TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMAENVIRONMENTAL
SOCIAL
GOVERNANCEREPORTTSUBAKI NAKASHIMA

Tsubaki Nakashima is an

Organization with a challenging spirit,
committed to the respect ofenvironment and upholding sustainability
standards; this respect and commitment are central
to the success of our 20 Plants in 12 Countries,
in all the Communities in which we operate.

We are a manufacturer of precision balls, rollers, ball screws,
and blowers with local production and local procurement, short delivery
times and detailed support, through a well-organized production and sales
network, responding to the needs of our Customers, and realizing further profitable growth,
continuously increase Corporate value.
As the social, industrial, technological and lifestyle changes are progressing globally,of realizing Corporate Value are:
4

1

A better
Corporate
Citizenship2

The highest
QCDS (Quality,

Cost, Delivery
time and Service)3

Teamworkin the spiritof “OneTeam”

4the foundations

A truly
GlobalCompany

5

Further
Profitable
GrowthTsubaki Nakashima appreciates and encourages the contribution of every Team Member in every location.
It is the variety of talent, ideas, opinions, and experiences – Tsubaki-Nakashima know-how – that givesa broader understanding of the marketplace and the world around; it is how our Company builds
high-performance Teams and deliver innovative solutions for Customers.

PRECISIONFOR AchangingWORLD

As Tsubaki Nakashima,
we recognize our responsibility to address
the environmental and social impacts of our business.
Our Global Sustainability System – a multisite integrated system
based on ISO 14001, ISO 45001, and ISO 50001 - has been implemented
in many of our factories in the world and it will be fully applied in 2021.
A responsible use of resources and energies, as well as tracking and reducing
Green House Gas (GHG) emissions, will allow us to lessen our climate change impact
and provide important opportunities to help drive momentum for global climate action.
The urgency of climate change is recognized in the UN Sustainable Development Goals(SDGs) – SDG 13 calls for urgent action to combat climate change and its impacts.

supports the SDGs

Tsubaki Nakashima
and recognizes the need for engaging others
to collectively play our part in addressing climate change, as no single company can make meaningfulprogress alone. At Tsubaki Nakashima, we are taking initiatives to eliminate accidents and occupational
diseases, minimizing risks, reducing the production ofwaste and to tackle climate change, driving momentum
for global climate action. For our direct operations,this approach involves increasing energy efficiency
and expanding clean energy by investing in
renewables. Tsubaki Nakashima will continue topursue innovative and sustainable
solutions for our Products, reducing energy use in our

direct operations, improving the work environment, andusing the available resources in a responsible way.
Director and Representative
Executive Officer, CEO
Koji Hirota

5Introducing Tsubaki Nakashima’s second Sustainability
Report, a document that uncovers the 2020 operations of our 20 plants
around the world, this report embodies our aim to continue growing as anenvironmentally responsible and ethically sourced business, therefore reaffirming
our commitment to transparency and good governance, particularly in matters ofsustainable and profitable growth, attention to our Stakeholders, and the Vision Zero’s
Approach (Zero accidents, Zero occupational illnesses, Zero wastes, Zero inequalities, Zero lackof knowledge). It aims to represent a real evolution of the Company with a view to the continuityof values, considering elements of the past and above all the strong projection to the future. Since
2017, the Company has grown on solid pillars such as respect for people, safety at work, the quality ofservices offered, attention to customers, the environment and transparency in relationships; all factors still
today not only present but strengthened and in which we continue to invest. Precisely for this reason we
have decided to invest and draw up the Sustainability Report; because we have always believed that serious
Corporate Social Responsibility can make a difference in everyday work. This is the second non-financial
reporting report that Tsubaki-Nakashima publishes to reach and involve all its Stakeholders and in particular6

The report addresses itemsof significant importance to TsubakiNakashima’s business strategy and the narrative describes
our efforts to contribute to the United Nation’s Sustainable
Development Goals (SDGs).
Making innovation, even before operating on processes and structures, means
working on trust, on culture, on the motivation of employees and collaborators.
It means improving and never stopping, to become an excellence in our specificbusinesses to satisfy our Customers and becoming a source of inspiration for our Competitors.
Publishing the Sustainability Report on a regular basis has allowed us and allows us to becomeaware offor our Stakeholders.

who we are and what we want to represent

RESPECT SAFETY QUALITYof ATTENTIONto ATTENTIONto TRANSPARENCY
forpeople atwork services
customers environment inrelationships
its Employees, Customers and Suppliers, as well as our Shareholders, with the aim of improving our way to do business. And this arises as a spontaneous consequence of the subjective values ​​and the personal ethical senseof each of us. An individual responsibility even before a Corporate one, which has led us here, today,
to innovate and evolve, because there is an important link between innovation and sustainability,
which identifies the ethical depth of a company and its ability to generate shared value in the long run.

IMPROVING
AND never
STOPPING

The reporting framework prescribed in the Global Reporting Initiative (GRI)
Standards. The person responsible for the content and form of thisdocument is the CSO, Hisashi Tate, and the CHRO, Franco Dutto.
For any information, it is possible to contact them.

7

by Kosaburo Chikamori, Toyo
Foundedin
1934
Steel Ball Seisakusho started manufacturing steel balls for bicycles. In 1954
the Company changed name to Tsubakimoto Steel Ball Manufacturing Co., Ltd. andin 1958 began mass production of nylon, stainless, brass, and other special balls suchas tungsten carbide balls.
In 1959 Tsubakimoto started manufacturing and sale of ball screws and in 1961 theCompany was listed on the second section of both the Tokyo and Osaka Stock Exchanges.
In 1973 it started manufacturing and sale of ceramic balls.
More recently, in 1996 the Company has been merged with Nakashima Seisakusho Co., Ltd.,and finally Tsubaki Nakashima Co., Ltd. was established, starting a long process of acquisitions (USA,
India, China, Poland, Taiwan, UK, Thailand until the most recent in 2017 with the acquisition of Precision
Bearing Components, Group of NN Inc.).

83Countries with offices

globalTsubaki Nakashima is a
producing a broad range of high-quality

Company

precision balls, rollers, ball screws and other precision parts.

We boast a high global market share in the field of precision balls, and one of ouradvantages is that we have a wide product lineup of over 20,000 types of high quality,
including various materials and sizes. Precision balls are mainly used for ball bearingsand contribute to the quality and reliability of final products such as automobiles and machine tools.
Precision rollers are used in certain non-bearing applications such as hydraulic pumps and motors,
in addition to applications similar to precision balls. In recent years, in addition to conventional steel
balls, we have strategically expanded the scale of manufacturing ceramic balls, which are expected
to grow significantly; ceramic is lightweight yet has high strength, and has excellent insulation, wear
resistance, heat resistance, and corrosion resistance, for EVs (electric vehicles), wind power generators,
medical equipment such as MRI and CT, and communication like 5G infrastructures and technologies.
Ball screws are mainly used in machine tools as parts that affect accuracy. We also handle medium- andlarge-sized blowers according to the application of each facility such as steelworks, thermal power plants, andnuclear power plants.
Tsubaki Nakashima is a known brand in the Medical Devices Business, where we produce solid plastic balls, thatare a light-weight alternative to metal balls - less than 1/6th the weight of metal and the weight of aluminum,
advances in plastic material formulations and thermoplastic products can even outperform metal in certain
applications – and high-quality injection molding of plastic tubes, petri dishes and other plastic disposables.
We strive to constantly increase the quality of our products and achieve virtually zero defects. In refining
our manufacturing processes, we have developed in-house both proprietary grinding machines to achieve
sphericity and our own inspection machines to ensure consistent quality for our customers.

12

TOWARDS
NEW goals and BEYONDCountries with

20

plants9EUROPE

6
10

ASIA

6

AMERICA
JAPAN

THE
NET

4

4
GLOBALPRESENCE

20 PLANTS

Tsubaki Nakashima Co. Ltd. is headquartered in Nara, Japan, with offices in Osaka,
Singapore,Seoul and 20 plants in 12 Countries: Japan, United States, Italy, Poland,
Slovakia, The Netherlands,UK, Bosnia, China, Thailand, India and Taiwan.
This enables Tsubaki Nakashima to respond to various customer needs,
local procurement, quick delivery, and superior customer support.

11

Krasnik, POLAND
Kysucke, SLOVAKIA
Konjic, BOSNIA

Sault St. Marie - MI, USA

EUROPENORTH AMERICA
Erwin - TN, USA

Worthing, UK
Veneendaal, NETHERLANDS
Pinerolo, ITALYASIAKariyama, JAPANOkayama, JAPANKatsuragi, JAPAN
Sechibaru, JAPAN

Mountain City - TN, USA
Cumming - GA, USA

Taichung, TAIWAN12TWELVENATIONSGLOBALPRESENCE
Silvassa, INDIA
Chongquing, CHINA
Kunshan, CHINA
Taicang, CHINA
Rayong, THAILAND

20
PLANTSIN THE WORLD

13

14

TRUE
NUMBERS12

3.147

52.875

GLOBALORGANIZATIONBELONGING TOREVENUEFY2020countries

employees

30

different
nationalities

MJPY

15

CEO

CFO

COO

CHRO

EuropeAmericasJapan, China
GCB, L/B

Global / AccountManagement
Americas

Japan

China

BusinessIntelligence

Monozukuri

Global / AccountManagement

16

EuropeCSO

Engineering
Global CeramicBusiness

The corporate structure of the company is made up of a high-level company organized by a Boardof Directors made up of 7 members and by a Management Committee (made up of 7 members).
The Company organization chart is divided into 2 Great Regions which are divided in 6 Regions
and/or Businesses, 3 Administrative and Strategic Functions (finance and control, human resources
and sustainability, strategy) and 4 Operational Functions (engineering, purchasing, quality,
plant management and continuous improvement) under the Monozukuri direction.

NO MANIS AN ISLAND

Linear & Blower
Business

Plant Mgmt Level 3 Kaizen
Quality - Central
Laboratory
Purchasing

17

REALIZEFURTHERPROFITABLEGROWTH18

VISION

AIMING TO BE A SHINING
EXAMPLE OF A COMPANY
WHICH CONTINUOUSLYSEEKS IMPROVEMENTVISIONand MANAGEMENT
PRINCIPLES

19

BUILD20

MISSIONSTAKEHOLDER TRUSTAS WE GROW
AND PROSPER

WITH COMMUNITIESAND TO HELPCREATE A BETTER WORLDVISIONand MANAGEMENT
PRINCIPLESOur mission is to build stakeholder trust as we grow and prosper with communities
and to help create a better world. We consider any action designed to realize Tsubaki
Nakashima’s Vision and Management Principles to be a Corporate Social Responsibility (CSR)
activity. In addition to ensuring compliance, observing corporate ethics, and fulfilling our
responsibilities at a level that exceeds what society requires, we will fully demonstrate
our unique creativity in CSR by creating value through the products we develop andmanufacture.

21

We will improve our manufacturing technologies
on a continuous basis to make the best products in the world
and contribute to preserving the global environment.

ComplianceContribution to theglobal environment

With our creativity and an unwavering spirit to take on challenges,
we will provide our customers with the highest QCDS (quality, cost, delivery,and service), drawing ideas from our customers and the market.
We will create a teamwork-oriented corporate culture, maximizing the strengthsof our employees while valuing their satisfaction at work and in their lives.

We aim to become a truly global company with an international mindset.

22

A BETTERCORPORATE CITIZEN
Continuous
strenghteningof the company

THE
HIGHESTQCDSFURTHERPROFITABLEGROWTH

Marketoriented actions
for customers’
benefitContinuous
innovation andkaizan(continuous
improvement)

We aim to be a company that continues to achieve profitable growth.
Tsubaki Nakashima Group supplies a diverse range of
products to customers worldwide to create new values

through manufacturing and contributing to society
at large, in a sustainable way.

MANAGEMENT
PRINCIPLESVISION
andMANAGEMENT
PRINCIPLES

WE

23A TRULY GLOBALCOMPANYTEAMWORK

Global reach / Local

Communication withand respect for each other

Adaptation
to global standard

Mutual trustwith business partners

ENVIRONMENTDEVELOPMENTTRUENOURISHMENT

5 MATERIAL
ITEMS
Improvementof

as a framework for its
sustainability activities

prod
uct
ivit
g
e
d
e
(
l
S
o
w
c
o
i
n
a
k
l
• Develfonoitopme yCreant)ronment • Social • Profit)
i
v
n
E
(
e
f
i
l
lity ofauq(Environment)
d
f
n
a
o
y
t
t
socie
men
d
e
e
ocial)
z
S
v
i
n
•
o
o
r
t
n
carb
Imp
nme
e
o
r
d
i
fa
Env
(
and in addition to that, it has set the sales of ceramic balls of our
o
y
t
n
e
o
i
i
c
t
group as Sustainability Performance Targets, with the aim to continue
d so
liza
e
t
to contribute to the global environment by continuously evolving
a
en
i
Re
r
world-class products and manufacturing technologies. The Company
g-oni
is committed to increasing its contribution to the environment bylcydeveloping ceramic balls that improve energy and environmental
recaperformance. Tsubaki Nakashima’s ceramic balls are lightweight,fnostrong, long-lasting, highly insulating, wear-resistant, heat-resistant,

Re
ali
za
tio

PROFIT
SOCIAL24

Tsubaki Nakashima has set

and corrosion-resistant, contributing to energy conservation invarious products, and are expected to grow in the wind power
generation, EV, and medical applications.

VISION
andMANAGEMENT
PRINCIPLES

25

26

Professional ethics and corporatesocial responsibility are the cornerstones
on which the company’s business is based.
Honesty, seriousness, fairness, respect, ethics,
and safety in work and in interpersonal relationships
are and always will be fundamental pillars of Tsubaki
Nakashima’s work. The win-win partnership between
customer and supplier as well as the enhancement
and continuous training of its human resources are twomain directions of the Company’s work and choices. Tsubaki
Nakashima makes its wealth of international skills andknow-how available to customers and the local area, pursuing
excellence in the provision of products and services, with the aimof creating shared value and developing long-lasting
collaboration networks. In addition to ensuring compliance,
observing corporate ethics, and fulfilling our responsibilities
at a level that exceeds what society requires, we will fully
demonstrate our unique creativity in Corporate Social
Responsibility by creating value through the products
we develop and manufacture.

