Supply Chain Due Diligence Act (LkSG)
The Supply Chain Due Diligence Act (LkSG) represents an important step toward strengthening human rights and environmental standards in global supply chains. It requires companies to carefully ensure that their own business practices – as well as those of their suppliers – comply with high ethical and legal standards.
As a company, we are fully committed to complying with the requirements of the LkSG. For this reason, we have implemented strict due diligence processes to identify and minimize potential risks in our supply chain at an early stage. This includes the careful selection and ongoing monitoring of our suppliers, as well as risk analyses carried out with the support of specialized software.
Our goal is not only to meet legal obligations, but to go beyond them and take a leading role in ethical business practices and sustainability. We firmly believe that responsible conduct throughout the entire supply chain is the foundation for long-term success, and we are committed to continuously setting and maintaining high standards.
Social responsibility, as well as the respect for and implementation of human rights in our own operations and in our relationships with business partners, form a binding foundation of our business conduct. The implementation of human rights and environmental due diligence obligations within our operations and supply chains is an ongoing process to which we are fully committed. For this reason, we continuously strive to identify and prevent potential long-term impacts on human rights and environmental aspects along the value chain. By appointing a Human Rights Officer within the company, we ensure internal risk monitoring. The following guideline supports us in this process and is outlined below:
Table of Contents:
1.2) Fair Competition
1.3) Disclosure of Information
1.4) Intellectual Property Rights
1.5) Information Security
1.6) Whistleblowing System
1.7) Product Safety
1.8) Quality Management
1.9) Responsible Sourcing of Minerals
2.2) Child and Youth Labor
2.3) Discrimination and Inhumane Treatment
2.4) Wages and Social Benefits
2.5) Working Hours and Holidays
2.6) Right to Freedom of Association and Collective Bargaining
3.1) Environmental Management System
3.2) Environmental Protection and Impact Reduction Activities
3.3) Environmental Permits and Reporting
3.5) Hazardous Substances
3.6) Solid Waste
3.7) Emissions to the Atmosphere
3.8) Material Restrictions
3.9) Water Management
3.10) Energy Consumption and Greenhouse Gas Emissions
3.11) Eco-Conscious Design and Life Cycle Analysis
3.12) Biodiversity Conservation
3.13) Disclosure of Environmental Information
4.2) Workplace Safety
4.3) Emergency Preparedness
4.4) Work-Related Injuries and Illnesses
4.5) Physically Demanding Work
4.6) Industrial Hygiene
4.7) Machine Safeguarding
4.8) Hygiene, Nutrition, and Accommodation
4.9) Health and Safety Communication
5.2) Approach to Universal Social and Environmental Challenges
6.2) Accountability and Responsibility of Management
6.3) Risk Assessment and Management
6.4) Improvement Targets
6.5) Training
6.6) Communication
6.7) Employee Feedback and Participation
6.8) Audits and Evaluations
6.9) Supply Chain Integration
The Nidec Group and its supply chain partners (“Suppliers”) have an ethical responsibility to perform business operations with integrity, fairness and transparency, consistent with the spirit and intent of internationally recognized guidelines. All suppliers of the Nidec Group are expected to comply with applicable legal, regulatory, ethical and social requirements of the countries, regions, cities and other jurisdictions in which they conduct their businesses.
Suppliers must not engage in activities that violate applicable laws, rules, and regulations.
Bribery and corruption pose serious risks in today’s global business environment and underscore the need for employees to avoid inappropriate conduct or conflicts of interest. Suppliers must not tolerate any form of bribery or corruption and must not offer or accept favors of excessive value, expensive gifts, or hospitality that could influence or adversely affect business relationships with customers, agents, suppliers, subcontractors, intermediaries, consulting firms, or other service providers.
Particular caution must be exercised when dealing with government officials. Suppliers must not, directly or indirectly, offer or promise cash, gifts, meals, entertainment, or other items of financial value to domestic or foreign government-affiliated individuals or their family members with the expectation of receiving a business advantage in return.
Suppliers must not engage in illegal or unethical business practices, including but not limited to:
Suppliers must not engage in unfair business practices, including but not limited to:
1.3) Disclosure of Information
Suppliers must disclose material information about labor, health and safety practices, environmental practices, business activities, structure, financial condition, and performance in accordance with applicable regulations and prevailing industry practices.
