Sustainability Policy | About NTCJ | Nuvoton Technology Corporation Japan

Nuvoton is committed to working with all of our stakeholders through the principles of "fairness, justice, and integrity", while maintaining good channels of communication and complying with all international and domestic regulations. And with the goal of "sustainable operations" and "improvement through innovation", we seek to fulfill our corporate social responsibility vision of "providing a sense of safety, reassurance, and empathy".

NTCJ Code of Conduct

We will respond to changing market demands and stakeholder expectations in areas such as human rights, labor, health and safety, the environment, and ethics, contributing to the development of a sustainable society. In addition, we establish the following Code of Conduct as specific guidelines for realizing our corporate social responsibility vision of "providing a sense of safety, reassurance, and empathy".

（1）Human rights/Labor

Our company respects human dignity. We treat workers with respect in accordance with the principles of "Fairness, Impartiality, and Integrity" to be understood by the global society. This policy applies to all the workers (regular workers including managers, temporary workers, fixed-term workers, and other workers engaged in our business operations).

① Prohibition of forced labor

We never engage in any form of forced labor, including debt bondage, involuntary labor, etc.
We never impose unreasonable restrictions on workers’ freedom of movement in the facility and on entering or exiting company-provided facilities.
We provide all workers with a written employment agreement in their native language, or in a language the worker can understand that contains a description of terms and conditions of employment. Furthermore, we provide employment agreements to foreign migrant workers prior to the worker departing from his or her country of origin. Additionally, we never modify contracts unless the modified version is equivalent to or better than the original from the workers' perspective.
All work must be voluntary, and we do not seek penalties for absence from work or termination of the employment relationship if reasonable notice is given.
We never hold, destroy, conceal, or confiscate the worker’s identity or immigration documents, such as passports or work permits.
We never allow employers’ agents or sub-agents’ to collect recruitment fees or other related fees for employment from temporary or foreign workers. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker.

② Consideration for young workers

We never allow children (under the age of 15) to work.
We never require workers under the age of 18 (young worker) to perform work that is likely to jeopardize their health or safety, including night shifts and overtime.
We establish an appropriate mechanism to verify the age of workers when hiring.
We manage student workers appropriately and never impose excessive or improper jobs.
Also, we ensure that they receive educational opportunities and necessary support.
If child labor is identified, we provide assistance/remediation.

③ Ensuring appropriate working hours and holidays

We aim for a maximum limit of 60 hours per week or the working hours stipulated by laws and regulations in respective regions. We make efforts to enhance work efficiency and reduce working hours if they exceed the target.
We do not force workers to work overtime.
We provide workers one day off or more per week.
We provide workers with annual paid leave in accordance with local laws and employment regulations.
We never reject leave applications from workers without justifiable reasons.

④ Wages

We pay wages and allowances to workers promptly, ensuring compliance with all applicable laws and regulations regarding minimum wages, overtime allowances, and other legally required allowances stipulated in respective regions.
We never reduce workers' salaries as a disciplinary measure.
We provide details of salary payments through documents such as pay slips at the appropriate time.
We ensure equal pay for equal work and qualification.

⑤ Non-discrimination/Non-harassment/Humane treatment

We never tolerate any form of inhumane acts or their possibility in the workplace, including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical suppression, bullying, public shaming, or verbal abuse, and strive to create a fair and pleasant work environment.
We never engage in discrimination or harassment based on race, color, age, gender, sexual orientation, gender identity or expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information, or marital status in hiring and employment practices such as wages, promotions, rewards, and access to training.
We establish disciplinary codes for addressing these cases and inform workers about them.
We never retire, dismiss, demote, or transfer workers to positions with lower salaries irrationally due to situations such as sick leave, maternity leave, or other equivalent leaves related to occupational accidents.
We do not conduct medical or physical examinations that may be used for discriminatory purposes on workers or prospective workers.
We provide workers with reasonable accommodation for religious practices and disability.

⑥ Freedom of association and collective bargaining

Taking into account the laws and labor practices of each country, we respect the right of all workers to form and join trade unions of their own choosing, to engage in collective bargaining, and to participate in peaceful assembly.
We always make efforts to establish healthy relationships with workers and resolve problems through active and sincere dialogues.

（2）Health and Safety

We make efforts to ensure a safe and comfortable work environment, taking into consideration the health of workers.