CULTURE,ETHICSand VALUESAt Tsubaki Nakashima, we have closelyaligned our Management Statements,
Codes, Policies and Systems with internationally recognized standards tohelp ensure that we serve the role thatsociety expects of us. Tsubaki Nakashima also understands and respects
the laws and regulations in the countries and regions in which it operates.

CORPORATESOCIALRESPONSIBILITY
INTERNATIONAL
STANDARDSVISION
andMANAGEMENT
PRINCIPLES

27

Corporate Social
Reponsability Themes

ESG

Products and Services
Business Operations alignedwith global social trends

EN
Productivity Innovation and Competitiveness VIR
ON
Strategic MarketingME
Effective use of energy and resourcesNT
Productivity Improvement - Motus 4.0

68

TICK
NOTICES

Climate change

28

Contributing to the environment(procurement, products)
Respect of human rights
Diversity
Training and development,
employees engagement
Supply Chain

SO
CI
AL

Product Quality and Development
ComplianceManagement Systems

GOV
ERN
ANCE
VISION
andMANAGEMENT
PRINCIPLES

29

Tsubaki Nakashima has

ManualofCompliance, Code of Businessadopted a

Ethics and related Policies

addressed to all those who have
employment, collaboration,
consultancy, or other relationships
with the Company. The Manualof Compliance, Code of Business
Ethics and related policies dictates
the rules of correctness andtransparency that distinguishthe company’s work and isbased on a series of principles
with values, which are thendeclined within the code.

In order to conduct businessand grow on a global scale, theGroup is working to strengthen
its highly transparent
and objective Corporate
Governance System.
In addition, we haveestablished a GroupManagement Systemwith a sense of unity
by realizing a groupcompany management
function with efficiency
and expertise.

Our

Corporate Governance
Systemconsists of the Board of Directors, Nomination Committee,
Compensation Committee, and Audit Committee as supervisory bodies, and MC(Management Committee) and RMC (Risk Management Committee) as business execution
bodies. We have adopted the organizational design of a company with a nominating committee,etc., because we believe that the separation of supervision and execution is a means of enhancing
corporate value by strengthening the supervisory function and ensuring prompt management.
The Board of Directors, consisting of 7 Directors (including four outside Directors), makes decisions on basic
management policies and supervises the execution of business by the Executive Officers. Each of the outside
Directors has his or her own area of expertise and based on their extensive experience and wide range of knowledge, they provide advice and exchange opinions on management, thereby fulfilling the supervisory function.
The Nomination Committee consists of two outside Directors (including the Chairman) and one inside Director,
and most of the committee members are outside Directors to ensure the appropriateness of nominations.
The Nomination Committee decides the details of proposals for the election and dismissal of Directors.
The Compensation Committee consists of two outside Directors (including the Chairman) and one inside
Director and has a system to ensure the appropriateness of remuneration; it determines the basic policy
on remuneration, etc. for Directors and Executive Officers and the amount of remuneration for everyone.
The Audit Committee consists of three outside Directors. The Audit Committee is composed of three outside
Directors, each of whom has a different area of expertise, and is appointed based on the belief that audits fromvarious perspectives are possible. The Audit Committee audits and supervises the execution of businessby the Directors and Executive Officers and decides on the content of proposals for the appointment anddismissal of the accounting Auditor to be submitted to the General Meeting of Shareholders.
In addition, we have established a system in which a full-time assistant to the Audit Committee
assists the Audit Committee.

Corporate Governance31Compliance Promotion System

Under the supervision of the President and Representative Executive Officer,
who is in charge of overall management, compliance is promoted mainly by the
Executive Officer in charge of HR, Compliance & Sustainability (CHRO)
In addition, an Internal Audit Office has been established directly under the President andRepresentative Director to conduct internal audits and confirm the status of compliance.
In addition, an assistant to the Audit Committee has been established under the direct supervisionof the Audit Committee to audit the compliance status of directors and other officers.
The Internal Audit Office, the Audit Committee assistant, and the accounting auditor share information
as necessary to strengthen cooperation.
The Group experienced a problem with non-conforming products
in 2018. To prevent the recurrence of this problem, we held a
Recurrence Prevention Committee under the direct control of the
President and Representative Executive Officer and implemented
monitoring of related departments. Currently, the Recurrence
Prevention Committee is continuing to meet.
32

SPECIFIC
POLICIES

TRAINING
NEVER STOPS

We conduct compliance training for all employees to preventthe occurrence of non-conforming product issues and othercompliance problems that could damage the trust of stakeholders.
In fiscal 2019, we explained the background of the problem
and preventive measures to prevent recurrence of thenonconforming product problem, and in fiscal 2020, wetrained all our employees on the new Code of Business
Ethics and related Policies.

CORPORATEGOVERNANCE

Tsubaki Nakashima is proactive in making sure that personal
relationships and activities do not interfere with the ability to makeobjective business decisions on behalf of Tsubaki Nakashima.
The Company knows and avoids the kinds of situations that can present

CONFLICTS
of interest
34

Engaging
Third
PartiesWorking
with
Suppliers

Personal
Relationships
and Family
Members

We at Tsubaki Nakashima are acting to protect the personal data of
our Customers, Business Partners, and Employees to reward theirtrust and fulfill our social responsibility. The Data Protection
Policy states the rules applicable in all the Countries where we
operate, and Individual Group companies are not entitled toadopt regulations that deviate from it. Every Unit must identify
all applicable International (Regional, National Regulations,
CodesandLaws,e.g.GDPRinEurope,ActonProtectionofPersonal
Information (APPI) in Japan, Data Protection Laws in USA, etc.),with which it must comply. The Data Protection Policy extends
to all processing of personal data. In countries where the data oflegal entities is protected to the same extent as personal data,
the Data Protection Policy applies equally to data of legal entities.

PERSONAL DATA
protection
SPECIFIC
POLICIES

Our Tracking Regulations’ Policy supports Tsubaki Nakashimapractice to participate in relevant international and community activities and in
the development of responsible legislation, regulations, standards and technology.
And, at the same time, it demands to every organization to apply the Corporate
process to ensure that the information regarding Laws and Regulations
is accurate and received in a timely manner, and for understanding
the applicability of International, Regional, National,
Company and other applicable requirementsin the specific organizational environment,
as well as authorizations, permits, licenses
needed to operate the Organization in compliance with Laws and Regulations, keeping track of them.

LAW
and regulation

PROTECT
well being

This policy sets additional expected standard of behavior
for team members and all stakeholders while at work, helping all
the employees to comply with applicable laws and regulations,
guiding the decision-making process, reinforcing the commitment
to impeccable character. It includes requirements driven by law,and requirements driven by Tsubaki Nakashima Code of Business
Ethics, philosophy, and culture and by Tsubaki Nakashima
management statements. As part of the Tsubaki Nakashima team,each employee takes care of himself/herself and eachother. Tsubaki Nakashima promotes safety, health, and social
responsibilities because people matter – not just to the Company,
but to fellow team members, friends, families, and communities.

35

Tsubaki Nakashima values the powerof Collective know-how. The Company grows the business andimproves the work environment by building positive and enduring relationships.
In specific, the policy determines the general rules in terms of Diversity, Inclusion andOpportunity, and Harassment-free Workplace.

createPOSITIVE
relationships

36

LABOUR
standards

Tsubaki Nakashima (TN) is an organization committed to therespect of human rights and upholding labour standards.
This respect and commitment are central to the success of
TN entities in all the communities in which it operates.Labour
Standards Policy is aligned with the principles establishedwithin the Universal Declaration of Human Rights and incombination with TN Managerial Statement and Codeof Business Ethics, reinforces the commitment to ensuring
all internal and external stakeholders are treated with dignity
and respect. As part of due diligence when entering acquisitions,new operations and other contractual arrangements,
Tsubaki Nakashima seeks to abide by the requirements
set out in this document to ensure any labour standards
and human rights issues are identified and assessed.
The purpose of this Policy is to set out the responsibilities
of Tsubaki Nakashima, its Employees and Associates inobserving and upholding our principles with respect tolabour standards and human rights.

SPECIFIC
POLICIES!!

Tsubaki Nakashima does not accept child labour.

Child labour is defined as work undertaken by a child which
the child is legally prohibited from undertaking or is likely to be harmful
to the Child’s health or physical, mental, spiritual, moral, or social development,
or interferes with a Child’s education.
Tsubaki Nakashima supports the United Nations and ILO conventions specifying

CHILD
labourTsubakiNakashima
does notacceptchildlabour!

All actions concerning
the child shall takefull accountof his or her
best interests

The right of the child to beprotected from economic
exploitation, from performing
any work that is likely to be
hazardous or interfereswith the child’s education,or is harmful to a child’s
health or physical, mental,
spiritual, moral or social
development.
37

Tsubaki Nakashima recruits, develops, and promotes personnel
on the basis of merit. We want to maintain a work environment free fromdiscrimination and harassment. Equal opportunity means treating individuals
fairly and without discrimination in all aspects of their employment. Discriminationmeans treating an individual less favorably than others on grounds prohibited by law.
Grounds of unlawful discrimination include:

EQUAL
opportunities

GenderParental
StatusMaritalStatusPolitical
beliefs
or activity

Religious
beliefs
or activity

SexualOrientation

FamilyResponsibilities

Age

Criminal
recordDisability
Impairment

Ethnicity

INCLUSION
and diversity

Freedomofassociation
39

38

Physicalfeatures

Victimization

Conflictof interest

SPECIFIC
POLICIES

Tsubaki Nakashima is committed to supporting the values of diversity
and inclusion through the adoption of corporate, organizational andmanagement processes based on respect for people’s rights and freedom. To
this end, the path taken aims to develop the ways in which diversity issues
are addressed, moving from an approach designed to safeguard andintegrate diversity, to a proactive strategy to overcome cultural stereotypes
and to identify and address those factors that prevent inclusion in theworkplace. The company operates impartially and does not tolerate any formof direct or indirect discrimination. It also promotes conditions that enable
the elimination of cultural, organizational and material barriers that limit
people’s full participation and full potential within the organization. TN
safeguards the value of its staff and promotes the protection of their
psychophysical, moral and cultural integrity through working conditions
that respect individual dignity and rules of conduct.

Tsubaki Nakashima supports a person’s right to cometogether with others to promote, pursue, and defend common
interests. Our company strives to provide employees with a pay and benefits
package in line with market practices and adapted to their skillset and performance.
Wages and benefits are equal or superior to the applicable minimum legal and regulatory
requirements and shall comply with negotiated agreements with legally established trade unions.

FREEDOM
WORKINGof association
conditions
BARGAINING
40

The Tsubaki Group’s regional Presidents and Global functional
Managers in charge of manufacturing, quality, sales, technology,
finance, and human resources are responsible for analyzing andassessing the individual risks inherent in our business activities.
When a significant risk is identified, the Risk Management Committee(RMC) is convened to review the risk analysis and assessment conductedin each region and report the results to the Management Committee(MC), the executive body. In addition to discussing and deciding
how to respond to such risks, the MC will promptly report to
the Board of Directors and take countermeasures in the event thata serious loss is expected to occur.

RISK
management

SPECIFIC
POLICIES

One of the objectives of Tsubaki Nakashima’s activity is to make theenvironments cleaner, more efficient and above all safe and we canconfigure this in the prevention and adoption of environmentally friendly
techniques and sustainable approaches.
Under the direction of the CEO and Management Committee, the Tsubaki Nakashima’s
CSO - Director in charge of Corporate Planning, Business Strategy, and M&A - is responsible
for promoting ESG, with the support of the Investor Relation Department.
CHRO – Director of Human Resources, Compliance and Sustainability – created the
management System and the Global Sustainability System in order to guide the direction of global
activities, in the right way. Our Global Operations’ Director manages specific Sustainability projects(e.g. Waste reduction, Energy). The established direction is incorporated into specific activities at the
Plant level through each Regional President.

One Team

ENVIRONMENT
and regulation
SOCIAL&GOVERNANCE
promotion
structure

41

The Company Management has
decided to draft the document integrating the
GRI Standard with the principles of Integrated
reporting in order to provide the widest information
to its Stakeholders and with the aim of highlighting
the creation of value over time. The integrated report is a
new approach to corporate reporting that aims to emphasize
the link between strategy, financial performance and thesocial context in which the company operates.The objective of
the Framework is to define the guiding principles and contents
that are part of an integrated report and the main purpose is to42

SWOT Analysis started from thealignment between Managerial Statements, Strategy andSustainability (ESG) Targets,with the ZERO Approach.
Marketoriented actions

ComplianceContribution to theglobal environment

A BETTERCORPORATE CITIZEN
Continuous
strenghteningof the company

THE
HIGHESTQCDSFURTHERPROFITABLEGROWTHA TRULY GLOBALCOMPANYfor customers’
benefitContinuous
innovation andkaizan(continuous
improvement)

TEAMWORK

Global reach / Local depthCommunication withand respect for each other

Adaptation
to global standard

Mutual trustwith business partners

TSUBAKINAKASHIMACONTEXTANALYSIS
demonstrate to financial capital providers, through an improvementin the quality of information, how an organization is able to create
value over time. The company has made an objective analysis of the

SUSTAINABILITY(ESG)
context, concretizing it in a SWOT analysis, a strategicplanningtoolusedtoevaluatethestrengths(Strengths)theweaknesses (Weaknesses), the opportunities (Opportunities)
and the threats (Threats) that characterize a company
to facilitate decision-making processes and achievebusiness objectives, concerning Sustainability(Environment, Social, Governance).

Safe and healthy plants (Zeroaccidents and Zero occupational
illnesses – Zero inequalities)
and low environmental impact (Zero wastes) - Improving
Energyefficiency
andconsumption; Common system,
platform and standards to manage
and sustain Sustainability(Zero lack of knowledge), incompliance with the laws andobligations.

