Compliance

The public complaint and reporting procedure is available to anyone, including:

• all employees of the TDK Electronics Group worldwide, including all business groups as well as subsidiaries and sales companies;
• all employees of TDK companies outside the TDK Electronics Group based in the EMEA region, (e.g., TDK-Lambda and InvenSense companies);
• third parties outside of TDK, (including, but not limited to organizations, suppliers, agents and other individuals affected by TDK’s corporate activities or business).

Any violation of applicable laws or internal company rules, as well as corresponding suspicious cases, may be reported. The suspicion may be directed at an individual employee or it may be related to a TDK business. Whistleblowers should not conduct their own investigation to determine whether a suspicious case is a violation of law or company rules. TDK expects that whistleblowers will not intentionally and/or knowingly make false reports, but will act to the best of their knowledge and in good faith and make reports that they believe to be true.

In particular, the following may be reported: 

• Human rights violations
• Violations of environmental, health and safety regulations
• Anti-competitive behavior
• Corruption and bribery 
• Information security 
• Misuse of company property 
• Export control violations 
• Theft, fraud, embezzlement and money laundering 
• Conflicts of interest 
• Other misconduct (e.g., discrimination, harassment) 

Employees can always report violations directly to their manager. In addition, there are several different reporting channels that employees and third parties can use to submit reports. 

These reporting channels are described in more detail in the following sections. 

TDK Electronics has established an online whistleblowing portal. This allows electronic reporting in multiple languages 7 days a week, 24 hours a day. The online whistleblowing portal is managed by an independent operator. The data is stored on secure servers in Germany. Only a few selected TDK Electronics Compliance Officers may access, evaluate and process complaints or reports. 

The whistleblower can access the report at any time by assigning a password and individual key code. This process allows for further communication between the compliance officer and the whistleblower, anonymously if desired.

Online whistleblowing portal

All reports will of course be treated confidentially. The confidentiality of the report and the identity of the whistleblower are of the utmost importance to TDK Electronics. 

Reports are handled according to a strict ‘need-to-know’ principle. This ensures that the smallest possible group of people is involved in the processing of reports. TDK Electronics will respect and maintain the anonymity of the person who submits the report, if requested, throughout the entire process, except in the following cases: 

• the person providing the information consents to the disclosure of his or her identity and/or report; 
• the disclosure is necessary for TDK Electronics’ compliance with a legal obligation or vis-à-vis authorities; 
• the disclosure is made by TDK Electronics as part of its cooperation with government authorities. 

Reports can be made without revealing names or identities. The online whistleblowing portal contains specific technical measures to ensure the anonymity of the whistleblower. However, anonymity can only be guaranteed if the whistleblower does not provide any information that would allow the identity of the whistleblower to be inferred. 

No one who makes a report in good faith will be penalized, discriminated, or otherwise retaliated. It does not matter whether the information provided ultimately proves to be completely true or not. 

If a whistleblower believes that he or she has been discriminated against, retaliated against, or otherwise adversely affected as a result of making a report, the whistleblower may contact TDK’s compliance officers by using the channels mentioned above. TDK’s compliance officers will investigate each report.

Reports are generally handled by the TDK Electronics Legal & Compliance Department in Munich, Germany, which acts as the central reporting office for all complaints and reports, regardless of the channel through which they are reported. 

Reports are handled by a dedicated TDK compliance officer. The employees responsible for handling reports are impartial, independent, not bound by instructions and sworn to confidentiality. Depending on the nature of the report, selected employees from specialized departments may be involved on a ‘need-to-know’ basis to obtain relevant information and clarify the facts.

Every report received is taken seriously. The first step is to determine whether the report contains sufficient information for further clarification of the facts. If further information is needed, the compliance officer will contact the person who provided the information, if possible.