① Occupational health and safety

We ensure workers' safety by identifying and assessing the possibility of exposure to health and safety hazards, and mitigating them using the Hierarchy of Controls (implementing measures in order of effectiveness to reduce risks).
Where hazards cannot be adequately controlled, we provide workers with appropriate, well-maintained, personal protective equipment, and educational materials about risks to them associated with these hazards.
We will implement gender-responsive measures, such as providing reasonable accommodations for pregnant women and nursing mothers.

② Emergency preparedness

In preparation for emergencies such as disasters and accidents, we identify and assess potential risks and ensure readiness to minimize harm to workers' lives, the environment, and property.
This includes creating action plans (emergency reporting, worker notification, and evacuation procedures), providing education and training, ensuring appropriate fire detection and suppression equipment, maintaining clear and unobstructed egress, ensuring adequate exit facilities, maintaining contact information for emergency responders, and creating recovery plans.
We will execute emergency drills at least once a year.

③ Occupational injuries and illness

In order to prevent, manage, track, and report occupational injuries and illnesses, we will implement procedures and systems to encourage worker reporting, classify and record cases, provide necessary medical treatment, investigate cases, implement corrective actions, and facilitate the return of workers to work.
We allow workers to remove themselves from imminent harm, and not return until the situation is mitigated, without fear of retaliation.

④ Industrial hygiene

We provide workers with safe and healthy working environments and maintain them.
We identify, evaluate, and control risks associated with worker‘s exposure to chemical, biological, and physical agents according to the Hierarchy of Controls.
If we identify risks that cannot be eliminated through the adequate risk management measures, we require workers to wear well-maintained personal protective equipment in accordance with relevant laws.

⑤ Consideration of physically demanding work

We identify and evaluate physically demanding work such as manual material handling, heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks. We then implement proper controls to prevent these tasks from causing work-related injuries or illnesses.

⑥ Safety measures for machine equipment

We evaluate the potential safety hazards associated with using machinery and implement and maintain appropriate safety measures (such as applying protective covers, interlocks, barriers).

⑦ Sanitation, food, and housing

We provide clean toilet facilities, water, hygienic food, and sanitary eating facilities.
When providing company dormitories to workers, we maintain them to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate lighting, and adequate conditioned ventilation. For shared rooms, we offer individually secured accommodations for storing personal and valuable items, and reasonable personal space along with reasonable entry and exit privileges.

⑧ Health and safety communication

Regarding the various workplace hazards which have been identified, we provide workers with education and training on appropriate health and safety information in a language and manner that they can understand, before commencing work. We also provide regular training sessions thereafter.
We will incorporate content on specific risks related to gender, age, etc. into health information and training.
We communicate health and safety-related information to workers by clearly posting it in the facilities or making it available in an accessible location.
We encourage workers to raise health and safety concerns, and we never retaliate against them for doing so.

⑨ Health management of workers

We manage the health conditions of all workers in an appropriate manner.

（3）Environment

We commit to becoming a company that continuously improves itself and achieves sustainable development, in compliance with environmental laws, regulations, and global standards. Additionally, we endeavor to eliminate foreseeable environmental pollution risks by mitigating environmental impacts, reducing of pollution sources to protect the natural environment, and fostering company-wide participation.

① Environmental permit and report

We obtain and maintain all the permits, approvals, and registrations necessary for operating our business, and keep them up-to-date. We also ensure compliance with laws and regulations regarding registration and reporting.

② Pollution prevention and resource conservation

Through appropriate management, we promote the principles of reduce, reuse, and recycle, thereby ensuring the effective utilization of resources and controlling emissions and discharges of pollutants and generation of waste.

③ Control of hazardous substances

We identify, label, and manage chemicals, waste, and other materials posing a hazard to humans or the environment. We ensure the safe handling, movement, storage, use, recycling, or reuse, and disposal of these materials.
We document and archive hazardous waste data for traceability.

④ Solid waste

We implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).
We document and archive waste data for traceability.

⑤ Air emissions

We characterize, routinely monitor, control, and treat, as required, volatile organic chemicals, aerosols, corrosives, particulates, ozone-depleting substances, and combustion byproducts generated from our operations prior to discharge to air.
We effectively manage ozone-depleting substances in accordance with the Montreal Protocol and applicable regulations.
We conduct routine monitoring of the performance of its air emission control systems.