SWOT

SWOT

43

HELPFUL
EXTERNAL
ORIGIN

44

Potential “green” incentives in almost all the Countries
Sustainability is perceived as an asset
Automation and Artificial Intelligence
could decrease the risk of injuries
Common International Standards
and local Regulations
founded on them

O

SWOT

Lack of common standards for the Auditors

W

INTERNAL
ORIGINS

Some aged plants and machines, increasing
the safety risks and use of energy, as well as
the potential environmental impacts
Energy not always perceived as an opportunity
Cultural and Linguistic barriersCommon electronic platform where to share
documents, best practices, etc.
not properly working

HARMFUL
Pandemic issue and Economic recession is slowing down
the implementation of Sustainability projects
Higher cost of energy
Higher cost of waste disposal, like grinding sludge

T

ANALYSISCORPORATE LEVEL

45

EXTERNAL
ORIGININTERNAL
ORIGIN

Sustainability considered as a strategic asset and included in
the Managerial Statements (Better Environment management
will decrease the production of wastes and costs Better Energy
management will decrease the consumption and costs
Multicultural Company and global/multiethnic/functional
Organization - Mutual support between Regions/Plants
Process to standardize systems, materials,
equipments, machines, manufacturing flow, etc.
Low rate of injuries and zero occupational illnesses
Global Sustainability System and Minimum Technical Standards
Many of the plants already have at least one ISO Certification
Energy assessment done in many plants
and Energy Project is a crucial item of Monozukuri

The Group places great importance on maintaining andbuilding relationships of trust with its stakeholders based on long-term
collaboration. Tsubaki Nakashima interacts with numerous subjects, worldwide;
the Company bases its relationships on solid pillars such as respect for people, safety
at work, the quality of services offered, attention to the environment, transparency inrelationships and Social Responsibility.
The stakeholder engagement activity made it possible to define the reporting perimeter andto build a stakeholder mapping that identifies the subjects linked to the company by relationshipsof different nature and in turn inserted in wider networks of interrelations.
Tsubaki Nakashima identifies its stakeholders by dividing them into two main categories: internal andexternal stakeholders, following the ISO requirements.

OUR STAKEHOLDERS
46

INTERNALStakeholders

are represented not only by shareholders and company management, but above all by
employees and collaborators, the heart of the company, who are in direct contact withcustomers every day, representing Tsubaki Nakashima. The company strongly believes in the
integration and concrete motivation of its employees by stimulating training at 360° and inparticular on fundamental issues such as safety at work and the principles established by the highest
ethic’s standards. Shareholders and company management guide the strategy and operations of theCompany in compliance with and sharing ethical and moral principles.

EXTERNALStakeholders
include suppliers and contractors, who are selected through a precise
evaluation system, as well as based on compliance with the principles
governed by our QMS and GSS: being a supplier of Tsubaki Nakashimameans committing to extend the same ethical principles that guide thecompany also to its supply chain and along the entire value chain.
A relevant external stakeholder is the Customers.

Both categories of stakeholders (internal and external) have legitimate
expectations regarding the work of Tsubaki Nakashima and, in relation
to the most relevant stakeholders, the possibility of expressing opinions
and suggestions, both in clear and anonymous (i.e. Surveys), through various
sharing tools made available by the company and with periodic meetings.
Thanks to these listening processes, the company has the opportunity tounderstand their needs and evaluate them to improve its activities and its
impact on them. In general, stakeholder involvement takes place in compliancewith the principle of inclusiveness, through which Tsubaki Nakashima undertakes
to encourage the active participation of all internal stakeholders in corporate
life and strategic decisions.

CONTEXTANALYSIS

47

MEDICAL PRODUCTS

SPECIALLY MANUFACTUREDPRODUCTSPRECISION
CERAMIC BALLSPRECISIONSTEEL BALLS

48

BALL SCREWS

WIND TUNNELGLASS BALLSSOLIDPLASTIC BALLSCMM REFERENCE
BALLS

49

PRODUCTSFOR ELECTRIC
POWER INDUSTRYBESPOKETOOLING FEATURES
TO DESIGNPRECISION ROLLERSAND STAMPINGSTSUBAKINAKASHIMALARGE SCALEBLOWERS

YS
A
W
BALL

PRODUCTSUNIVERSEOTHERS

50

TSUBAKINAKASHIMAPRODUCTSPRECISIONSTEEL BALLSPRECISION
CERAMIC BALLS

Bearing Steel Balls, Stainless Steel Balls, Carbon
Steel Balls, Chrome Steel, Nickel Chrome
Molybdenum Steel, Tungsten Carbide Alloy Balls,
Non-ferrous Metal Balls are used in a variety
of products for everyday use – these include
home electronics such as air conditioners,
refrigerators, and vacuum cleaners to ensure
a quiet operation. The high precision of our
precision components ensures the highest
durability and quality to meet our diverse
client’s needs.

Fine ceramics are light and tough. In addition to having excellent
insulating properties, they have excellent wear resistance, heat resistanceand corrosion resistance. Taking advantage of these characteristics,
our ceramic balls are used in bearings for spindle motors of machine
tools, turbochargers, and dental drills that rotate at high speeds.
Ceramic balls are also used as check balls in metering pumps for fluid
control in water treatment and food applications. Our ceramic balls areindispensable for creating the future for environmentally friendly applications
such as wind power generators, electric vehicles, and semiconductor
manufacturing equipment that supports 5G technology.

PRECISIONROLLERSAND STAMPINGS

Our industry position as the largest independent manufacturer of precision rollers allows TN theflexibility to offer products matching a wide range of customer specifications. Our roller
technologies have been proven to create lower friction, bear heavier loads, and withstandthe most severe conditions, ensuring that bearings containing TN rollers have the longest
possible service life. Our fully automated, deep-drawn transfer and die pressing technology
allows us to manufacture a wide variety of precision sheet metal parts, including tapered
and spherical roller cages as well as other products for automotive and industrial
markets.This process delivers high precision and improves overall
product performance.

51

SOLID
PLASTIC BALLS

52

TSUBAKINAKASHIMAPRODUCTS

IV therapy check valves
High speed dental drills
Xray markers
Surgical instruments

We specialize in high quality, price competitive, injection
molding of plastic tubes, petri dishes and other plastic
disposables. We employ state of the art injection molding and clean room technology with advanced skills where
tight tolerance, special color, clarity or light transmittance andlot-to-lot integrity are crucial. Some specialty injection molded
plastic parts can be manufactured in our Class 8 Compliant,
ISO 13485:2016 Certified, FDA registered clean room.

MEDICAL PRODUCTS
FDA Registered for Contract Cleanroom Injection Molding
Example of applications
Endoscopic irrigation
and washing

Medical tester
Analysis and diagnostics
Airways and respiratory

Disinfection machines
Haemodyalisis
Blood processing equipment
Saline washing and cooling
Tumour ablation

Solid plastic balls are a light-weight alternative to metalballs. Less than 1/6th the weight of metal and the weightof aluminum, advances in plastic material formulations
and thermoplastic products can even outperform
metal in certain applications. The balls can be used inapplications requiring light weight, noise reduction,
corrosion resistance or color. Common applications
are lightweight bearings, check valves, and plug balls.

53

SPECIALLY MANUFACTUREDPRODUCTS

Alongside our standard selection of precision balls,
our Spheric Trafalgar brand can supply a wide rangeof specially manufactured metrology productsthat meet the requirements of demanding
engineers across all sectors of industry.

54

TSUBAKINAKASHIMAPRODUCTS

GLASS
BALLS
BALL
SCREWSUKAS Calibration - ourlaboratory can supply UKAS
certified measurement
certificates for balls from
1mm up to 60mm and offer ameasurement uncertainty as
accurate as ±0.00025mm.

Tooling Balls for general
purpose use in Jigs andfixtures, Spherical Plug
Gauges for gauging internalbores, Specialty Tungsten
Carbide ball production.

CMM
REFERENCE
BALLS

for setting precision
measuring equipment

BESPOKETOOLINGFEATURES
to design

BALL
WAYS

We have established an integrated
manufacturing system startingwith the original material.
By applying our production
technologies of the steel bearing
balls into this system, we canoffer you high-quality products
at a low price.
We have an unparalleled lineup of small
to large products, heavy load products,
and high precision rolled products.
These are often used in machine tools,
electric injection molding machines,
semiconductor manufacturing equipment,
industrial robots, and advanced
medical equipment.
The features of this product are 4 equalload capacities in 4 directions, highmoment load capacity, tube type, while
also providing long life, high rigidity,
and high-speed running. This producthas an established reputation for easeof centering in machinery. Like Ball
Screws, Ball Ways are used in a wide
range of industries.

55

LARGE SCALEBLOWERS56

TSUBAKINAKASHIMAPRODUCTS

The iron and steel industry requires
stable operation under harsh conditionsof high temperature and high pressure.
We provide safe and reliable productsthat are resistant to wear and corrosion,high temperature and special gases (e.g.
COG, LDG, BFG). We also provide postdelivery support to meet individual
customer needs. Typical applications
are: IDF of OG, COG booster fan,steam
exhaust fan, dust corrector fan, direct
dust collection fan, hydrochloric acidrecovery fan, N2 purge fan, preheating
fan, BUF, coal exhaust machine.

WIND
TUNNEL

Electricity demands increase year after year. Stable power
supplies will become even more important as global power
requirements expand. Our proven track record of products
and services within nuclear and thermal power plants
demonstrate our commitment to our customers
meeting those rigorous demands.

OTHERS

Reliable ventilation is criticalin manufacturing applications that include steel andchemical processing as wellas subways and road tunnels.
Tsubaki Nakashima’s high-quality blowers deliver the durability and safety demandedin these environments. Our
meticulous design and consistent support allow customers
to maximize their equipment
for enduring performance.

Wind tunnels provide valuable flow
data that continue to improve upon
designs of automobiles, motorcycles,
sportwear, and buildings. Tsubaki
Nakashima blowers provide consistentand accurate wind flow that support
the evolution of this technology.

FDF
The vanes of the turbo type
fan mimic the shape of an
airplane wing. This fan has been
proven to have the highest
efficiency with minimal noise
among all centrifugal blowers.
It has an Inlet Guide Vane which
controls the flow rate of FDF
and provides power savings.

INDUSTRY(stainless steel)Multi-stage impeller is a centrifugal fan covering
a wide range of applications such as a blower.

FAN FOR METRO
The vanes of the turbo type fans follow the designof an airplane wings. This fan has been provento have the highest efficiency with minimal noise
among all centrifugal blowers.

MULTI-STAGE
IMPELLER
Multi-stage impeller is a centrifugal fan covering
a wide range of blower applications.

PRODUCTS IDF
FOR ELECTRIC
POWER

HIGH PRESSURE
BLOWER

Ceramic or hardened plates
can be attached to the impeller
surfaces to prepare the productfor use in an abrasive
environment.

PAF
We have developed an originalhigh efficiency type turbo fanthat matches the efficiency ofan airfoil fan. It is perfect for
cutting down the initial andthe running costs.

57

APPLICATIONS

58

59

Tsubaki Nakashima
Quality Management System and Quality
Organizations are designed to achieve customer satisfaction,
one of the core commitments included in our Corporate managerial
Statements

TO SUPPORTTHE ORGANIZATION TO

Our Quality Mission is

ESTABLISH
ANDIMPROVE
EFFECTIVEQUALITYQUALITY
FRAMEWORKS
AND TECHNICAL KNOWLEDGE
WITH THE GOAL OF
FACILITATINGTHE OVERALL SUCCESSOF OUR INTERNALAND EXTERNALCLIENTS61

QUALITY PERFORMANCE

Our Quality Management System uses theRisk-Based Thinking approach:

Supplier Quality Manual to help to consolidate

CONTINUOUS
IMPROVEMENTa stronger Supplier base

The Internal Global Audit Team competencies
have been strengthened by specific training,
working on the development of tools able toincrease the effectiveness and technologicalcontent of the process
62

Q

Q
QUALITY
The Global Quality scorecard has been developed to make the data
available and easily monitorable+

In terms of products, support continued to the
local Quality department for Claims management and custom type-approval audits, continuing the development of the APQP methodology (Advance Product Quality Planning).
Investments were also made in Digital Quality
development.

ATPZERO DEFECT APPROACHQUALITY

COMMONQMS

63

In accordance with our Quality Policy, we have establisheda system that enables us to consistently manufacture high-quality
products that meet Customers’ expectations at all our sites. In 2019, we
renewed our Quality Management System and established a global QMS, worldwide.
This allows us to unify the quality of products manufactured at all our sites. As of the end of
March 2020, 19 of our 22 global sites had obtained ISO 9001 certification and 17 the
IATF 16949 certification. As KPIs for maintaining and improving quality globally, we have set targets
for the number of complaints, internal defect rate, and CNQ (cost related to quality, including complainthandling), which are linked to improvement activities. Internal audits and audits based on internal
audit guidelines are also conducted at each site as quality-related audits. In both audits, we improve
the accuracy of the audit by checking quality from the three aspects of quality, products, and systems.
As of the end of March 2020, we had 108 employees with auditor qualifications globally and 8 in Japan.

64

Q

S SPECIFICM MEASURABLE
A ACHIEVABLER RELEVANT
T TIMEQMS

Be specific in whatever we control, aiming to maintain and improve
our leading position in the manufacturing of high quality
and high precision components.

Our process and performance must be measured, as the customers’
specification and performance evaluations are measurable.
Achievable and clearly defined goals are the key for driving
continuous improvement in the company’s overall quality
and service performance.
Focus and drive actions on relevant root causes to exceed
to our customers’ and stakeholders’ expectations.
Establish and deliver on clear improvement and businessdevelopment project timing expectations to create trustand enhance our partnership with our customers and stakeholders.

QUALITY
POLICY65

Development of in-house manufacturing equipment

Due to the simple spherical shape of precision balls, the main product ofour group, process design is more important than product design in quality control.
Our group manufactures many of the machines used in manufacturing in-house, andsome of the inspection equipment is also manufactured in-house to match the manufacturingmachines and product shapes. We use commercially available acoustic measuring instruments
and devices for measuring loads and dimensions in order to meet external standards, but we also
manufacture parts that cannot be handled by commercially available products, such as the inspectionof the appearance of spheres, and customize them for more efficient measurement. We also perform
appropriate maintenance and checks on inspection equipment to achieve higher quality control.

66

Q

QUALITYinitiatives
CONTROL

Tracking system

Our group has introduced a tracking system to check all manufacturing processes.
This prevents mistakes such as mixing the wrong raw materials or skipping processes.
In addition, the system automatically outputs data on which process the product has gone
through and which inspection it has undergone, making it possible to go back and check thedetails of the process when there is an inquiry from the customer after shipment. In order toreduce human error to zero, we are aiming to automatically capture all inspection data, and plan toachieve automatic determination of all inspection data by 2022.

