efforts to promote employment and foster human resources have also contributed to local communities. Furthermore, Minebea Group have fulfilled a social responsibility through environmental protection efforts such as obtainment of ISO14001 for all our production sites around the world as well as through efforts to promote labor safety and health in which we have obtained OHSAS18001 for factories mainly in Asia.

Consequently, our parent company has declared a commitment to continuously strive to understand corporate ethics and applicable laws, harmonize with society, and achieve sustained improvement of corporate value through fair and appropriate business management by ensuring implementation of Minebea Group Code of Conduct.

Minebea Group of Companies (Thailand), as part of Minebea Global Group, acknowledges and shares the same commitment. Moreover, we have a commitment to global citizenship which includes growing our company in a strong and sustainable way, preserving and protecting our environment, promoting a safe and healthy work environment and treating people with dignity and respect. To put such commitment into practice, we have established and implemented Minebea Group of Companies (Thailand) Code of Conduct. To ensure unity and solidarity with our parent company, our Code of Conduct is revised to align and be in line with Minebea Group Code of Conduct.

Each director and employee of our group is required to fully comprehend the purpose and comply with Minebea Group of Companies (Thailand) Code of Conduct.
August 15, 2017
NMB-Minebea Thai Ltd.
President and Director
Masayuki Imanaka

 

II. CODE OF CONDUCT

1. LABOR
The Minebea Group of Companies (Thailand) is committed to upholding the human rights of employees, and to treating them with dignity and respect. All companies within Minebea Group of Companies (Thailand) shall adhere to the following standards regarding use of labor:
(1) Freely Chosen Employment
Forced, bonded, indentured, or involuntary and inhuman prison labor shall not be used. All work shall be voluntary, and Minebea employees shall be free to leave upon reasonable notice in compliance with applicable law, regulation, and contractual agreement. Minebea employees shall not be required to hand over government-issued identification, passports, or work permits as a condition of employment.

(2) No Child Labor
Child labor shall not to be used in any stage of manufacturing. The term “child” refers to any person employed under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Minebea supports the use of legitimate workplace apprenticeship programs which comply with all laws and regulations. Minebea employees under the age of 18 shall not perform hazardous work and may be restricted from night work with consideration given to educational needs.

(3) Discrimination
The Minebea Group of Companies (Thailand) is committed to a workforce free of harassment and discrimination. Companies within Minebea Group of Companies (Thailand) shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition, employees or potential employees should not be subjected to medical/pregnancy tests that could be used in a discriminatory way.

(4) Harsh or Inhumane Treatment
Companies within Minebea Group of Companies (Thailand) shall not allow any harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of employees, nor shall the threat of any such treatment be allowed.

(5) Minimum Wages
Compensation paid to employees shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits. Any disciplinary wage deductions are to conform to applicable law and regulation. The basis on which employees are paid shall be clearly communicated to them in a timely manner.

(6) Working Hours
Work weeks are not to exceed the maximum set by applicable law and regulation. Employees should be allowed at least one day off per seven-day week.

(7) Freedom of Association
The Minebea Group of Companies (Thailand) respects the rights of its employees to associate freely, join labor unions, seek representation, and or join workers’ councils in accordance with applicable law and regulation. Employees shall be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment.

 

2. HEALTH AND SAFETY

The Minebea Group of Companies (Thailand) recognizes that the quality of its products and services, consistency of production, and employee morale are enhanced by a safe and healthy work environment. All companies within Minebea Group of Companies (Thailand) shall adhere to the following standards regarding health and safety:
(1) Machine Safeguarding
Physical guards, interlocks and barriers for machinery used by employees shall be provided where appropriate, and shall be properly maintained.

(2) Industrial Hygiene
Employee exposure to chemical, biological and physical agents shall be identified, evaluated, and controlled. When hazards cannot be adequately controlled by engineering and administrative means, employees shall be provided with appropriate personal protective equipment.

(3) Safety
Employee exposure to workplace safety hazards shall be identified, evaluated, and controlled through proper design, engineering and administrative controls, preventative maintenance, and safe work procedures. Where hazards cannot be adequately controlled by these means, employees shall be provided with appropriate personal protective equipment.