⑥ Material restrictions

We adhere to all applicable laws, regulations, and customer requirements regarding the prohibition or restriction of specific substances in products and materials.

⑦ Water management

We monitor and appropriately manage the source, use, and discharge of the water we use.
We characterize, monitor, control, and treat all wastewater as required prior to discharge or disposal.
We also identify sources of pollution that may contribute to water pollution (flow into rainwater, etc.) and manage them appropriately.
We conduct routine monitoring of the performance of our wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

⑧ Energy consumption and greenhouse gas emissions

We improve energy efficiency and engage in ongoing emission control activities, such as minimizing energy consumption and greenhouse gas emissions.
We establish a greenhouse gas reduction goal and track, document, and publicly report energy consumption and greenhouse gas emissions.

（4）Ethics

We comply with laws, regulations, and ethical standards in all our business activities to fulfill our responsibilities.

① Business Integrity

We uphold the highest standards of integrity in all business interactions, and prohibit any and all forms of bribery, corruption, extortion, and embezzlement.

② Elimination of improper advantage

In pursuit of business acquisition or retention, or to gain unfair or undue profit, we do not provide benefits that violate the law or social ethics, either directly or indirectly through a third party.
Similarly, we do not accept improper advantages from any source.
We implement monitoring, record keeping, and enforcement procedures to ensure compliance with anti-corruption laws.

③ Disclosure of information

We make efforts to disclose information to stakeholders in a fair, accurate, understandable, appropriate, and timely manner. This information includes financial situation and performance, business activities, organizational structure, human rights and labor, health and safety, actions related to environmental issues, and other corporate information.
We do not tolerate falsification of records or misrepresentation of conditions or practices in the supply chain.

④ Intellectual property rights

We respect the intellectual property rights owned by others and strive to prevent or eliminate any infringements of our own rights.
We establish the results of our R&D achievements as intellectual property rights, accumulate them, actively protect them, and fully utilize these rights.

⑤ Fair business activities, advertising, and competition

In procurement of goods and services, we comply with laws and social norms. Also, we base our company's procurement standards on safety, quality, environment, price, lead time, etc., offering equal competition opportunities to global suppliers, and fairly evaluate and select them.
We make efforts to enhance brand values through communication of fair and accurate information on products and technologies. At the same time, we always listen to stakeholders, take their feedback sincerely, and incorporate it into our business activities.
No matter how intense the competition may be, we comply with laws and regulations and prioritize fair sales activities based on corporate ethics.
We never pursue sales and profit over laws or social ethics.
We never engage in any illegal and unethical acts such as bribery, cartel, bid rigging, and controlling the sales price for business partners.
We will respond firmly to anti-social forces and organizations.

⑥ Establishment of mechanisms for handling complaints, identity protection, and prohibition of retaliation

In order to prevent misconduct in our company and the supply chain, we establish a mechanism for handling complaints (i.e., a system that allows concerned individuals to report suspected violations for prompt correction), which is accessible to stakeholders including workers and suppliers.
We never subject suppliers and workers who make reports to disadvantageous treatment such as contract cancellation, dismissal, or demotion. We maintain a process for reporting after the whistleblower confirms to that effect.
We thoroughly manage information to ensure the confidentiality of reports and the anonymity of reporters.
When a violation occurs, we promptly correct the situation, prevent recurrence, and take strict action against the violation.

⑦ Responsible sourcing of minerals

We recognize the mineral* issue as a significant concern, as it often serves as a source of funding for organizations engaged in risky or exploitative practices such as human rights abuses involving child labor, harsh working environments, environmental destruction, corruption, particularly in countries located in conflict zones and Conflict-Affected and High-Risk Area (CAHRA).
In order to fulfill our social responsibility in procurement activities, our policy is to refrain from using minerals involved in unlawful activities as raw materials. In the unlikely event that the company discovers inadvertent use of conflict-affected minerals, we promptly take steps to cease their use. (*tin, tantalum, tungsten, gold, cobalt, etc.)
We exercise due diligence on the source and chain of custody of these minerals and disclose their due diligence measures upon customer request.

⑧ Appropriate export management

We understand the laws and regulations of each country and comply with them.
In the import and export of technology and products (such as parts, products, equipment, software) regulated by laws, we establish a clear management system and ensure appropriate import and export procedures.

（5）Information security

We prevent leaks of confidential and personal information and strengthen our information security system.