1.4) Intellectual Property Rights
Suppliers are expected to protect their own intellectual property rights and ensure that their innovations do not infringe upon the intellectual property rights of others.
1.5) Information Security
Suppliers must ensure the proper handling of confidential corporate data by applying appropriate procedures to protect their information assets from unauthorized access, misuse, manipulation, disclosure, or leakage. This includes, in particular:
1.6) Whistleblowing-System
Suppliers must develop an internal reporting system that encourages all directors, senior executives, and employees (including permanent, part-time, temporary, and fixed-termemployees) to report and raise concerns regarding suspected violations of laws and regulations, including unethical practices such as accounting fraud, bribery and corruption, and violations of health and safety requirements.
Suppliers must implement appropriate procedures to:
1.7) Product Safety
Suppliers must give the highest priority to product safety in all aspects of business operations, including product planning, development, design, manufacturing, sales, and customer service. Furthermore, suppliers are expected to comply with all legally mandated safety standards and to continuously strive to exceed these standards to ensure ongoing compliance.
Suppliers are obligated to promptly investigate and identify the cause(s) of any product safety risks by tracing the production process and informing the affected Nidec Group entities.
Suppliers must continuously apply the PDCA (Plan-Do-Check-Act) cycle to improve the quality of their products through the establishment, maintenance, and revision of an effective quality management system.
Minerals such as tantalum, tin, tungsten, and gold, which are currently being illegally mined in the Democratic Republic of the Congo (DRC) and neighboring countries, have become a source of funding for armed anti-government militias. For this reason, these minerals are referred to as “conflict minerals.” The scope of conflict minerals may be expanded in the future to include other minerals or their derivatives.
The Nidec Group expects its suppliers to take appropriate measures to ensure that conflict minerals used in their products do not directly or indirectly finance or support armed groups committing serious human rights violations in the DRC or neighboring countries. Where applicable, suppliers shall cooperate with their direct suppliers to trace the supply chain back to the smelters and refiners processing the minerals contained in their products, primarily using the industry-standard reporting template.
The actions taken and the results of the suppliers’ due diligence efforts must be made available to the Nidec Group upon request.
In the global marketplace, our business activities bring us into contact with diverse social, political, financial, legal, and economic systems, as well as with a variety of cultures, traditions, and languages. Therefore, it is essential for both the Nidec Group and its suppliers to have a solid foundation that ensures human rights are respected and that every individual can develop their abilities in the workplace.
Suppliers must not tolerate the use of forced labor, bonded labor, slavery, or human trafficking in their own operations or in their supply chains.
Suppliers must not retain, destroy, confiscate, or deny access to identity or immigration documents—such as government-issued IDs, passports, or work permits—unless required by law.
Suppliers must comply with the minimum employment age set by national laws or by the International Labour Organization (ILO)—whichever sets the higher standard.
Suppliers are committed to eliminating discrimination in recruitment and employment and to ensuring equal opportunity and fair treatment in the workplace.
Suppliers must provide a working environment free from discrimination based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, or marital status, in all employment-related decisions including hiring, compensation, promotion, rewards, and access to training.
Suppliers must also ensure that there is no harsh or inhumane treatment, including physical, sexual, psychological, or verbal harassment or abuse of employees, suppliers, or vendors.
Suppliers must ensure that the wages paid to employees comply with all applicable wage laws, including those relating to minimum wage, overtime compensation, and legally mandated benefits. Unlawful or unjustified wage deductions used as disciplinary measures are not permitted. For each pay period, employees must be provided with a wage statement that contains sufficient information to verify accurate compensation for the work performed.
Suppliers must comply with all applicable wage and working time laws and regulations, including those relating to minimum wages, overtime, and maximum working hours. Additionally, in cases where employees repeatedly work more than 60 hours per week (including overtime), suppliers are expected to implement corrective measures.
Unless otherwise required by local law, suppliers must provide all employees with at least one day off per week or every seven consecutive days. This rest period is in addition to any statutory vacation provided by national laws and customs.
Suppliers must respect the right of all employees to form and join trade unions of their choice, to engage in collective bargaining, and to assemble peacefully, as well as the right of employees to refrain from such activities.
Suppliers must ensure that employees and their representatives can communicate openly with management and express their ideas and concerns regarding working conditions and management practices without fear of discrimination, retaliation, intimidation, or harassment.