(4) Emergency Preparedness and Response
Emergency situations and events shall be identified and assessed, and their impact minimized by implementing emergency response and recovery plans and procedures.

(5) Occupational Injury and Illness
Procedures and systems shall be implemented to manage, track and report occupational injury and illness, including provisions to:

encourage worker reporting;
classify and record injury and illness cases;
provide necessary medical treatment;
investigate cases and implement corrective actions to eliminate their causes; and,
facilitate return of employees to work.
(6) Physically Demanding Work
Employee exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks shall be identified, evaluated and controlled. Employees shall be provided with appropriate equipment to perform such tasks.

(7) Dormitory and Canteen
Workers shall be provided with clean toilet facilities, access to potable water and sanitary food preparation and storage facilities. Worker dormitories provided by the Minebea Group of Companies (Thailand) shall be clean, safe, and provide emergency egress, adequate heat and ventilation, and reasonable personal space.

 

3. ENVIRONMENT

The Minebea Group of Companies (Thailand) recognizes that environmental responsibility is integral to producing world class products. In our operations, adverse effects on the environment and natural resources shall be minimized while safeguarding the health and safety of the public. All companies within Minebea Group of Companies (Thailand) shall adhere to the following standards regarding the environment:
(1) Product Content Restrictions
All products shall adhere to applicable laws, regulations, and customer requirements regarding prohibition or restriction of specific substances, including labeling laws and regulations for recycling and disposal.

(2) Chemical and Hazardous Materials
Chemical and other materials posing a hazard if released to the environment shall be identified and managed to ensure their safe handling, movement, storage, recycling or reuse, and disposal.

(3) Wastewater and Solid Waste
Wastewater and solid waste generated from operations, industrial processes, and sanitation facilities shall be monitored, controlled, and treated as required by applicable law and regulation.

(4) Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations shall be characterized, monitored, controlled, and treated as required by applicable law and regulation.

(5) Environmental Permits and Reporting
All environmental permits and registrations required by applicable law and regulation shall be obtained, maintained, and kept current. The operational and reporting requirements of all permits and registrations shall be followed.

(6) Pollution Prevention and Resource Reduction
Waste of all types, including water and energy, are to be reduced or eliminated to the extent practicable at the source or by practices such as modifying production, maintenance, and facility processes, materials substitution, conservation, recycling, and or re-using materials.

 

4. ETHICS AND BUSINESS PRACTICE

To meet our social responsibilities and to increase our corporate value, The Minebea Group of Companies (Thailand) has to uphold the highest standards of ethics including:
(1) No Corruption, Extortion, or Embezzlement
The highest standards of integrity shall be maintained in all business interactions. Any and all forms of corruption, extortion and embezzlement are strictly prohibited. Any such conduct may result in termination and legal action.

(2) Disclosure of Information
Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices.

(3) No Improper Advantage
Bribes or other means of obtaining undue shall not be offered or accepted.

(4) Fair Business, Advertising, and Competition
Standards of fair business, advertising, and competition are to be upheld. Customer information shall be safeguarded.

(5) Community Engagement and International Operation
Community engagement is encouraged to help foster social and economic development. The Minebea Group of Companies (Thailand), as an international corporation, contributes to the development of the community in every country in which we operate by not only complying with the laws and rules of each country, but also by respecting its history, culture and customs.

(6) Protection of Intellectual Property
The Minebea Group of Companies (Thailand) respects intellectual property rights and implements proper measures to protect others’ intellectual rights. To protect those rights, the Group also pays full attention to transferring and handling our or others’ technologies or know-how.

(7) Import/Export
Compliance with not only the laws and rules of each country but also all applicable international rules, regulations, and trade agreements shall be maintained when trading products or materials with, or providing technological assistance to, foreign countries. Appropriate management systems and procedures shall be maintained to assure compliance.

(8) Response to Antisocial Forces
The Minebea Group of Companies (Thailand) has no relations with any antisocial forces that may or will pose a threat to the public order and/or safety. At the same time, regarding unreasonable demands, if any, from such forces, without making compromises, the Group shall cooperate with external specialized institutions, including police and lawyers, and deal with such demands in a resolute attitude.

