A company is more than its facilities, its products, and its profits. At its core, a company is the belief system—the code—to which it operates, the measuring stick against which it evaluates its actions.
At NN, that evaluation exists on many levels. We believe companies have a number of responsibilities to their employees, their customers, their shareholders, the environment, and the communities they serve.
We believe our employees, officers, and directors have a responsibility to behave ethically, and to treat one another with dignity and respect. We believe empowerment and personal responsibility are the keys to our success, and the success of our customers. And we believe safety and opportunity for all are activities that can be improved upon every day.
Diversity, equity, and inclusion are at the core of our values and strategic business priorities. Throughout our business, we champion equality, supporting parity for women and under-represented groups as we work to create ethical, safe, and supportive workplaces where our employees thrive. We believe a diverse, fair, and inclusive workplace results in business growth and encourages increased innovation, retention of talent, and a more engaged workforce. Respect for human rights is fundamental to our business and its commitment to ethical business conduct.
At NN, our first priority is to ensure that our employees are safe. Each day, in every facility, we strive to provide a work environment that is free from hazards that can cause injuries and illnesses, ensure that we are good stewards of our environment, and educate employees to do their jobs safely.
We endeavor to conduct business in a manner that promotes the fair and just treatment of all people. We acknowledge our potential impact on the environment and are committed to operating in a responsible manner to help reduce that impact. In all aspects of our operations, we seek to conduct business in a way that reflects integrity and the high standards we have set for ourselves.
The protection of our environment and the health and safety of our employees, our customers and the communities in which we live and operate in is an integral part of NN’s mission to provide high-quality products and superior customer service that continuously exceeds our customers’ expectations. We manage our Company, wherever we do business, in an ethical way that addresses social, environmental and economic objectives. We expect our employees and service providers to embrace these objectives in all our daily activities.
OUR GOALS ARE TO
Implement health and safety practices that enable NN employees to work illness and injury-free and to conduct our operations in an environmentally sustainable and energy efficient manner.
WE ARE COMMITTED TO
WE WILL ACHIEVE THESE COMMITMENTS BY
This document was last updated on April 3, 2020.
NN is committed to maintaining a corporate culture that promotes, protects and supports all internationally recognized human rights. In conformance with the United Nations (UN) Universal Declaration of Human Rights, we respect the value and dignity of every individual, recognize our responsibility to respect human rights, and avoid complicity in human rights abuses.
Purpose
Our Company benefits when we treat human rights as fundamental and inalienable. This approach helps ensure that we make the right investments in our people that strengthen and improve our business for the long term.
Applicability
This Policy applies to all NN operating units and all of its directors, officers, employees (including temporary employees), suppliers, and contractors around the world. Our employees, officers, directors, suppliers, and contractors are expected to conduct themselves in accordance with this Policy and our Code of Business Conduct and Ethics. Suppliers and contractors are expected to take appropriate actions to require their own suppliers, subcontractors, agents, vendors, and partners to follow this Policy when providing goods or services to NN.
Employees
We believe that all employees deserve to be treated with respect and dignity, which includes working in an environment that is free from harassment and discrimination. We maintain an ethical work environment that reflects the core values of our Company, and we foster a safe and inclusive workplace. NN is a global company, and the world we serve is diverse in its social customs and cultural traditions. We respect and embrace this diversity, and believe the unique viewpoints that we each bring to our roles challenge and enable us to think more broadly, while helping us better serve our customers and communities.
Suppliers
NN is committed to high standards of ethical and business conduct as it relates to its procurement of goods and services. We strive to respect human rights through our supply chain by encouraging actions that are consistent with this Policy, and by using suppliers whose corporate values are consistent with ours. Our suppliers are expected to protect the rights of workers, including those regarding health and safety standards and local wage and hour laws. Further, they must not engage in the use of forced labor, child labor, or human trafficking of any kind.
Communities
Being a good corporate citizen to the communities we serve is a core value at NN, and our respect for human rights extends to the communities where our employees live and work. We recognize and enthusiastically accept our responsibility to these communities, from our ethical behavior to our involvement in and support for community activities. Further, NN believes in the free, prior and informed consent (FPIC) of Indigenous Peoples and conducts itself in alignment with the UN Declaration on the Rights of Indigenous Peoples and the ILO Convention 169.
The Environment
We conduct our operations in an environmentally responsible manner and in compliance with all applicable legal requirements. In addition, we look to reduce our environmental footprint, reduce the production of waste, reduce our use of scarce natural resources, and protect our global environment. We believe access to water is a fundamental human right, and as such it is important to our Company, our employees, our stakeholders and our local communities to proactively manage our environmental impacts and continue to enhance the sustainability of our operations.