The Nidec Group and its suppliers must recognize that environmental responsibility is an essential part of manufacturing world-class products. Both the Nidec Group and its suppliers are committed to minimizing the negative impact of their manufacturing processes on communities, the environment, and natural resources, while protecting public health and safety. Environmental adaptability not only enables a company to meet new environmental regulations and market requirements, but also to bring environmentally conscious products and solutions to market in a timely manner.
Suppliers must establish, maintain, and manage an appropriate environmental management system and continuously improve it in order to contribute to global environmental protection and the reduction of environmental impacts.
Suppliers must take appropriate measures to reduce resource and energy consumption, greenhouse gas emissions (which are a major cause of climate change), other air emissions, water consumption (intake), total solid waste, and wastewater. Suppliers must implement measures to prevent pollution at the source, control pollution, and promote recycling and reuse in accordance with local laws and relevant regulations.
Suppliers must use resources efficiently by:
1. Optimizing the use of resources:
2. Reusing resources:
3. Recycling resources:
4. Developing products that are easier to dismantle and recycle
Suppliers must obtain, maintain, and keep current all necessary environmental permits, approvals, and registrations, and must fulfill all applicable operational and reporting requirements.
Suppliers must address sources of pollution, implement pollution control systems, and reduce emissions of pollutants and the volume of waste through process modifications in production, maintenance, and facility management. Furthermore, suppliers are expected to actively contribute to the conservation of natural resources, including water, fossil fuels, minerals, and forest products.
Suppliers must clearly identify chemicals that pose risks to human health and the environment by properly labeling their containers, and must ensure these substances are handled, transported, stored, used, recycled, reused, and disposed of safely.
Suppliers must identify solid waste (non-hazardous waste) and strive to manage, reduce, and recycle it appropriately.
Suppliers must verify the physical properties of emissions prior to release—including volatile organic compounds (VOCs), aerosols, corrosive substances, microparticles, ozone-depleting substances, and calcined by-products generated during manufacturing processes. Suppliers must regularly monitor, manage, and dispose of these emissions, and are expected to routinely assess the functionality and effectiveness of their emissions management systems.
Suppliers must comply with all applicable laws, regulations, and customer requirements regarding the prohibition or restriction of certain substances in products and manufacturing processes, including proper labeling for recycling and disposal.
Suppliers shall implement, maintain and improve a water management system that monitors water sources, water intake and effluent discharge, analyzes their characteristics, and puts the results of monitoring and analysis in writing to reduce water use and effluent discharge. Suppliers shall also take reasonable measures to prevent pollutants from entering waterways.
Suppliers shall monitor their energy usage and greenhouse gas emissions and promote initiatives to reduce them through continuous improvements in energy efficiency.
Suppliers must assess the environmental impact of their products throughout the entire life cycle—from raw material extraction through production, distribution, and disposal—and work on the development of products with lower environmental impact.
Suppliers must adequately consider biodiversity by protecting animal and plant species that are endangered or at risk of extinction.
Suppliers must regularly disclose their efforts and results in environmental management in order to build and maintain a good relationship with stakeholders.
4. Occupational Health and Safety
The Nidec Group and its suppliers must ensure occupational health and safety in the workplace and protect employees from hazards and risks associated with daily work activities. Suppliers are expected to create a safe and healthy working environment, which not only minimizes the incidence of work-related injuries and illnesses but also improves product and service quality, production reliability, employee retention, and morale.
Every employee has the right to a workplace free from hazards. In addition, employees are personally responsible for working safely and for helping to create a safe working environment for others.
Suppliers are obligated to ensure that their employees are not assigned to hazardous tasks and that all applicable governmental health and safety laws, regulations, and their own internal standards and instructions are followed.
Suppliers are encouraged to refer to internationally recognized management systems such as OHSAS 18001 and the ILO Guidelines on Occupational Safety and Health as useful sources of additional information.
Suppliers must establish, maintain, and continuously improve a written policy and procedures to control occupational health and safety risks in the workplace.
Suppliers must assess potential health and safety risks and prevent employees from being exposed to workplace hazards (e.g., electrical and other energy sources, fire, vehicles, or fall hazards). This should be achieved through proper design, engineering and administrative controls, preventive maintenance, and safe work procedures (including lockout/tagout), as well as ongoing safety training.