Identification of Critical Processes

In the precision ball manufacturing process, we have identified processes that are particularly prone
to quality problems as critical processes, and are working to strengthen quality monitoring andprocess improvement. In the final cleaning and packaging processes, we are strengthening
the management of each treatment solution and preventing insufficient application ofanti-corrosion oil with an automatic alarm system, installing automatic abnormality
monitoring equipment in the pressing process, and inspecting the management
status of the heat treatment process based on CQI9. With regard to raw materials,
in addition to encouraging raw material manufacturers to conduct their own
audits and strengthen their audits, we audit raw material manufacturers and checkthe quality of materials when we receive them.

Process for responding to quality complaints

In the event of a quality problem, including a quality claim, we have our own risk
management system, and each site first conducts a risk assessment. As a resultof the risk assessment, if a certain standard is exceeded, the matter is reported
to the Risk Management Committee for early resolution of the quality problem.
This process is shared globally. In fiscal 2020, we responded to 47 quality
complaints at our major sites, and none were severe enough to be reported
to the Risk Management Committee.

QUALITY

67

The Global Quality organization is focused not only on
supporting the manufacture of precision, zero defect product, but more
importantly on ensuring our Customers’ needs are exceeded.
As a truly global manufacturer of a wide rangeof precision components of our resources and expertise are extensive.
TN Global Quality and Central Lab are focusedon the following main development activities,
with the close collaboration of Customers:

68

GLOBALQUALITY
and CENTRAL LAB
ORGANIZATIONSTANDARDIZATIONHIGHPERFORMANCELOW ALLOYSTEELFAILUREANALYSISSTEEL
BENCHMARK69

CERAMIC
MATERIALS

LOW NOISEPRODUCTMANUFACTURING PROCESSQUALITY

The impact of the spread of the new coronavirus
infection caused a sharp and significant slowdown in the global
economy, and in 2020, global automobile production, machine tool
orders, and other factors declined significantly. Under these circumstances,
Tsubaki Nakashima’s top priority is to ensure the health and safety of our employees,
customers, and other stakeholders and to try to slow the spread of infectionin accordance with local and national government policies. Although there weretimes and regions where we had to temporarily suspend or reduce our operations,
we aimed to ensure a stable supply by utilizing our global production system, which
is one of the strengths of the Group, and by complementing each other across regions.

70

GUIDELINES[ MARCH 2020 ][ UPDATED IN SEPTEMBER 2020 ]RESPONSE
to theCORONAVIRUS
PANDEMIC

These guidelines aim to help our Tsubaki-Nakashima entities and plants (“Employer”)
and our workers to stay safe and healthy in a working environment, that has changed
significantly because of the COVID-19 pandemic. They give advice on:• risk assessment and appropriate measures• minimizing exposure to COVID-19• resuming work after a period of closure• managing workers working from home
• involving workers• taking care of workers who have been ill

Immediately after infections from a new coronavirus became news, Tsubaki Nakashima
invoked the Risk Management Committee and formulated the basic response Covid-19
Protocol. Since then, we have been gathering all available information and implementing
measures to combat the spread of COVID-19. Starting from March 2020, daily meetings with all
the plants have been organized to prevent, intercept, and manage the infections spreading,to share best practices and solidarity. Tsubaki Nakashima advises employees to takesteps to protect themselves and others, such as washing their hands, covering their cough,and performing health checks before coming to work. Employees are instructed tostay home if they have a fever or cold symptoms. Measures are in place in officebuildings, meeting rooms, and employee cafeterias to enable people to maintainsocial distance. Seating has been rearranged, restrictions have been placed on
meeting room capacity, and employees are encouraged to telecommute. In
addition, business travel is restricted or prohibited, depending on the region
and infections, so employees are using alternative means such as virtual
meetings via video conferencing and teleconferencing.

And finally, we implemented the new
ISO/PAS 45005:2020 - Occupational
health and safety management
General guidelines for safe working
during the COVID-19 pandemic

COVID-19

71

The Risk Management Committee(s) resolved tocontinue to monitor the state of infections around the globe
while implementing improvements and to put preparations in place
to respond immediately in the event of a worsening of the crisis. Tsubaki
Nakashima’s production and sales sites were hamstrung by COVID-19, forsome months but always ensuring the best possible solutions for its Customers.
In China, production gradually recovered from late February as restrictions on
movement were relaxed. Production in the other regions normalized at the end ofJune, but we need to continue to pay close attention to the situation.

Tsubaki Nakashima’s organizations and single employees
around the world took actions to help contain the effects of COVID-19
in their communities, providing masks and supporting employees andfamilies affected by the virus with subsidies, logistical support, psychologicalassistance, as well as local communities - especially schools - with donationsof computer equipment for both face-to-face and remote lessons;

22 PCs have been provided for a high school in Bosnia
and 20 tablets and 2 PCs for a middle school in Italy.

73

72

CORPORATECITIZENSRESPONSE
to theCORONAVIRUS
PANDEMIC

COVID-19

The Group operates, trains, and secures human resources
based on unified rules, with the aim of ensuring that all employees working
around the world continue to move toward the future as a single One Team. Our
Group has developed through the acquisition of companies in Japan and overseas. In
particular, the corporate culture of the PBC division of NN Corporation of the United States,
which joined the Group in 2017, differed greatly from the culture that had been nurtured
mainly at Tsubaki Nakashima’s headquarters in Japan, and it became necessary to develop anddeploy unified rules, corporate culture, and organizational systems for the entire Group. As a resultof subsequent efforts, we formulated unified rules (One Team Management System) based on theconcept of “One Management + One Operation = One Team” and One Tsubaki Nakashima culture thatembraces and harmonizes differences in race, language, and culture. In addition, based on our One TeamManagement System, we respect diversity and promote the creation of workplaces that realize the Vision Zero.

74

OUR COMMITMENT
TO PEOPLE
One Management
One Operation =+One Team

INCLUSIONAND DIVERSITY

45

Respect for diversity is a cornerstone of Tsubaki
Nakashima Management Philosophy,and our personnel policies
reflect it. Diversity is the inclusion of individuals of different genders,
national origins, religions, regions, educations, social statuses, and LGBT,
regardless of whether these traits are innate or acquired, visible, or invisible.
The Group has manufacturing bases not only in Japan, but also in the United States,
Italy, Poland, Slovakia, the Netherlands, Bosnia, China, Thailand, India, and Taiwan,
and in each of these countries, local employees take the lead in conducting activities.
As a Corporate Group with global operations, we aim to utilize diverse values in ourbusiness, and promote diversity by appointing suitable personnel to Executive Officers
regardless of nationality, promoting the activities of women, and employing people withdisabilities. In our Group we have 30 different nationalities; Diversity is key, always.
For example, in the Management Committee (7 members), 4 different nationalities are represented
With regard to the promotion of women’s activities, we have formulated numerical targets
and action plans, and are moving forward with our efforts. In order to balance work withchildbirth and childcare, we are expanding our childcare leave system, raising the age of children
76 who can take advantage of shortened working hours related to childcare, staggered work
hours, telework, and a half-day paid leave system to create a comfortable working environment,
according to the local Laws and Regulations.
With regard to employment of people with disabilities, we are working with local government
agencies to recruit and support people with disabilities; the Japanese domestic employment
rate for people with disabilities in FY2020 is 1.82%, and in Japan we are currently working
with specialized organizations to expand the range of jobs and increase employment and willcontinue to do so in the future. In the rest of the world, the rate of people with disabilities
varies from 1% to 2% in China, Italy, 4% in Slovakia and 8% in Bosnia and Poland.

INCLUSIONAND DIVERSITY

77

GLOBAL MEETINGS

Tsubaki Nakashima holds a variety of (virtual) meetings and seminars forrepresentatives from our global sites. Some are function specific, for areas such as
manufacturing, quality, engineering, sales, finance and accounting, HR, sustainability.
Others are for global projects involving matters such as Sustainability systems, Quality
Management System, Sustainability Monozukuri Projects and so on. Every week, at least once,
there were virtual meetings with all establishments to discuss the evolution of the pandemic,
countermeasures, and to assist colleagues.

RECRUITMENT

The Group is committed to hiring and training appropriate human resources in order to continue
manufacturing essential products for the world and to achieve further corporate growth. As a rule,
recruitment activities are conducted at each site, with the Tsubaki Nakashima Head Office involved
in important management positions. Based on our policy of “zero inequality,” we believe that diversity is agreat value and, consequently, we do not discriminate on the basis of gender or other factors when hiring.

78

PEOPLE DEVELOPMENT

For the development of our People, we have established an education and training system and provide
opportunities for all employees to acquire the knowledge, skills, and techniques necessary to perform theirduties accurately and promptly, both inside and outside the workplace. Tsubaki Nakashima Academy (TNAcademy) aims to enhance the customer value we create.
To this end, we teach our Managers andTalents basic technology and skills andhave them experience Monozukuri(the art and science of manufacturing) by performing specific manufacturingand managerial tasks step by step. This helps them tackle jobs from different
angles. Employees also learn by mastering essential skills for making manufacturing
more efficient with the#MOTUS 4.0 APPROACHOUR COMMITMENT
TO PEOPLE

TN ACADEMY

We believe that the Value of our Managers should be the ratio between Competencies,
Humility and Ability to operate. However only our Attitude can be the right multiplierto achieve or not the success.

V = (Ch + A) x A
This is the reason why Tsubaki Nakashima decided to launch an ambitious a Knowledge Platform to ensure
a common technical and managerial knowledge; in the first round we involved Plant managers, who play
an important role in the execution of business at each site, and Talented Employees (selected after a severe
process and specific Organizational Competency Assessments), with on line and “in presence “courses
concerning Plant Management, People management, Ethics, Safety and Health, Environment, Quality
and basic Finance. Each plant designs a people Development plan at all the levels, in alignmentswith our Quality Management System and Global Sustainability System.

100% OF OUR EMPLOYEES

took part in training courses, during 2020,
for an average of more than 40 hours per person,
60% of which were dedicated to Compliance, Health,
Safety and Environment.

79

IN 2020 AN IMPORTANT PROJECTOFRESEARCHANDINNOVATIONOFPRODUCTS
AND PROCESSES AND OF PREPARATION FOR THE
INSERTION OF NEW ENGINEERS BEGAN, INVOLVINGTHEUNIVERSITYOFTURIN(ITALY)ANDDUBLIN(IRELAND)
AND 8 STUDENTS.

80

THE SEARCH FOR NEW YOUNG TALENTS,
PARTICULARLY IN THE TECHNICAL AREA, IS
EXTENSIVE WORLDWIDE IN TSUBAKI NAKASHIMA.
IN THE PICTURE BELOW (RIGHT), WE SEE TWO NEWYOUNG ENGINEERS JOINING OUR GLOBAL CERAMIC
BUSINESS ORGANIZATION.

NEWTALENTS81

OUR COMMITMENT
TO PEOPLE

TRAINING
NEW TALENTS

LEADING BY EXAMPLE

Respect and Honest Communication

Integrity

Courage

Customer Focus

EVALUATIONSYSTEM82

The criteria for evaluating
employees who work a full
day and employees who work
shorter hours are identical.
This was done to ensure a levelplaying field when it comes toadvancement and promotions.
Employees
areevaluated(Performance Evaluation andCompetency Assessment process)based on their achievementswith respect to goals (Goals
and Objectives Process) andbased on their behaviours andcompetences, with respect
to the 15 Tsubaki Nakashima
Competencies, divided in 5
categories linked to theManagerial Statements.

Continuous Innovation

DELIVERY
Results Orientation
Driving Change

Influence
Vision, purpose
and relationships

Strategic Thinking

GROWTHFROMMANAGEMENT
PRINCIPLESTO MANAGEMENTCOMPETENCIES
Value-Based
Decision Making

INSPIRATIONPEOPLE Cultural Sensitivity

Comfort around authority

People Management

OUR COMMITMENT
TO PEOPLE

Conflict Management

83

GLOBAL TALENT

Tsubaki Nakashima has sites around the world to accurately identify and swiftlyand flexibly meet the changing needs of customers at different times and in different
regions. The TN Group currently employs about 3,500 people. A high-performing,
diverseworkforceisessentialforachievingverticalintegration,makingitvitalforouroperations
divisions in Japan and companies overseas to be on the same page in terms of business vision andpolicies. Organizational Capability Assessment andSuccession Planning processaretwoprograms
supporting the identification of Talents to be trained and accompanied to the next steps of theircareer in our Company.

SELECTING MANAGERS,DIRECTORS AND EXECUTIVES

Tsubaki Nakashima seeks to put itself in the best position to achieve the Mid-Term
Goals by reviewing organizations, roles, and human resources from a global
perspective and making adaptations that best serve our business strategies
and the ever-changing business environment. The company specifies
84 the roles and requirements for key positions in the global TN Group.
It establishes succession plans and has systems in place to ensure thatthe best people for these positions are selected without regard
to consideration such as age, gender, and nationality. In each entity,
personnel reviews (Organizational Competency Assessment
and Performance Evaluation) that focus primarily on managers
in each business and function are conducted to identify candidates
for future management positions. Succession plans are drawn up,
and training, both internal and external, is provided to put
them in a position to succeed. Information about their skills
and capabilities is gathered by various means, including
360-degree evaluations, and future career path anddevelopment plans are explored.

OUR COMMITMENT
TO PEOPLE

WORKFORCE COMPOSITION
AND SERVICE PERIOD
Men represent 75% of the entire population and women 25%; Tsubaki Nakashima
is a manufacturing company, and we believe that the efforts made in Ergonomics allowed
many women and people with disabilities to join us, also in activities that were historically
performed by male personnel.
In most Plants, women play key managerial roles as managers, department heads, and supervisors.
In 2020, the Company increased the percentage of female employees by 7%.
Length of seniority depends on the plant’s age, but in general we can say that in the majority of ourfactories, turnover is not an issue and, where present, it’s not influencing the goals and targets set up.
In all the Regions, excluding China, the turnover rate is below the national average.