① Protection of personal information

We recognize the importance of personal information for all parties involved in our business, including suppliers, customers, consumers, and workers, and take appropriate and reasonable measures to protect it.
We comply with privacy and information security laws and regulatory requirements when personal information is collected, managed, stored, disposed of, transmitted, and shared.

② Prevention of leakage of confidential information

We ensure the prevention of any confidential information leakage, including information from our company, customers, and third parties, and manage and protect it appropriately.

③ Protection from cyber attacks

We take preventive measures against the threat of cyber-attacks to avoid damaging the company and third parties.

（6）Quality and product safety

We assure the safety and quality of our products and services and provide accurate information.

① Ensuring product safety

We fulfill our responsibility as a producer by designing, manufacturing, and selling products that meet the safety standards stipulated by the laws and regulations of each country and ensure adequate safety.

② Quality control

We comply with all laws and regulations, our own quality standards, and customer requirements that apply to the quality of our products and services.

③ Provision of accurate information of products and services

We provide accurate and non-misleading information about our products and services.

（7）BCP/BCM

Even if our company or business partner were to suffer damage from a large-scale natural disaster, we prepare to restart production operations as soon as possible to fulfill our supply responsibilities.

① Creating a BCP and its preparation

We identify and evaluate risks that could affect our business continuity, assess their impact, and create a business continuity plan (BCP) outlining our activities and progress toward implementing mid-term and long-term countermeasures.

② Maintaining, enhancing, and managing BCP

We review the progress of our activities on a regular basis, and strive for further improvement to enhance the effectiveness of the BCP.

（8）Supply chains

We establish partnerships with our primary suppliers and engage in sustainable procurement across the entire supply chain.

① Implementing NTCJ Code of Conduct in collaboration with suppliers

Together with our suppliers, we comply with laws, social standards, and corporate ethics, promote procurement activities which fulfill social responsibilities including the protection of human rights, labor, health and safety, conservation of the global environment, and other actions.

② Selection and evaluation of suppliers

When selecting new suppliers, we set NTCJ Code of Conduct implementation as transaction terms, screening them from the perspectives of human rights, labor, health and safety, conservation of the global environment, and information security, and other actions. Once we confirm that the supplier meets our standards, we start business transactions.
Additionally, we assess our existing suppliers and encourage them to improve based on the evaluation results.

（9）Management System

In order to comply with each item of our Code of Conduct, we establish a management system. We strive for continuous improvement by complying with laws and regulations related to our operations and products as well as customer requirements, incorporating Code of Conduct into our business activities, and identifying and reducing risks.
The management system includes the following.

① Company commitment

We establish policy statements affirming our commitment to due diligence and continual improvement, endorsed by executive management, and communicate them to workers in a language they understand.

② Management accountability and responsibility

We clearly identify executive management and company representatives responsible for ensuring the implementation of management systems and associated programs.
Executive management reviews the status of management systems on a regular basis.

③ Legal and customer requirements

We establish procedures to identify, monitor, and understand applicable laws, regulations, and customer requirements, including the requirements of this Code.

④ Risk assessment and management

We identify and manage risks to ensure compliance with laws, regulations, and Code of Conduct.
We determine the relative significance for each risk and implement appropriate procedural and physical controls.

⑤ Improvement objectives

We set objectives, targets, and implementation plans for improvement, and conduct periodic assessments.

⑥ Training

We establish training programs for workers (including managers) to implement our policies, procedures, and improvement objectives, and to meet applicable legal and regulatory requirements.

⑦ Communication

We establish processes for communicating clear and accurate information about our policies, requirements, and performance to workers, suppliers, and customers.

⑧ Worker/Stakeholder engagement and access to remedy

Where relevant or necessary, we establish ongoing two-way communication with workers, their representatives, and other stakeholders, obtaining feedback to foster continuous improvement.
Additionally, we provide a safe environment for them to grievance and feedback without fear of reprisal or retaliation.

⑨ Audits and assessments

We conduct periodic self-evaluations to ensure conformity to compliance with legal and regulatory requirements, the content of the Code, and customer contractual requirements.

⑩ Corrective action process

We establish a process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations, and reviews.

⑪ Documentation and recording

We create and maintain documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.

⑫ Management of suppliers

We communicate the requirements of NTCJ Code of Conduct to suppliers, monitor their compliance, and request improvements when necessary.