Where hazards cannot be adequately controlled by such means, suppliers must provide employees with appropriate and well-maintained personal protective equipment (PPE). In addition, suppliers are expected to continuously train their employees on the risks associated with workplace hazards and to encourage the reporting of safety concerns.
Suppliers must continuously strive to identify and assess potential emergency situations and incidents in order to minimize harm to life, the environment, and property. To this end, they must implement emergency plans and response procedures that include: emergency notification, employee communication and evacuation procedures, training and drills, appropriate fire detection and suppression systems, sufficient evacuation routes, and recovery plans.
Suppliers must ensure that procedures and systems are in place to prevent, manage, track, and report occupational injuries and illnesses. These measures include:
4.5) Physically Demanding Work
Suppliers must protect employees from avoidable injuries or illnesses resulting from physically demanding work by implementing appropriate measures such as regular breaks, the provision of mechanical aids, and dividing tasks into smaller units.
Physically demanding work may include:
Suppliers must also take appropriate steps to ensure that pregnant women or nursing mothers are not exposed to excessively strenuous working conditions.
Suppliers must identify, assess, and control health risks associated with exposure to chemical, biological, and physical agents. Preventive measures, including personal protective equipment (PPE) programs, must be implemented to protect workers from excessive exposure.
Suppliers must conduct risk assessments for machine safety and ensure proper maintenance of protective devices, fail-safe designs, interlocks, and barriers on machinery that poses injury risks to workers.
Suppliers must provide employees with access to clean and sanitary toilet facilities, potable drinking water, and hygienic facilities for the preparation, storage, and consumption of food.
Suppliers must provide employees with appropriate workplace health and safety training, preferably in their native language. Health and safety-related information must be clearly posted in the facility and made readily accessible to all workers.
Corporate social responsibility encompasses nearly every interaction a company has with society. The responsibility of the Nidec Group and its suppliers goes beyond addressing the interests of immediate external stakeholders and also includes engaging with and supporting the broader community.
Suppliers are expected to build strong and trustworthy relationships with local communities that may be affected by their business activities, through open and honest communication. They should also consider the views and concerns of the community in their operations.
Suppliers are expected to share the Nidec Group’s vision for sustainable business growth by providing technological solutions to major global challenges such as climate change, environmental degradation, poverty, resource and energy scarcity, and health issues.
6. Framework for Ensuring Effectiveness
Suppliers must establish and maintain a management system that translates the principles of this Code into practical operational procedures. The system must be designed to ensure:
(a) compliance with applicable laws, regulations, and customer requirements;
(b) alignment with this Code; and
(c) the identification and mitigation of operational risks related to the topics covered herein.
Relevant control procedures may be developed by adopting or referencing international standards such as ISO 14001, OHSAS 18001, or the Responsible Business Alliance (RBA) Code of Conduct.
Suppliers must establish and maintain statements of social and environmental responsibility, affirming their commitment to legal compliance and continuous improvement. These statements should be posted, where possible, in the local language(s) at the supplier’s facilities.
Suppliers must clearly identify senior executives and responsible personnel who are accountable for the implementation of the management systems and related programs. Management must regularly review the status and performance of these systems.
Suppliers must develop a process to identify the risks related to legal compliance, environmental protection, health and safety, labor practices, and ethics that are associated with their operations. Suppliers must also determine the significance of each risk and implement appropriate procedural and physical controls to manage identified risks and ensure compliance.
Suppliers must establish written performance objectives, targets, and implementation plans to improve their social and environmental performance. They must also regularly evaluate their progress toward achieving these targets.
Suppliers must develop training programs for managers and employees to implement their policies, procedures, and improvement objectives, and to ensure compliance with applicable legal and regulatory requirements.
Suppliers must establish procedures to provide clear and accurate information to their employees, suppliers, and customers regarding their policies, procedures, expectations, and performance.
Suppliers must establish ongoing procedures to assess employee understanding of the practices and conditions addressed in this Code, to solicit feedback, and to foster continuous improvement.
Suppliers must conduct regular self-evaluations (internal audits) to verify compliance with legal and regulatory requirements, the content of this Code, and the contractual obligations with the Nidec Group regarding social and environmental responsibility. These internal assessments may be supplemented by external evaluations (second- or third-party audits) to incorporate industry best practices—either at the request of the Nidec Group or on the supplier’s own initiative.
Suppliers must cascade the requirements of this Code to their key direct suppliers as part of an initiative to promote responsibility throughout the entire supply chain.