Average turnover rate 2020 in our plants

compared to the average of the Region/Area

25 %
20 %

85

15 %
10 %
5%
0%
Japanese
PlantsEuropean
PlantsAmericanPlantsChinesePlantsAsian
PlantsMEDIAN AGE 2020: THE MEDIAN

AGE IN OUR PLANTS GUARANTEES EXPERIENCE,KNOWLEDGE AND COMMITMENT, EVERYWHERE

86

TN China Chongqing

40

TN China Taicang

37

TN China Kunshan

37

TN Japan (Ceramic)

39

TN Japan43

TN Thailand

38

TN India37

TN Europe

45

TN Bosnia

47

TN Italy51

TN Netherlands

49

TN Poland

35

TN Slovakia

41

TN America Michigan

44

TN America Georgia

44

TN America M.City, Tenn.

45

TN America Erwin, Tenn.

48

OUR COMMITMENT
TO PEOPLE

Tsubaki Nakashima is serious about keeping all formsof discrimination and unfair practices out of its operations aroundthe world. This stance is reflected in our participation in the United Nations Global Compact and in the Tsubaki Nakashima Group Policies regarding
Human Rights and Labor Standards, which articulates Tsubaki Nakashima’s
strong convictions in areas such as respect for human rights, prevention of all
forms of harassment and discrimination, respect for local culture and customs,
prohibition of child and forced labor, and maintenance of positive labor-management
relations. Tsubaki Nakashima Human Resources Function, working in concert
with the HR departments of our global affiliates, guides initiatives to prevent humanrights abuses, discrimination, and unjust labor practices.
Tsubaki Nakashima has identified humanrights risks such as child labor, forcedlabor, other exploitative labor, workers’
rights, labor conditions, discrimination,and harassment as business risks.

RESPECTINGHUMAN RIGHTS

All personnel are regularly notified
of disciplinary actions and otheractions taken by the company in response to incidents of discrimination, unfair labor,harassment and other human rights abuses to prevent similar incidents in the future.

87

Since Tsubaki Nakashima’s acquisition of
PBC, the company has instituted two awards,
one for organizations, i.e., plants

Best Run Plant and Most Improved Plant
and one for Individuals and Teams

BX Award - Be eXceptional Award

88

TSUBAKINAKASHIMA

AWARDS

BE EXCEPTIONAL
AWARD

To create Profitable Growth,
the content needs to Be eXceptional

BX Award is recognizing the results of peers and colleagues in our group who have achieved excellenceand serve as inspiration and example for others. We want to inspire and celebrate positive behaviour,
results and successes. Thriving as a Company and acting as a worldwide leader in our business segment
can only be realized by showing exceptional results and world-class excellence in all the things we do,
independent from the role we fulfill in the Corporate – Region/Division – Plant or level of responsibility
we hold. Our goal is that every employee step on board and feels the spirit of being part of a winning team.

During 2020, 82 employees were honored

89

EUROPE

CHINA

16

12

GCB
90

JAPAN

AMERICA

7

4

1

NUMBEROF AWARDEDNOMINATIONSBY REGION

82

2020 BX PROGRAM SUMMARY
number of advanced nominations
number of awarded employees

12

Q1

32

17
6 8
Q2

91

40

30

6

BE EXCEPTIONAL
AWARD

Q3

11

Q4

TOTAL

TSUBAKINAKASHIMA

AWARDSTsubaki Nakashima aims to recognize and reward excellenceacross the Organization, inspiring us to be better, to think bigger andto continue to grow, profitably through 2 Awards:
The Best Run Plant Award, which recognizes the continuous pursuit of excellencein every aspect of the business including customers, employees and environment.
And the Most Improved Plant Award, which recognizes a plant’s ability to overcome
challenges and bounce back stronger, wiser and more powerful.
2020 has been a very difficult year for the whole world, for Tsubaki
Nakashima, for our People. Never as in these moments has it been and isimportant to remain united, to be even more a One Team, to demonstrateunity, commitment, courage, solidarity and vision. Great work deserves to beacknowledged and celebrated. In 2020, Tsubaki Nakashima awarded 4 factories
For the second consecutive year TJS, from Sechibaru, Japan. For the second time,
TAM from Americas Region, already awarded in 2018. And for the first time
2 Chinese Plants, the first to face the pandemic at the end of January:
TCT, Taicang and TCK, Kunshan

92

MOST
IMPROVED
PLANT
AWARD

BEST RUN
PLANT
AWARD

93

TSUBAKINAKASHIMA

AWARDSAPPROACH TO OCCUPATIONAL
SAFETY & HEALTH
Tsubaki Nakashima believes thatproviding and maintaining a safe and healthy work environment
and promoting physical and mental well-being
are the foundation of a healthy company.

Accordingly, understanding that safety and health are the lifeblood of the company, we haveinstituted safety and health systems and activities at our sites around the world, so that our employees
and partners can enjoy working as part of a team in a healthy environment and in the knowledge that they
are safe and secure.

94

OCCUPATIONAL
SAFETY & HEALTHOUR COMMITMENT
TO PEOPLE

The core component of this effort is the Tsubaki Nakashima Global Sustainability System, according to
the 3 most important ISO Standards of which one of them is ISO 45001 (OCCUPATIONAL HEALTH AND SAFETY),
established in FY2018 and progressively deployed in all the factories. The process will be completed in 2021.
GSS (in its SH portion) is covering safety, health, fire/disaster prevention, and facilities; this original Tsubaki
Nakashima program is based on an occupational safety and health management system that also conforms
to International Labour Organization (ILO) guidelines.
Since that program came into effect, we have enforced the GSS Manual and Procedures and manage
our workplaces with the idea that every workplace is responsible for maintaining its own safety.

GSS

95

CEO

MANAGEMENTCOMMITTEECOO
EA / JC, L&B, GCB
PRESIDENTS

STAFF SUPPORT
96

HR
AND
SUSTAINABILITY(GLOBAL/LOCAL)

DIRECTRESPONSABILITYREGIONAL / DIVISIONALPRESIDENTS
SUPPLYCHAIN(GLOBAL/LOCAL)OPERATIONS(GLOBAL)QUALITY(GLOBAL / LOCAL)FINANCEENGINEERING(GLOBAL / LOCAL) (GLOBAL / LOCAL)

MAINTENANCE(LOCAL)

PLANT MANAGERS
HEAD OF DEPARTMENTS

ACCOUNTABILITYPYRAMIDOUR COMMITMENT
TO PEOPLE

SUPERVISORS - TEAM LEADERS / SHIFT LEADERS
WORKERS97

INJURIES

23

THE FREQUENCY AND SEVERITY OF
OCCUPATIONAL ACCIDENTS IN MOST OFTSUBAKI NAKASHIMA’S PLANTS WERE

MANAGEMENTCOMMITTEEEMPLOYEESINVOLVED

1

25

WE HADONE SERIOUS
OCCUPATIONAL
ACCIDENT*
IN THE FY2020.

LOWER THAN THE
NATIONAL AVERAGE
AND IN COMPARISON TO 2019.

98

861

THERE WEREDAYS LOSTOCCUPATIONAL
ACCIDENTS
OUR COMMITMENT
TO PEOPLENOCASEOF OCCUPATIONAL DISEASESIN 2020*accidents resulting in fatalities or permanent disabilities

099Tsubaki Nakashima seeks to improve its safety and healthprograms around the world by holding regular meetings at all theorganizational levels to share information, discuss issues and opportunities toimprove to achieve ZERO Accidents and ZERO Occupational Illnesses. At theManagement Committee level, during the bi-weekly meeting, our Executives update one
another about actions being taken and discuss issues to identify opportunities for improvement.
At the Regional and operational level, Managers, Supervisors, Workers’ Representatives andSustainability Representatives also meet regularly to share information (Sustainability Committee).
According to the Global Sustainability System, anannual Management Review has been preparedin every plant and consolidated at Global Level.
Startingin2019,wehavedevelopedasystem of internal
standards, based on international technical regulations(ISO) pertaining to safety, health and the environment,
which is called Minimum Technical Standard, in order to:

SAFETYMANAGEMENTINITIATIVES

Minimum Technical Standards
is a method of establishing uniformity of minimum expectations,

OVER 43 MINIMUMTECHNICAL EHS&E STANDARDS

developed.

a Procedure containing the International Minimum Standards
a Visual example of what we are talking about

a detailed and complete training session, with pictures and drawings
each MTS has adjoining MTS Implementation Checklist

101

100
ensure all Tsubaki Nakashima
Plants run the business in amanner that results in

Injury Free, Incident Freeand no adverse
environmental impacts,
in full compliance withTN Management Principles,International Standards
and local Laws

clearly state TN Plants’obligation to developa Sustainability Plancomplying with the
Minimum TechnicalStandards

ensure all Tsubaki
Nakashima Plants

utilize consistent
EHS & Energy standards
and establish/share
Best Known Methods

OUR COMMITMENT
TO PEOPLERAISING EMPLOYEE
AWARENESS WITH ACCIDENT REPORTS

Tsubaki Nakashima analyzes all occupational injuries and accidents, identifies causes, andmakes plans for preventing similar incidents. Occupational accidents are reported in theform of Preliminary Accident Report and Root Cause Analysis which describes accident causes,
countermeasures, and actions that all sites are to take to prevent similar accidents in the future.
These reports are placed on the intranet (One Team Software) and discussed with employees.

PROFESSIONAL DEVELOPMENT
THROUGH SAFETY AND HEALTH TRAINING

Tsubaki Nakashima considers safety and health training vital for protecting employees.
The training curriculum is tailored to the position, roles, and responsibilities of employees.
Training for non-management employees focuses on practical techniques such as risk assessment
and hazard prediction. Training for managers and supervisors focuses on leadership. All Group
companies use the Training Plan to include specific ESH training. Our Chief HR Officer provided
training concerning the Global Sustainability System and Minimum Technical Requirements
to the Management Committee, Regional Presidents and all the HR & Sustainability Team members.

103

102

ENGINEERING MANUAL

In 2020 we developed a Safety Engineering Manual, a detailed guidance on how machine guardingand electrical safety is to be set up and maintained to ensure employee protection.
In 2021 the Manual will be deployed within the entire Organization.

OUR COMMITMENT
TO PEOPLE

TSUBAKI NAKASHIMA SEEKS TO
CONTRIBUTE TO THE ACHIEVEMENT OF ASUSTAINABLE SOCIETY THROUGH ITS BUSINESSACTIVITIES AND THEREBY BECOME AN INDISPENSABLE
COMPANY. FOR THIS REASON, WE ARE MEMBERS
OF NUMEROUS ASSOCIATIONS AND FOUNDATIONS,FOR INSTANCE:104

INTERNATIONALEVENTS AND
PARTICIPATION
IN EXTERNALINITIATIVES

105

AND MANY OTHERS AT LOCAL LEVEL AS WELL AS WE ENDORSE
AND TAKE PART IN NUMEROUS INTERNATIONAL CONGRESSESAND MEETING TO SHARE WHAT WE ARE DOING
AND TO LEARN FROM OTHERS.
INTERNATIONAL EVENTS
and PARTICIPATION
IN EXTERNAL INITIATIVESInternational Foundation
for the Organizational Risk Prevention
Ball characteristics impact on bearing noise generation,
Annual Tradeshow where Tsubaki Nakashima
was the bronze sponsor

Come crear una empresa multicultural,
sostenible, multinacional y multietcnica,
ORP meeting, Cartagena de India, Colombia 2020
Nuevos escenarios de la gestion de personas”,
Universitat Polytecnica de Catalunya,
Barcelona, Spain

106

American Gear
Manufactures
Association’s
Annual meeting

Canadian Manufacturing Safety Alliance of BC
International Leader Panel: COVID-19
Lessons and Growth, Make it Safe conference,
British Columbia, Canada

SHO
Portuguese Associationfor Safety and Health
How to create a Sustainable Company
Culture in a Multiethnic andMulticultural Organization
SHO Annual Meeting, Portugal

INTERNATIONAL EVENTS
and PARTICIPATION
IN EXTERNAL INITIATIVES

New perspectives on risks andopportunities of the pandemic:
Managing People during & after
COVID-19
Universitat Polytecnica
de Catalunya, Barcelona, Spain
107

International Social Security Association (ISSA) - Global Vision Zero Business Council
Physical and mental health challenges caused by the pandemic and smart ways
to promote safe and healthy behaviors, Denmark		Committed to a world of work without accidents, disease and harm
Vision Zero Business Council

International Journal of Fatigue 2020
Inﬂuence of micro inclusions in life of rolling elements:
Experimental, microstructural, analytical and numerical investigation

STAND IN EVENTS
109

108

Coordinated by International Scientific Committeeof Mechanics and Materials in Design
Safety GovernanceInstitute, Australia
Annual Meeting

Micro-inclusions and loads effect on metal fatigue: a modified life
estimation model through experimental and analytical investigation
Experimental analysis of the influence of defects in bearing
rolling balls on noise and vibrations
Quantitative comparison of amplitude and phase thermal responses
on steels and ceramics through active thermography techniques

INTERNATIONAL EVENTS
and PARTICIPATION
IN EXTERNAL INITIATIVESTN ATMOSPHERE110

OUR
ENVIRONMENT

Products provided by the Tsubaki
Nakashima Group, including
precision balls, contributeto improving the energy performanceand efficiency of final products.
For this reason, we believethat not only supplying high-quality
products, but also giving due
consideration to the environment
in the manufacturing process
will help reduce the environmental
impact of the entire value chain.

OUR COMMITMENT

Tsubaki Nakashima shall continue to improve its own organization, processes, products,
and services, aiming at reaching zero defects, zero accidents and zero environmental impact
and the improvement of the energy performance by means of:• the involvement, participation and co-responsibility of the employees and workers

representatives where they exist, collaborators and suppliers and other relevant parties with
the intention of making them aware of their individual duties, also through specific communication
initiatives, while promoting a healthy and safe behavior, and being aware of the rational use of energy• embracing the philosophy of the 5 Z’s of sustainability approach, we strive to have
Zero accidents, Zero occupational illnesses, Zero wastes, Zero inequality and Zero lack of knowledge
111• the implementation of all that is necessary to guarantee the safeguarding of the environmentand health and safety in the workplaces• the development of production processes, oriented to continuous improvement of the safety,

environmental and energy standards, to reduce and eliminate the negative impacts in an economicallyfeasible manner, by making provision for the acquisition of products and services with a view to improvethe energy and environmental performances• the commitment to preventing defects, accidents, and environmental impacts

rather than identifying them

• a constant respect for company, customer and governmental health and safety,

environmental and energy requirements• a continuous improvement of the management and performances of health and safety,
environmental and energy matters by locating the necessary resources in order reachthe set objectives and targets, using adequate monitoring and evaluation tools
All the above to satisfy the requests and expectations of our employees,
customers and shareholders in the best possible way, increasing the
reputation of the company and strengthening our leadership position.