Diversity, Equity, and Inclusion
NN values and advances diversity, equity, and inclusion in the workplace. We work to maintain workplaces that are free from discrimination or harassment on the basis of race, sex, color, national origin, ethnicity, religion, age, physical or mental disability, sexual orientation, gender identification or expression, citizenship status, veteran status, marital status, genetic information, or any other status protected by applicable law. Further, we strive to protect the rights of women and minority groups. Qualifications, performance, skills and experience are the basis for recruitment, hiring, placement, development, training, compensation and advancement at the Company.
Labor Relations
The Company respects the rights of employees to form, join, or not join labor unions. This includes the right to freedom of association and collective bargaining. Our employees have the right to fair working conditions, competitive wages and reasonable working hours. We do not tolerate the use of child labor, forced labor, bonded labor, or human trafficking of any kind.
Responsibilities
Everyone at NN is responsible for observing and promoting this Policy. The Company and its managers are responsible for upholding specific areas of this Policy, communicating them to their employees, supporting NN’s efforts to respect and support the protection of human rights, modeling their behavior accordingly, and raising concerns regarding potential non-compliance with this Policy.
Consequences/Penalty for Non-Compliance
Adherence to all Company polices is mandatory. Non-compliance may result in disciplinary action, up to and including termination. A violation, or suspected violation, of this Policy should be reported to your manager, your site’s human resources department, the Chief Human Resources Officer, or the Chief Compliance Officer.
This Privacy Notice explains the way NN, Inc. and its controlled affiliates collect, use, maintain, disclose and transfer information collected from users (each, a “User”) of the www.nninc.com website (“Site”). This privacy notice applies to the Site and all products and services offered by NN, Inc. This privacy notice describes how you may exercise your rights regarding our processing of the information and the measures we take to safeguard the personal information we obtain.
Personal Information
“Personal information” as used in this privacy notice is any data that can be used to identify, locate or contact a single person, such as:
Types of Information/Data We Collect and How it is Collected
We may collect personal information from Users in a variety of ways, including, but not limited to:
Users may be asked for, as appropriate, name, email address, mailing address, or phone number. Users may, however, visit our Site anonymously. We will collect personal information from Users only if they voluntarily submit such information to us. See below ‘Web Cookies and Similar Technologies’ section of this notice. Users can always refuse to supply personal information, except that it may prevent them from engaging in certain Site-related activities. For instance, if cookies are not accepted, user language preferences will not be remembered and these will have to be reset each time a user visits the site.
Non-Personal Information
We may collect data about Users whenever they interact with our Site that does not, on its own, permit direct association with any specific individual. Non-personal information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
Web Cookies and Similar Technologies
Our Site may use “cookies” to enhance User experience. Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. A User’s web browser places cookies on its hard drive for record-keeping purposes and sometimes to track information about them. We may collect information about your activity on the site and your language preferences. In addition, we may collect information about the website you visited before accessing the NN, Inc. website. In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without reference to personal information. Users may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly. For more information concerning cookies, refer to our Cookie Policy.
How We Use Collected Information
NN, Inc. may collect and use personal information for the following purposes:
How We Protect Your Information
We adopt appropriate data collection, storage and processing practices and security measures designed to protect against unauthorized access, alteration, disclosure or destruction of your personal information, including username, password, transaction information and stored data. We also employ appropriate procedures and protocols to adequately protect personal data in transit.
Sharing Your Personal Information
We do not sell, trade, or rent personal information to others. We may share generic aggregated demographic information that is not linked to any personal information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
Third Party Websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing.
These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
User’s Choices to Manage Personal Information
NN, Inc. complies with applicable law regarding your ability to manage your personal information, including your ability to access, correct and delete your personal information. Specifically, NN, Inc. complies with the requirements stated within the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA). Under GDPR, users have rights for access, rectification, erasure, restriction, objection, portability and automated decisioning. To help manage these choices, please contact us via email to NN.Privacy@nninc.com. You can also write us a letter at the address provided in the Contacting Us section below. Please include in your correspondence your name, address, email address and detailed information about the change you would like to make.
Children’s Personal Information
Our Site is not directed to children under the age of 16. We do not knowingly collect or solicit personal information from children under the age of 16 through the Site. If we become aware that we have collected personal information from a child under the age of 16, we will promptly delete the information from our records. If you believe that a child under the age of 16 may have provided us with personal information, please contact us as specified in the Contacting Us section of this Privacy Notice.
Privacy Rights Under the California Consumer Privacy Act (CCPA)
This California Privacy Notice supplements the NN, Inc. Privacy Notice and contains the disclosures required under the California Consumer Privacy Act (CCPA). For individuals who are California residents, the CCPA requires certain disclosures about the categories of personal information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it. You have also the right to exercise certain rights regarding your personal information.
Please note that for California residents, the term personal information means information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular consumer or household as defined in the CCPA. All other capitalized terms have the same meanings as given them in the Policy.