An effective complaints mechanism is a key element in ensuring compliance with the German Supply Chain Due Diligence Act (LkSG). It enables both internal and external stakeholders—such as employees, suppliers, and affected parties—to report potential human rights or environmental violations within the supply chain quickly and easily. This is essential for identifying risks at an early stage, addressing grievances, and preventing negative impacts.
As a global leader in the automotive industry, Nidec Motors & Actuators places the highest value on excellence, honesty, and integrity, as well as strict compliance with all applicable laws. The trust of our customers, business partners, and employees is our most valuable asset. To maintain this trust, we always act in accordance with the highest business and ethical standards and comply with all relevant legal requirements.
The complaints mechanism also helps the company proactively fulfill its due diligence obligations, identify potential violations, and respond appropriately. By integrating this mechanism into our risk management system, we are able not only to meet legal requirements but also to shape a sustainable and responsible supply chain.
Reports must be submitted in good faith and based on information that the reporting person believes to be accurate to the best of their knowledge and belief. Nidec Motors & Actuators carefully and confidentially reviews each report to determine appropriate actions to protect the company and all involved.
2.1 Recipients and Scope of Application
The complaints procedure at Nidec Motors & Actuators is open to all relevant stakeholders worldwide, including employees, suppliers, business partners, and external interest groups such as NGOs and local residents. It offers a channel for reporting human rights or environmental risks and violations within our own operations as well as across the entire supply chain. Accessibility is ensured through multiple reporting channels so that any individual who is potentially affected or has knowledge of a violation can submit a complaint.
2.2 Procedure
- Responsibility: The Compliance Office of Nidec Motors & Actuators is responsible for receiving and processing complaints. It operates independently and confidentially. In the respective regions, regional compliance officers support the implementation and monitoring of the complaints procedure. All parties involved are bound by strict confidentiality.
- Receipt of Complaint:Upon submission of a complaint, the reporting person will automatically receive an acknowledgment of receipt. The complaint is immediately forwarded to the responsible regional compliance team, which reviews the matter and coordinates the next steps.
- Plausibility and Review: Each complaint is reviewed for plausibility. If necessary, a more in-depth investigation is initiated. Relevant departments such as Legal, Procurement, or Supplier Management may be involved in this process. All complaints are handled fairly and impartially.
- Action in Case of Violations: If a human rights or environmental violation is confirmed, the company will immediately initiate appropriate measures to mitigate and remediate the damage. These may include process adjustments, contract revisions with suppliers, or targeted training measures.
- Action in Case of No Violation: If the complaint does not lead to the identification of a violation, a preventive risk review will nevertheless be carried out to minimize potential future risks. Preventive measures may be implemented as part of supply chain due diligence or internal process improvements.
- Anonymous Reporting: Reporting persons may submit complaints anonymously. Nidec Motors & Actuators ensures that no data is collected that could reveal the identity of the reporting individual. Anonymous complaints are treated with the same level of care and diligence as non-anonymous ones. Any form of retaliation or disadvantage against whistleblowers is strictly prohibited.
- Protection of the Reporting Person: All whistleblowers are protected against any form of discrimination or retaliation. The company is committed to preserving the confidentiality of the identity of reporting individuals and to ensuring that no negative consequences arise from the act of reporting a violation.
The reporting channel is a vital tool for identifying and addressing potential human rights and environmental violations within our supply chain at an early stage. Your complaint submissions play a critical role in helping us fulfill our obligations under the German Supply Chain Due Diligence Act (LkSG) and in upholding ethical standards.
To submit a complaint confidentially, please contact us at: lksgcompliance@nidec-ma.com, or use the anonymous reporting system
The reporting system is available in a wide range of languages.
All reports are handled with the utmost care and discretion.
All complaints received, along with any measures taken in response, are thoroughly documented and retained for a minimum of seven years in accordance with the requirements of the LkSG. These records serve both internal evaluation purposes and compliance with the reporting obligations under Section 10 of the LkSG. The effectiveness of the complaints procedure is reviewed annually and adjusted if necessary to meet legal requirements and stakeholder expectations.
This dedicated procedure is integrated into Nidec Motors & Actuators’ existing compliance structures and ensures full alignment with the requirements of the LkSG. By combining global compliance processes with the legal obligations of the Act, we strengthen effective risk management and enhance the protection of human rights and the environment throughout our supply chain.