USE OF RESOURCES
AND SUSTAINABILITY

Tsubaki Nakashima consumes resources and, in the process of conducting businessactivities across the life cycles of its products and services, emits GHGs and other emissions
to the air, land, and water. Following the specifications indicated by the ISO 14001: 2015
standard and our Global Sustainability System, we have assessed the environmental impactsof our business activities across the value chain to reduce our impacts.

LIFE CYCLE THINKING

Tsubaki-Nakashima defines an eco-considerate product as one for which environmental impacts are
considered from product conception to mission completion; that is, at every phase of the life cycle, fromdesign and manufacturing to transport, usage, and recycling.

112

THINK
CHOOSE
CREATE
Tsubaki Nakashima takes
a life-cycle thinking approach inefforts to minimize customers’
environmental impacts byproviding products that offer
environmental performance.
Almost all our products are 100%
recyclable – we use steel, plastic,
glass, ceramic, aluminum,and other material that
could have a second life.

in our Global Sustainability System,
specifically in the Minimum TechnicalStandards set up, we focus ourattention on Management of Chemical Substances in manufacturing,
replacing hazardous substances with
non-hazardous and recycle them into
the process, as much as possible

Climate Change Policy,
Life Cycle Assessments,
Pollution Prevention& Chemical Management

OUR ENVIRONMENT

113

Transport/Value Chain – Our motto is Global Reach and Local
Depth, working to serve our Customers close to their factories,
also to reduce transportation and material handling

DELIVERUSE RECYCLE
responsible
use of natural
resources,
as well as of otherresources is key,in our approach.

114& REUSE

Oil, coolants
and other
substances
are recycled as muchas possible.
All our products
are recyclable,
almost 100%

OUR ENVIRONMENT

Through the creation of eco-considerate products, we are cooperating with
our Customers to expand our environmental impact mitigation efforts beyond
Tsubaki Nakashima’s doors. The Group’s core product, precision balls, are basicallymanufactured and delivered in regions close to customers for local production for
local consumption in order to reduce emissions, as well as prevent damage andbreakage caused by long-distance transportation. Although theprocurement of raw materials, manufacturing, sales,
and after-sales service are carried out at each siteaccording to the characteristics of each productand region, important visions and directions inbusiness operations such as purchasing, quality
assurance, and technology development areformulated at the Tsubaki Nakashima
Headquarter andcommunicatedto each site.

115

TSUBAKI NAKASHIMA IS
COMMITTED TO PROTECTING THE
ENVIRONMENT (INTERNAL, EXTERNAL)BY CONSTANTLY TRYING TO REDUCE ITS IMPACT ON
EVERY SINGLE TERRITORY OF ITS PLANTS AROUND THE
WORLD AND BY MONITORING AND IMPROVING ITSACTIVITIES AND THROUGH AWARENESS-RAISING INITIATIVES
AIMED AT STAFF. THE CERTIFICATIONS OBTAINED AND RENEWEDOVER THE YEARS SUCH AS ISO 9001, IATF 16949, ISO 13485,
ISO 45001, ISO 14001 AND ISO 50001 DEMONSTRATE OURCOMMITMENT TO QUALITY, ENVIRONMENT, ENERGY AND SAFETY.
116

SUSTAINABILITY
Commitment

13 PLANTS20
13 6
PLANTSWE HAVE 13 PLANTS
WITH ENVIRONMENTAL
AND/OR SAFETY AND/OR
ENERGY CERTIFICATIONOUR ENVIRONMENT

14001

5
PLANTS
CERTIFICATES
PLANTSWITHOUT NCS

45001
117

2 PLANTS
50001

INDICATORS AND TARGETS

We are actively working to reduce environmental impacts throughout
the value chain by leveraging our efficient, compact, and precision technologies
to improve the environmental performance of our products, utilizing renewableenergy, and enhancing our business activities in order to achieve our targets.

RESPONSIBLE SOURCING OF MINERALS

118

Where minerals such as tin, tantalum, tungsten, gold (3TG) and cobalt are mined in conflict-affectedor high-risk areas such as the Democratic Republic of Congo (DRC) and adjoining countries, the revenue
from the mining and trading of these minerals is a source of funding for armed groups and anti-government
forces carrying out atrocities and human rights abuses. Minerals sourced from such conflict-affected or
high-risk areas have the potential to promote conflict, human rights violations and environmental degradation.
Tsubaki Nakashima considers mining to be an intensive process involving social and environmental
risks, and believes the minng of metals and minerals, including conflict minerals (3TG) and cobalt minedin the DRC, as well as other minerals mined in other regions, must be managed. Tsubaki Nakashima’s policy
is that we want no part in any human rights violations or environmental destruction. While sourcing minerals
that originate in conflict-affected or high-risk areas, we will not, by any means, tolerate, knowingly profit from,contribute to, assist with or facilitate the commission by any party of any form of human rights violations orabuses, or support operations that result in the degradation of socioeconomic and environmental stability.

REDUCING GREENHOUSEGAS (GHG) EMISSIONSThe 2015 Paris Agreement set a goal of keeping the increase in average global
temperature to well below 2°8above pre-industrial levels. Tsubaki Nakashima
started few years ago to work on the same direction.
Actions to reduce emissions are being explored at model sites and then sharedwith others to increase the likelihood that targets will be achieved.
Main actions for reducing emissions

Production innovations and automation

Investment in updated facilities and equipment
such as plant infrastructure, and solar power systems
Purchasing low-carbon electricity and using other forms of renewable energy
Other reductions to be achieved by power utilities reducing
their GHG emissions factors

INITIATIVESIN MANUFACTURING
PROCESSES119

In many of our steel ball plants, we have reduced the tons of CO2 produced per ton of productto below a 1-to-1 ratio and averaged 0,8 and, thanks to the Monozukuri project on the rationaluse of energy, we expect to lower this value to below 0,8 in the next three years.
In our Rollers Plant, the ratio is 0,5.

OUR ENVIRONMENT

Tsubaki Nakashima expects its energy use to increase as
production increases in line with its long-term growth strategy. The useof renewable energy (energy from natural sources) is one of the most effective
ways to reduce GHG emissions. Accordingly, Tsubaki Nakashima is implementing plans
to expand its use of renewable energy long-term. However, there are obstacles to expanding
renewable energy use, including costs and supply limitations in some regions. Recognizingthat there is nothing one company alone can do about these obstacles, we decided to declare our
support for the important policy recommendations below as one solution. The realization of theserecommendations will make it easier to take actions that minimize the impact on future climate change.
Coordinated global action is essential to combat climate change. We at Tsubaki Nakashima will therefore
continue our efforts toward decarbonization, including by supporting future such recommendations. In
specific, according to the Global Sustainability System,
all our sites and businesses are implementing
energy-saving measures and increasing the useof renewable energy to achieve our targets.

120

RENEWABLE
ENERGY USE

In every plant, to reduce fixed power consumption, we installed, and we are promoting the use of LEDs for fluorescent and mercury
lamps and the introduction of high-efficiency boilers, hydraulic units, and otherequipment with low energy consumption when renewing facilities. We have also beenworking on reducing fuel consumption by renewing or eliminating boilers and reducing
electricity consumption through efficient operation of air-conditioning equipment andcompressors; we are also promoting the installation of solar panels and use of electrical vehicles.

For example

Tsubaki Nakashima Italy - Elimination of asbestos’s roof and Energy
saving: as a replacement of the asbestos roofs, a total of 945
monocrystalline photovoltaic modules have being installed,with a power output of 311.85 kWp.

Tsubaki Nakashima implemented
a new Car Policy that all company
cars must be electric or hybrid,using the green energy producedby our photovoltaic systems
or purchased from renewableenergy producers.

Plants working
to introduce
sources of renewable energy

OUR ENVIRONMENTEUROPE

Plants using
renewable energy
sources

INDIA
121

Tsubaki Nakashima
India is supporting towards green energy
and installed roof top Solar Power Plant
of 60 KW capacity.

On top of it and to reduce energy consumption in manufacturing,a new Project has been launched at the end of 2020, led by Monozukuri’s
Global Function, assisted by the CHRO.
The international standard ISO 50002 defines all the process leading to the identificationof opportunities for improvement of energy performance and the Energy Audit process isa simple chronological sequence of specific activities that allows our Plants to improve theirenergy performance, reduce energy consumption and obtain environmental benefits.
Our Global Sustainability System is based on ISO 14001 (Environment), ISO 45001 (Health and
Safety) and ISO 50001 (Energy); the full implementation of it allows our Plants:
To be compliant with mandatory
and voluntary standards on energy
and environmental issues

To analyze processes from energy
perspective aiming at reachinga deep knowledge

To improveenergy performance

122

RENEWABLE
ENERGY USE
To inform suppliers that
products purchase is subordinate
to energy savings

To implement/improvemonitoring systemof energy consumptions

To internally communicate
and share Energy Management
SystemTo evaluate opportunity to buyhighly efficient plant and equipment

OUR ENVIRONMENTRESOURCES/FORMINGA CIRCULAR ECONOMY

To contribute to the formation of a circular economy in which waste is minimized,
Tsubaki Nakashima is working to reduce emissions and preserve water resources in its
production processes.

ZERO EMISSIONSAs per our Vision Zero Approach, Tsubaki Nakashima is working toward zero emissions by reducing
generated business waste and recycling. Wastes are generated in our production processes, offices, andoperations. Wherever possible, we reduce, reuse, and recycle these wastes on-site. Plastic runners frommolding processes are recycled, for example, and ReMida project is a significant example of this Vision
The remaining wastes, including valuable wastes, are recycled by a contractor. We carefully sort andseparate wastes and select the best available recycling methods and contractors for each type.
We will continue to reduce wastes and to work for general improvement
in waste processing methods, including by allying with recyclers.
In every ISO 14001 Certified Plant (13 factories, in total)
we employed control metrics and specific KPIs.

REDUCTION
OF WASTE

123

PRODUCTION PROCESSTRANSFORMING A WASTE
IN RESOURCE > ReMida PROJECTThe Monozukuri philosophy is based on “smooth manufacturing process”,
which include smooth process, less noise, friendly product, sludge reduction
and waste elimination.
The ReMida Project must achieve the target to reduce the quantity of sludge
produced, then transform the sludge in recyclable product. We strongly believe that improving
the internal environment we will improve the proudness of our employees and the confidenceof our Customer, together with the awareness of working for a brilliant future of Tsubaki Nakashima.

ZERO WASTE PROJECTSSludge basket
GOOD SLUDGENO GOOD SLUDGE

Sludge cleaning
process
Flitter press
Sludge Clean coolant

SludgePress molding

No goodcoolant

125

124

Briquette machine
Dehydration

Oil, microrganisms, etc.

Hardening
Press molding

Pressing
Hardening

OUR ENVIRONMENT

Penetration
treatment and oven

COOLANTS In the manufacture of precision balls, coolant

is used for processing, and sludge is generated during processing. In order toreduce the amount of sludge generated, we are working to improve our manufacturing
technology. The water-soluble cutting fluid used in the polishing process is recycled
by removing the shavings and returning them to the process, which leads to water
conservation. In addition, the sludge generated is compacted to remove the water content
and the residue is turned into valuable resources to reduce the total amount of waste.
Similar efforts are also being made to reuse water-soluble cutting fluids in the ball screw cutting
process through filtration and circulation.

PRESERVATION OF WATER RESOURCES

126

Water and climatechange, as well as other environmental factors, are closely linked. Tsubaki Nakashima’s factories rely onwater resources, and the sustainability of water resources substantially affects business continuity. Given this,
we are working to preserve water resources by avoiding unnecessary contamination and use, and by recycling
the water we do use. We actively strive to increase the rate of industrial wastewater that is recycled in our production processes and to meet strict water quality standards. We are also mitigating our overall environmental
impacts, including by introducing more energy efficient water processing facilities. Our efforts extend beyond
the water used in our production processes. We ensure that all employees have access to safe drinking water,
as well as sanitary kitchens and restroom facilities. Moreover, we make our employees aware of the importanceof saving water and preventing water pollution, and we install water-saving fixtures and sanitation facilities.

OUR ENVIRONMENTEXAMPLES
OF SUSTAINABILITY
PROJECTS
127

Install roof
in the waste
disposal’s
area

Fire
brigade’s
training

128

KATSURAGI(JAPAN)
Replacementof the Washing Machine
to improve efficiency,
reducing use of water

129

Reduction of coolant’s
consumption
6 Centrifuges for filteringof coolant, that enables
to reduce mesh typefilter waste.

EXAMPLES
OF SUSTAINABILITY
PROJECTSBEFORETHE NETHERLANDS

Redesign Infeed
System Honing Machine:Complete mechanicalinfeed without useof compressed air anymore,
and additional Energy
saving, Noise reduction,Less miston the shopfloor.

130

AFTER
Plant
environment
improvements

TAICANG(GREATER CHINA)
KONJIC(BOSNIA/HERZEGOVINA)

Air filtration
Recycle air by filtering
the exhausted air
in CRB grinding lines.
The goalof this projectis energy saving.