Data Subject Requests
If you are a California resident who has provided personal information to NN, Inc. or a California resident that reasonably believes that NN, Inc. collected or stores their personal information, you have the right to request NN, Inc. to:
You can only make two Requests to Know in a 12-month period, and the information provided need only cover the 12-month period prior to receipt of your request.
Methods for Submitting Request
You may submit Requests to Know and Requests to Delete by sending an email to NN.Privacy@nninc.com.
Verification of Requests
We will need to verify your identity to respond to Requests to Delete and Requests to Know. If you have an account with us that is password-protected, we may verify your identity through our existing authentication practices for your account.
If you do not have an account with us, and your request concerns “categories” of personal information collected, we can request from you two data points of personal information to verify your identity. If you do not have an account with us, and your request concerns specific pieces of personal information, we can request from you at least three data points of personal information as well as a signed declaration with penalty of perjury to verify your identity.
If a request concerns household information, and the household does not have a password-protected account with us, we will not comply with a Request to Know specific pieces of personal information about the household or a request to delete household personal information unless all of the following conditions are satisfied: (1) All consumers of the household jointly request access to specific pieces of information for the household or the deletion of household personal information; (2) we have individually verified all the members of the household under the CCPA; and (3) we have verified that each member making the request is currently a member of the household.
Time for Response
Please note that once you have submitted a Request to Know or Request to Delete, we will send you a receipt, acknowledging your request, within 10 business days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send us an email to NN.Privacy@nninc.com as an error may have occurred.
We will respond to Requests to Know and Requests to Delete within 45 calendar days after they are received. If we cannot verify you within the 45-day time period, we may deny the request. If necessary, we may take up to an additional 45 calendar days to respond to the consumer’s request, for a maximum total of 90 calendar days from the day the request is received, provided that we will provides you with notice and an explanation of the reason that we will take more than 45 days to respond to the request.
In the case of a Request to Delete, we may use a two-step process for online requests to delete where you must first, submit the Request to Delete and then second, separately confirm that you want your personal information deleted.
Notice of Opt-Out
You have the right to opt-out of the sale of your personal information by us. While we do not sell personal information as defined under the CCPA, you can still notify us that you wish to opt-out of any sales by sending an email to NN.Privacy@nninc.com. We will comply with a Request to Opt-out as soon as feasibly possible, but no later than 15 business days from the date we received the request. Nevada residents can also submit a Request to Opt-out.
Authorized Agent
As a California resident, you have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us at NN.Privacy@nninc.com for more information if you wish to submit a request through an authorized agent.
Right to Non-Discrimination for the Exercise of CCPA Rights
You have a right not to receive discriminatory treatment by us for the exercise of the privacy rights conferred by the CCPA. We hereby inform you that if you exercise any of your rights under the CCPA we may not deny you goods or services for that reason, or subject you to different prices than those paid by other consumers, except to the permitted under the CCPA.
Notice at Collection
Pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of personal information that we collect through the Site and Services, the business or commercial purposes for which such personal information was collected, the categories of sources of such personal information and the categories of third parties to whom such information was disclosed in the past twelve (12) months. If you are a California resident and a user of the NN, Inc. website, pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of Personal Information that we collect and the business and commercial purpose for which it is collected.
Personal Information for purposes of this notice is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
In particular, we collect the following categories of Personal Information from Users of this Site for the following business or commercial purposes:
Category | Collected | Business or Commercial Purpose |
---|---|---|
A. Identifiers. | YES | To respond to inquiries that are submitted through the NN, Inc. website |
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | YES | To respond to inquiries that are submitted through the NN, Inc. website |
C. Protected classification characteristics under California or federal law. | NO | Not Applicable |
D. Commercial information. | NO | Not Applicable |
E. Biometric information. | NO | Not Applicable |
F. Internet or other similar network activity. | NO | Not Applicable |
G. Geolocation data. | NO | Not Applicable |
H. Audio, electronic, visual, thermal, olfactory, or similar information | NO | Not Applicable |
I. Professional or employment-related information. | YES | To conduct the interview and hiring process for potential employees and/or to assist in making hiring decisions |
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | YES | To assist in making hiring decisions |
K. Inferences drawn from other personal information. | NO | Not Applicable |
Changes to this Privacy Policy
NN, Inc. has the discretion to update this privacy policy at any time. When we do, we will revise the updated date at the bottom of this page. We will inform you of changes to this privacy policy, such as posting a notice on our homepage or directly emailing you with information about material changes. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect.
Your Acceptance of These Terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. We will inform you of any changes to this policy.
Contacting Us
If you have any questions about this Privacy Notice, the practices of this site, your dealings with this site or if you would like us to update information we have about you or your preferences, please contact us at:
NN, Inc.
Corporate Compliance Department
6210 Ardrey Kell Road, Suite 120
Charlotte, NC 28277
980.264.4300
NN.Privacy@nninc.com
www.nninc.com
This document was last updated on July 27, 2022.