 

III. MANAGEMENT SYSTEM

1. ROLE OF THIS CODE OF CONDUCT

This Code of Conduct is one of the important tools for practicing Compliance based on the company policy. We assure all the stakeholders that, by practices based on the system described below, we will carefully follow the guidelines set out in This Code of Conduct.

 

2. STRUCTURE OF COMPLIANCE

(1) Chief Officer of Compliance
President and Director of NMB-Minebea Thai Ltd. takes a role of the chief officer of the compliance system of Minebea Group of Companies (Thailand).

(2) Compliance Committee
The Compliance Committee, a body to promote Compliance including this Code of Conduct, is established directly under President and Director of NMB-Minebea Thai Ltd.
The Compliance Committee assumes the operation of this Code of Conduct, approved by the Board of Directors, and takes a role of making decisions to address urgent requirements when a serious violation of the compliance occurs.
A secretariat for the Compliance Committee shall be the Compliance Office. The secretariat functions as an organ to execute and promote compliance measures approved by the Compliance Committee. It also functions as the secretariat for the body that makes decisions to address urgent requirements when a serious violation of the compliance occurs.

(3) Application to Each Company of Our Group and Supply Chain
This Code of Conduct is to be circulated to each company of Minebea Group of Companies (Thailand). Each company is required to take necessary compliance measures in accordance with this Code of Conduct.
Moreover, efforts shall be made to voluntarily observe this Code of Conduct in the Minebea Group of Companies (Thailand)’s supply chain, and each company shall request as appropriate that its suppliers and subcontractors agree to and implement this Code of Conduct.

(4) Addition of Detailed Guidelines
When putting this Code of Conduct into practice, while some detailed guidelines have been already stipulated, new detailed guidelines may be added according to specific requirements. We must comply not only with this Code of Conduct but also with such new detailed guidelines.

(5) Duty to Report
When you are not sure if your acts or decisions violate this Code of Conduct, it is your duty to consult your superiors, the competent departments or the consultation service separately designated by the Company.
Also, when you notice any violation of this Code of Conduct by a director or an employee, you must immediately report to the Compliance Office, Human Resources and Administration Division or the consultation service designated by the Company.
We ensure that every aspect of the privacy, such as his/her name and the content of the above-mentioned consultation, will be kept secret. We also ensure that he/she will not be disadvantaged due to such consultation.

(6) Penalty
In case of violating this Code of Conduct, one will be subjected to disciplinary action according to the company rules. When the act of violation causes damage to the company, he/she may be required to indemnify the company for the loss.
One who violates this Code of Conduct for the following reasons will not be exempt from responsibility:
Lack of knowledge on laws and regulations.
Absence of intention to violate the laws and regulations.
Intention to act for the benefit of the company.
(7) Education and Training
Based on this Code of Conduct, education and training concerning compliance are conducted for the following purposes. The employees who are ordered to participate in the training by the Compliance Committee, the secretariat, or an immediate supervisor must not refuse or fail to attend the training without legitimate reasons.
To increase the awareness of overall compliance issues such as laws and regulations as well as corporate ethics.
To provide accurate knowledge of this Code of Conduct and various office regulations.
(8) Audit
Each company of our group is required to conduct regular internal audits in accordance with this Code of Conduct to ensure none of the company activities violates the compliance manual.
With the cooperation of each related department, the secretariat, according to the specific requirements, is to conduct audit to find out if there is any acts of violation of the compliance within our group. The secretariat is then required to report the result of the audit to the Compliance Committee. It also orders the concerned department/section to correct its inadequate operation if necessary.
3. SUPPLEMENTARY PROVISION

(1) Revision
This Code of Conduct is revised when the Board of Directors of the Company approves the draft prepared by a secretariat.
(2) Enactment and Amendment
Enactment: May 4, 2009
Amendment: June 19, 2009
Amendment: September 9, 2010
Amendment: July 13, 2012
Amendment: March 20, 2014 (Change the name of person-in-charge)
Amendment: February 1, 2016
Amendment: August 15, 2017

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