EXAMPLES
OF SUSTAINABILITY
PROJECTS

131

Furnace
project
1

2
4

2

132

1

Double flip flap

3

4

3

Insulationand maintenanceIn last 3 years
all goals
were reached

-26%

133

Fire
fighting

Nitrogenreduction

PINEROLO(ITALY)SILVASSA(INDIA)
EXAMPLES
OF SUSTAINABILITY
PROJECTSInput:recycled
Qurnchingoil

Easier accessfor employees to work
instructions- the ability
to verify at any time
whether a given job
is performed
correctly

Input: waste gas fromheat treatment andheading equipment,
activated carbon,
electrolytic tank(filter screen)
Recycke systemof Quenching oil

134

Output:waste liquid(hazardous waste
outsourcing),
Quenching oil recycle

KUNSHAN(GREATER CHINA)

135

Waste gas
treatment
systemOutput: waste oil(hazardous waste
outsourcing)

CHONGQUING(GREATER CHINA)

EXAMPLES
OF SUSTAINABILITY
PROJECTSAFTER

BEFORE• Reducing the amountof hazardous waste

INDUSTRIAL
CLEANING CLOTHES• Supply safe storage of oilycleaning clothes in production
areas for safety workplace• Instead of using disposablecleaning clothes we use
reusable cleaning
clothes

Type of hazardous wastewith wspecific reduction(2020 vs 2019)

136

Bulletimplementationof the oil sludge
filtration process.
An external
company conducts
filtrationin our plant

Oil slduge-36%

Sorbents, oily foil and waste paper,cleaning cloth-20%

Waste oil

-22%

Others-45%-31%

Average percentageof reductionof hazardous waste-26%• Recover of oilfrom sludge,
reused in production• Reduction of oil
sludge disposal costs• Wider rangeof waste suppliers(to dispatch easier)

Reductionof sludge waste
137• Reduction of weightof oil sludge

KRASNIK(POLAND)
EXAMPLES
OF SUSTAINABILITY
PROJECTS

Recoveryof water fromthe process
of abrasive
treatment needles

New
training room

KYSUCKENOVE MESTO(SLOVAKIA)AFTERBEFORE

Heading and Scan&Pack
area refurbishment
and re-layout

138

139

• Creation of a dashboard• Constant check ofall elements (electricity,gas, water, nitrogen)
AFTER

ALL INDICATORSWEREIMPROVEDBEFORE

EXAMPLES
OF SUSTAINABILITY
PROJECTS

Proper maintenanceand cleaning of equipment
improves the EHS
and quality of the work
environment
for employees
Recycling
Program

BEFORE140

CUMMING(GEORGIA - U.S.A.)

AFTER

SAULT ST. MARY(MICHIGAN - U.S.A.)

Renewed attention to safety
and housekeeping

BEFORE

AFTER

EXAMPLES
OF SUSTAINABILITY
PROJECTS133

Sustainability
training

948

OKAYAMA(JAPAN)

days without
accidents(end of Feb 2021)
142

-20%

RAYONG(THAILAND)

Energy savingby changing
old lightingwith led
lightslitres of reduction
separating IPA
from wastewater-3800

EXAMPLES
OF SUSTAINABILITY
PROJECTS

As part of our Global Quality Management System, we havecreated a Supply Chain Quality Manual. The Manual stipulates
ethical rules, Sustainable Management Systems, and compliance with safety,
health, and environmental laws that we require of our Suppliers.To maintaina Sustainable Supply Chain, we conduct regular audits of our Suppliers. In addition toaudits conducted at each plant, the Global Quality Assurance Department also conducts
regular audits.The Global Quality Assurance Department conducts on-site audits of particularly
important suppliers, collects samples, and analyzes ingredients in laboratories.

SUSTAINABILITY
AND SUPPLIERS

The results of the regular audits are disclosed to the suppliers in the form of reports, and the items pointed out
and items to be corrected are confirmed together. If corrective measures are not taken, we will suspendtransactions. In fiscal 2020, due to the spread of the new coronavirus infection,we were unable to conduct
on-site audits, but we plan to resume them in fiscal 2021. We also conduct Surveys on the chemical
143
content of raw materials in order to comply with the regulations on chemical substances containedin products in each region, such as the European RoHS Directive and the European REACH Regulation.

BUSINESS CONTINUITY PLAN’S INITIATIVESIN THE SUPPLY CHAIN

To ensure that the Group is able to fulfill its supply responsibilities even in the event of a disasteror conflict, the Group has established a system in its purchasing operation rules that allows it
to procure raw materials from multiple suppliers. In fiscal 2020, plants in various regions
experienced lockdowns to prevent the spread of the new coronavirus infection
and suspended operations due to government orders. In addition, we were able
to adjust inventory levels and cooperate with suppliers who were able to operate.

COMPLIANCE
AND ENVIRONMENTAL
LAWS AND REGULATIONTHE GROUP REPORTEDZERO VIOLATIONS144

OF ENVIRONMENTAL
LAWS AND REGULATIONSIN FISCAL 2020
Measures against environmental pollutants – Japan - Katsuragi

In December 2018, a survey by Nara Prefecture detected trichloroethylene and other substances exceeding
environmental standards in groundwater at the Katsuragi Plant site. The Katsuragi Plant had previously
used trichloroethylene in its manufacturing process, and since it was found to exceed the environmental
standards for sewage water in a voluntary survey conducted between 2006 and 2008, the plant has been
continuously purifying and monitoring the water by installing pumping wells and contaminated water
treatment equipment on the premises to prevent external leakage. Although there was no obligation
to measure and report on underground water, we have continued to conduct water intake surveys
from observation wells and borehole investigations and have made efforts to prevent
underground water contamination by utilizing facilities such as cleaning equipment
and wells and have also eliminated the use of trichloroethylene in October 2020.
In response to the detection of trichloroethylene, we are also checking thesituation at each plant in Japan and taking appropriate measures.

145

GRI STANDARD

146

GRI 102:
General Disclosures
2016

DISCLOSURE

ESG REPORT 2020 • TSUBAKI NAKASHIMAGRI 101: Foundation 2016
General Disclosures

CHAPTER

PAGE

Organization profile 102-1 Name of the organization

History

8-9

102-2 Activities, brands, products and services

Products, Applications

48 - 59102-3 Location of headquarters

Global Presence, True Numbers

10 - 15

102-4 Location of operations

Global Presence, True Numbers

10 - 15102-5 Ownership and legal form

Organizational Chart

15 - 17102-6 Markers served

Products, Applications

48 - 59102-7 Scale of the organization

Company, Structure, Quality, Our Commitment to People

16, 17, 26 - 41, 60 - 69, 74 - 93

102-8 Information on employees and other workers

Our Commitment to People

74 - 93102-9 Supply chain

Sustainability and Suppliers

141

102-10 Significant changes to the organization and its supply chain

History, Improving and Never Stopping, Sustainability and Suppliers

6, 7, 8, 9, 141

102-11 Precautionary Principle or approach

Vision and Management principles, Culture, ethics and values

18 - 25

102-12 External initiatives

International events and participation in external initiatives

104 - 109102-13 Membership of associations

International events and participation in external initiatives

104 - 109GRI CONTENT INDEX

147

GRI STANDARD

CHAPTER

PAGE

Strategy102-14 Statement from senior decision-maker

CEO Letter

4-5102-15 Key impacts, risks, and opportunities

SWOT Analysis, Context

42 - 45

102-16 Values, principles, standards and norms of behaviour

Vision, Mission and Management principles, Corporate Social Responsibility

18 - 25, 26 - 41

102-17 Mechanism fro advice and concerns about ethics

Vision, Mission and Management principles, Corporate Social Responsibility

18 - 25, 26 - 41

102-18 Governance structure

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-19 Delegating authority

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-20 Executive-level responsibility for economic, environmental,
and social topics
102-21 Consulting stakeholders on economic, environmental,
and social topics

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-22 Composition of the highest governance body and its committees

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-23 Chair of the highest governance body

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-24 Nominating and selecting the highest governance body

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-26 Role of highest governance body in setting purpose,values, and strategy

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-27 Collective knowledge of highest governance body

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-28 Evaluating the highest governance body’s performance

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

Governance

GRI 102:
General Disclosures
2016

ESG REPORT 2020 • TSUBAKI NAKASHIMAGRI 101: Foundation 2016
General Disclosures

Ethics and integrity

148

DISCLOSUREGRI CONTENT INDEX

149

GRI STANDARDDISCLOSURE

GRI 101: Foundation 2016
General Disclosures
Governance150

GRI 102:
General Disclosures
2016
Stakeholder engagement

ESG REPORT 2020 • TSUBAKI NAKASHIMA
CHAPTER

PAGE

102-29 Identifying and managing economic, environmental,
and social impacts

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-30 Effectiveness of risk management processes

Corporate Governance, CSR and International Standards

25 - 29, 30 - 31

102-31 Review of economic, environmental, and social topics

Corporate Governance, CSR and International Standards, GSS

27 - 29, 30 - 41, 94, 95

102-32 Highest governance body’s role in sustainability reporting

Corporate Governance, CSR and International Standards, GSS

27 - 29, 30 - 41, 94, 95

102-33 Communicating critical concerns

Stakeholders

46 - 47

102-34 Nature and total number of critical concerns

Compliance142102-35 Remuneration policies

Our Commitment to People

74 - 93102-36 Process for determining remuneration

Our Commitment to People

74 - 93102-40 List of stakeholder groups

Stakeholders

46 - 47

102-41 Collective bargaining agreements

Corporate Governance, CSR and International Standards

25 - 29, 30 -41

102-42 Identifying and selecting stakeholders

Stakeholders

46 - 47

102-43 Approach to stakeholder engagement

Stakeholders

46 - 47

102-44 Key topics and concerns raised

SWOT Analysis, Context Analysis

42 - 45GRI CONTENT INDEX

151

GRI STANDARDDISCLOSURE

Material Topics
200 series (Economic topics)
Reporting102-45 Entities included in the consolidated financial statements
practice

GRI 102:
General Disclosures
2016

152

Economic performance
GRI 103:
Management Approach
2016

CHAPTER

PAGE

Corporate Governance, CSR and International Standards

25 - 29, 30 - 41

102-46 Defining report content and topic Boundariesre-

SWOT Analysis, Context Analysis

42 - 45

102-47 List of material topics

SWOT Analysis, Context Analysis

42 - 45102-50 Reporting period

CEO Letter, Improving and Never Stopping

4, 5, 6, 7

102-51 Date of most recent report

CEO Letter, Improving and Never Stopping

4, 5, 6, 7

102-52 Reporting cycle

CEO Letter, Improving and Never Stopping

4, 5, 6, 7

102-53 Contact point for questions regarding the report

CEO Letter, Improving and Never Stopping

4, 5, 6, 7

102-54 Claims of reporting in accordance with the GRI Standards

CEO Letter, Improving and Never Stopping

4, 5, 6, 7

102-55 GRI content index

GRI content index

146 - 171103-1 Explanation of the material topic and its Boundary

SWOT Analysis, Context Analysis

42 - 45103-2 The management approach and its components

History, Improving and Never Stopping, Corporate Social Responsibility,
Sustainability and Suppliers, Quality, TN Atmosphere
History, Improving and Never Stopping, Corporate Social Responsibility,
Sustainability and Suppliers, Quality, TN Atmosphere8, 9, 6, 7, 14, 15, 26 - 41, 143, 110-117, 60, 70

History, Improving and Never Stopping, Products, Applications

6, 7, 8, 9, 48-59

103-3 Evaluation of the management approach

GRI 201:
Economic Performance 2016

ESG REPORT 2020 • TSUBAKI NAKASHIMA

201-1 Direct economic value generated and distributed

GRI CONTENT INDEX

8, 9, 6, 7, 14, 15, 26 - 41, 143, 110-117, 60, 70

153

GRI STANDARDDISCLOSURE

Material Topics
200 Series (Economic Topics)
Market103-1 Explanation of the material topic and its Boundary
Presence

GRI 103:
Management Approach2016
GRI 202:
Market Presence
2016
GRI 103:
Management Approach
2016
154

CHAPTER

PAGE

Improving and Never Stopping, True Numbers, Products, Applications, Quality

6, 7, 14, 15, 48-59

103-2 The management approach and its components

Improving and Never Stopping, True Numbers, Products, Applications, Quality

6, 7, 14, 15, 48-59

103-3 Evaluation of the management approach

Improving and Never Stopping, True Numbers, Products, Applications, Quality

6, 7, 14, 15, 48-59

202-1 Ratios of standard entry level wage by gender comparedto local minimum wage

Corporate Governance, CSR and International Standards,
Our Commitment to People
Corporate Governance, CSR and International Standards,
Our Commitment to People
Improving and Never Stopping, True Numbers, Products, Applications, Quality,
TN Atmosphere
Improving and Never Stopping, True Numbers, Products, Applications, Quality,
TN Atmosphere
Improving and Never Stopping, True Numbers, Products, Applications, Quality,
TN Atmosphere202-2 Proportion of senior management hired from the local community

Indirect Economic Impacts

103-1 Explanation of the material topic and its Boundary
103-2 The management approach and its components
103-3 Evaluation of the management approach

GRI 203:
Indirect Econimic Impacts 2016
Procurement Practices
GRI 103:
Management Approach201625-29, 30-41, 74-93
25-29, 30-41, 74-93
6, 7, 14, 15, 48 - 59, 110 - 140
6, 7, 14, 15, 48 - 59, 110 - 140
6, 7, 14, 15, 48 - 59, 110 - 140

203-1 Infrastructure investments and services supported

Quality

60 - 69

103-1 Explanation of the material topic and its Boundary

6, 7, 14, 15, 48 - 59, 143

103-3 Evaluation of the management approach

Improving and Never Stopping, True Numbers, Products, Applications, Quality,
Suppliers
Improving and Never Stopping, True Numbers, Products, Applications, Quality,
Suppliers
Improving and Never Stopping, True Numbers, Products, Applications, Quality,
Suppliers

204-1 Proportion of spending on local suppliers

Stakeholders, Sustainability and Suppliers

46, 47, 143

103-2 The management approach and its components

GRI 204:
Procurement Practices 2016

ESG REPORT 2020 • TSUBAKI NAKASHIMAGRI CONTENT INDEX

6, 7, 14, 15, 48 - 59, 143
6, 7, 14, 15, 48 - 59, 143

155

GRI STANDARDDISCLOSURE

Material Topics
200 Series (Economic Topics)
Anti103-1 Explanation of the material topic and its Boundary
Corruption

GRI 203:
Indirect Economic
Impacts 2016103-2 The management approach and its components
103-3 Evaluation of the management approach205-1 Operations assessed for risks related to corruption

GRI 205:
Anti-Corruption
2016

205-2 Communication and training about anti-corruption policies
and procedures
205-3 Confirmed incidents of corruption and actions

Anti-Competitive Behaviour
156

GRI 103:
Management Approach2016

103-1 Explanation of the material topic and its Boundary
103-2 The management approach and its components
103-3 Evaluation of the management approach

GRI 206:
Anti-competitive Behaviour 2016

206-1 Legal actions for anti-competitive behavior, anti-trust,and monopoly practices

ESG REPORT 2020 • TSUBAKI NAKASHIMA
CHAPTERCEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR
CEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR
CEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR
CEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR
CEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR
CEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR
CEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR, Stakeholders
CEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR, Stakeholders
CEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR, Stakeholders
CEO Letter, Improving and Never Stopping, Vision, Mission,
Management Principles, CSR, Stakeholders

GRI CONTENT INDEX

PAGE
4, 5, 6, 7, 14 - 25, 26 - 41
4, 5, 6, 7, 14 - 25, 26 - 41
4, 5, 6, 7, 14 - 25, 26 - 41
4, 5, 6, 7, 14 - 25, 26 - 41
4, 5, 6, 7, 14 - 25, 26 - 41
4, 5, 6, 7, 14 - 25, 26 - 41
4, 5, 6, 7, 14 - 25, 26 - 41, 46, 47
4, 5, 6, 7, 14 - 25, 26 - 41, 46, 47
4, 5, 6, 7, 14 - 25, 26 - 41, 46, 47
4, 5, 6, 7, 14 - 25, 26 - 41, 46, 47

157

GRI STANDARDDISCLOSURE

300 Series (Environmental Topics)
EnergyGRI 103:
Management Approach2016

GRI 302:
Energy
2016

158

Water
GRI 103:
Management Approach2016
GRI 303:
Water and Effluents
2018

ESG REPORT 2020 • TSUBAKI NAKASHIMA
CHAPTER

PAGE

103-1 Explanation of the material topic and its Boundary

Context analysis, TN Atmosphere42 - 44, 110 - 122, 130 - 140

103-2 The management approach and its components

Context analysis, TN Atmosphere42 - 44, 110 - 122, 130 - 140

103-3 Evaluation of the management approach

Context analysis, TN Atmosphere42 - 44, 110 - 122, 130 - 140

302-1 Energy consumption within the organization

TN Atmosphere, Initiatives, Energy Certifications, Examples

110 - 115, 116, 117, 118, 119, 120 - 122, 127 - 140

302-2 Energy consumption outside of the organization

TN Atmosphere, Initiatives, Energy Certifications, Examples

110 - 115, 116, 117, 118, 119, 120 - 122, 127 - 140

302-3 Energy intensity

TN Atmosphere, Initiatives, Energy Certifications, Examples

110 - 115, 116, 117, 118, 119, 120 - 122, 127 - 140

302-4 Reduction of energy consumption

TN Atmosphere, Initiatives, Energy Certifications, Examples

110 - 115, 116, 117, 118, 119, 120 - 122, 127 - 140

302-5 Reductions in energy requirements of products and services

TN Atmosphere, Initiatives, Energy Certifications, Examples

110 - 115, 116, 117, 118, 119, 120 - 122, 127 - 140

103-1 Explanation of the material topic and its Boundary

TN Atmosphere, Initiatives

110 - 115, 118, 119

103-2 The management approach and its components

TN Atmosphere, Initiatives

110 - 115, 118, 119

103-3 Evaluation of the management approach

TN Atmosphere, Initiatives

110 - 115, 118, 119

303-1 Interactions with water as a shared resource

TN Atmosphere, Initiatives

110 - 115, 118, 119

303-2 Management of water discharge-related impacts

TN Atmosphere, Initiatives

110 - 115, 118, 119

303-3 Water withdrawal

TN Atmosphere, Initiatives

110 - 115, 118, 119

GRI CONTENT INDEX

159

GRI STANDARDDISCLOSURE

300 Series (Environmental Topics)
GRI 303:
Water and Effluents
2018

Water

Emissions
GRI 103:
Management Approach
2016

160

GRI 305:
Emissions
2016

ESG REPORT 2020 • TSUBAKI NAKASHIMA
CHAPTER

PAGE

303-4 Water discharge

TN Atmosphere, Initiatives

110 - 115, 118, 119

303-5 Water consumption

TN Atmosphere, Initiatives

110 - 115, 118, 119103-1 Explanation of the material topic and its Boundary

TN Atmosphere, Initiatives

110 - 115, 118, 119

103-2 The management approach and its components

TN Atmosphere, Initiatives

110 - 115, 118, 119

103-3 Evaluation of the management approach

TN Atmosphere, Initiatives

110 - 115, 118, 119305-1 Direct (Scope 1) GHG emissions

TN Atmosphere, Initiatives

110 - 115, 118, 119305-2 Energy indirect (Scope 2) GHG emissions

TN Atmosphere, Initiatives

110 - 115, 118, 119305-3 Other indirect (Scope 3) GHG emissions

TN Atmosphere, Initiatives

110 - 115, 118, 119305-4 GHG emissions intensity

TN Atmosphere, Initiatives

110 - 115, 118, 119305-5 Reduction of GHG emissions

TN Atmosphere, Initiatives

110 - 115, 118, 119305-6 Emissions of ozone-depleting substances (ODS)

TN Atmosphere, Initiatives

110 - 115, 118, 119305-7 Nitrogen oxides (NOX), sulfur oxides (SOX),
and other significant air emissions

TN Atmosphere, Initiatives

110 - 115, 118, 119

GRI CONTENT INDEX

161

GRI STANDARDDISCLOSURE

300 Series (Environmental Topics)

ESG REPORT 2020 • TSUBAKI NAKASHIMA
CHAPTER

PAGE

103-1 Explanation of the material topic and its Boundary

TN Atmosphere, Initiatives, Wastes and others

110 - 115, 118, 119, 123 - 125

103-2 The management approach and its components

TN Atmosphere, Initiatives, Wastes and others

110 - 115, 118, 119, 123 - 125

103-3 Evaluation of the management approach

TN Atmosphere, Initiatives, Wastes and others

110 - 115, 118, 119, 123 - 125

306-1 Water discharge by quality and destination

TN Atmosphere, Initiatives, Wastes and others

110 - 115, 118, 119, 123 - 125

306-2 Waste by type and disposal method

TN Atmosphere, Initiatives, Wastes and others

110 - 115, 118, 119, 123 - 125

306-3 Significant spills

TN Atmosphere, Initiatives, Wastes and others

110 - 115, 118, 119, 123 - 125

306-4 Transport of hazardous waste

TN Atmosphere, Initiatives, Wastes and others

110 - 115, 118, 119, 123 - 125

306-5 Water bodies affected by water discharges and/or runoff

TN Atmosphere, Initiatives, Wastes and others

110 - 115, 118, 119, 123 - 125

103-1 Explanation of the material topic and its Boundary

TN Atmosphere110 - 115

GRI 103:
Management Approach2016

103-2 The management approach and its components

TN Atmosphere110 - 115

103-3 Evaluation of the management approach

TN Atmosphere110 - 115

GRI 307: Environmental Compliance2018

307-1 Non-compliance with environmental laws and regulations

Compliance

144

GRI 103:
Management Approach
2016

Effluentsand Waste

GRI 306:
Effluents and Waste
2016

162

Environmental Compliance

GRI CONTENT INDEX

163

GRI STANDARDDISCLOSURE

400 Series (Social Topics)
Employment
GRI 103:
Management Approach
2016

Labour/Management Relations
164

CHAPTER

PAGE

103-3 Evaluation of the management approach

CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People

4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 73
6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 73
6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 73

401-1 New employee hires and employee turnover

KPIs

85 - 87401-2 Benefits provided to full-time employees that are not provided
to temporary or part-time employees

CSR

26 - 41401-3 Parental leave

CSR

26 - 41

103-1 Explanation of the material topic and its Boundary

CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People

4, 5, 6, 7, 8, 9, 14, 15, 16, 17, 18 - 25, 26 - 41, 74 - 93

103-2 The management approach and its components

CSR, Our Commitment to People

26 - 41, 74 - 93

103-3 Evaluation of the management approach

CSR, Our Commitment to People

26 - 41, 74 - 93

103-1 Explanation of the material topic and its Boundary

CEO letter, History, Improving and never stopping, Vision, Mission and Manag.
Principles, CSR, Our Commitment to People, Occupational Safety & Health4, 5, 6, 7, 8, 9, 14, 15, 16, 17, 18 - 25, 26 - 41, 74 - 93

103-2 The management approach and its components

Our Commitment to People, Occupational Safety & Health74 - 93103-3 Evaluation of the management approach

Our Commitment to People, Occupational Safety & Health74 - 93403-1 Occupational health and safety management system

Our Commitment to People, Occupational Safety & Health74 - 93403-2 Hazard identification, risk assessment, and incident investigation

Our Commitment to People, Occupational Safety & Health74 - 93103-1 Explanation of the material topic and its Boundary
103-2 The management approach and its components

GRI 401:
Employment
2016

GRI 103:
Management Approach2016
Occupational Health and Safety
GRI 103:
Management Approach2016
GRI 403:
Occupational Health & Safety
2018

ESG REPORT 2020 • TSUBAKI NAKASHIMAGRI CONTENT INDEX

165

GRI STANDARDDISCLOSURE

400 Series (Social Topics)
Occupational
Health & Safety

GRI 403:
Occupational Helath & Safety
2018

166

Training and education
GRI 103:
Management Approach2016
GRI 404:
Training and Education
2016

ESG REPORT 2020 • TSUBAKI NAKASHIMA
CHAPTER

PAGE

403-3 Occupational health services

Our Commitment to People, Occupational Health and Safety

74 - 93403-4 Worker participation, consultation, and communication
on occupational health and safety

Our Commitment to People, Occupational Health and Safety

74 - 93403-5 Worker training on occupational health and safety

Our Commitment to People, Occupational Health and Safety

74 - 93403-6 Promotion of worker health

Our Commitment to People, Occupational Health and Safety

74 - 93403-7 Prevention and mitigation of occupational health and safety impacts
directly linked by business relationships
403-8 Workers covered by an occupational health and safety
management system

Our Commitment to People, Occupational Health and Safety

74 - 93

Our Commitment to People, Occupational Health and Safety

74 - 93403-9 Work-related injuries

Our Commitment to People, Occupational Health and Safety

74 - 93403-10 Work-related ill health

Our Commitment to People, Occupational Health and Safety

74 - 93103-1 Explanation of the material topic and its Boundary

People Development, Talents

78 - 86

103-2 The management approach and its components

People Development, Talents

78 - 86

103-3 Evaluation of the management approach

People Development, Talents

78 - 86404-1 Average hours of training per year per employee

People Development, Talents

78 - 86

People Development, Talents

78 - 86

People Development, Talents

78 - 86404-2 Programs for upgrading employee skills
and transition assistance programs
404-3 Percentage of employees receiving regular performanceand career development reviews

GRI CONTENT INDEX

167

GRI STANDARDDISCLOSURE

400 Series (Social Topics)

CHAPTERPAGE

Diversity andEqual Opportunity

CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People

4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93

GRI 103:
Management Approach2016

103-1 Explanation of the material topic and its Boundary
103-2 The management approach and its components
103-3 Evaluation of the management approach

GRI 405: Diversity and Equal Opportunity 2016 405-1 Diversity of governance bodies and employees
Non-Discrimination

103-1 Explanation of the material topic and its Boundary
103-2 The management approach and its components
103-3 Evaluation of the management approach

168

ESG REPORT 2020 • TSUBAKI NAKASHIMAGRI 406: Non-discrimination 2016406-1 Incidents of discrimination and corrective actions taken

Freedom of Association
and Collective Bargaining
GRI 103:
Management Approach2016
GRI 408:
Freedom of Association
and Collective Bargaing
ù2016

103-1 Explanation of the material topic and its Boundary
103-2 The management approach and its components
103-3 Evaluation of the management approach407-1 Operations and suppliers in which the right to freedomof association and collective bargaining may be at risk

GRI CONTENT INDEX

169

GRI STANDARDDISCLOSURE

400 Series (Social Topics)

CHAPTER

PAGE

409-1 Operations and suppliers at significant risk
for incidents of forced or compulsory labor

CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People
CEO letter, History, Improving and never stopping, Vision,
Mission and Management Principles, CSR, Our Commitment to People

4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93

103-1 Explanation of the material topic and its Boundary

Stakeholders - Context analysis

42 - 47

GRI 103:
Management Approach2016

103-2 The management approach and its components

GRI 413:
Local Communities
2016413-1 Operations with local community engagement,
impact assessments, and development programs
413-2 Operations with significant actualand potential negative impacts on local communities

Corporate Governance, CSR and International Standards, Our Commitment
to People, Response to the coronavirus pandemic - Corporate Citizen
Corporate Governance, CSR and International Standards, Our Commitment
to People, Response to the coronavirus pandemic - Corporate Citizen
Corporate Governance, CSR and International Standards, Our Commitment
to People, Response to the coronavirus pandemic - Corporate Citizen

4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93
4, 5, 6, 7, 8, 9, 14, 15, 16, 17,
18 - 25, 26 - 41, 74 - 93

Response to the coronavirus - Corporate Citizen

70 - 73

Child Labour
GRI 103:
Management Approach2016

103-1 Explanation of the material topic and its Boundary
103-2 The management approach and its components
103-3 Evaluation of the management approach408-1 Operations and suppliers at significant risk
for incidents of child labor

GRI 408: Child Labour 2016
Forced or Compulsory Labour
GRI 103:
Management Approach
2016
170

ESG REPORT 2020 • TSUBAKI NAKASHIMA

103-1 Explanation of the material topic and its Boundary
103-2 The management approach and its components
103-3 Evaluation of the management approach

GRI 409: Forced or Compulsory Labour 2016
Local Communities

103-3 Evaluation of the management approach

GRI CONTENT INDEX

171

GRI STANDARDDISCLOSURE

400 Series (Social Topics)
Socioeconomic
Compliance

GRI 103:
Management Approach2016

GRI 419: Socioeconomic Compliance 2016

ESG REPORT 2020 • TSUBAKI NAKASHIMA
CHAPTER

PAGE

103-1 Explanation of the material topic and its Boundary

Stakeholders - Context analysis

42 - 47

103-2 The management approach and its components

CSR and International Standards, Our Committment to People

25 - 41, 74 - 93

103-3 Evaluation of the management approach

CSR and International Standards, Our Committment to People

25 - 41, 74 - 93

419-1 Non-compliance with laws and regulationsin the social and economic area

Compliance

144

169

168

GRI CONTENT INDEXThe graphic design and the graphic development of thecontents in this publication were thought and createdby Mario Bois, Italian eclectic artist, that expresses his
creativity in different fields working as: graphic designer
journalist, actor in theatre and film industry, director,
author and poet.
He really enjouyed to convey creative energy to give birth
to a new perception of common, shared business contents.

TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMANAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKITSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA TSUBAKI NAKASHIMA