Each and every employee strives to conduct in accordance with compliance.

Initiatives for compliance

Our Group's management policy begins with the phrase, “Maintain a straightforward way in business.”

In addition to legal compliance, we view it as fulfilling our Social Responsibility (CSR) to our stakeholders, such as our customers, shareholders, suppliers, and local residents, by following our Employees Code of Conduct, company rules, and social norms (manners and morals), as one of the major pillars of our management.

In promoting compliance, the President himself directly calls out the importance of compliance in all dialogues with the top management and employees of each Group company to foster awareness.

Also, in our Employees Code of Conduct stipulates that all corporate officers and employees are to comply with laws, regulations and corporate ethics.

To raise awareness of this, we issue top management messages on compliance with the Anti-Trust Law, anti-bribery, etc. To instill compliance, we conduct compliance trainings for new/ promoted employees of all Group companies by level, and various training programs such as compliance with the Anti-Trust Law and harassment.

We designate every November as “Ethics Enhancement Month” and take measures such as sending out messages from the top management of the NHK Group and displaying posters, as well as selecting familiar compliance themes every month and distributing “Compliance News”. We engage in this work not just at our Japanese affiliates, but worldwide, through such efforts.

Compliance promotion structure

Under the supervision of the President and CEO, the GM of the HQ CSR Department is responsible for promoting compliance management, the responsible leader is the head of each division,and the HQ CSR Department serves as the promotion secretariat.

Framework with respect to antitrust laws

In 2016, NHK Spring underwent an on-site search by the Fair- Trade Commission on suspicion of violation of the Antimonopoly Act. Learning from this, we execute antitrust law training for all sales members annually without fail.

Overseas, training is also conducted in line with the activities of each region. Besides the above, we have introduced a system to check for harmful behavior by implementing and checking prior notification of contact with competitors throughout the Group, as well as e-mail auditing.

Whistleblowing system (Compliance Hotline) / Supplier Reporting Contact Point

We have established a compliance hotline where employees of NHK and domestic group companies can consult or report anonymously to NHK Spring or an external law firm that has no conflict of interest with the Company, as a system to consult or report internally when they have questions.

In order to ensure the reliability of the system, we notice compliance hotline contact to all employees, through compliance cards distribution, and in various lectures/ monthly newsletters relating to compliance. Company newsletters are also used to inform employees about the flow of responses and operations from the receipt of internal reports.

We are also introducing this same system at overseas Group companies, including those in North America, China, and Mexico. Our company website includes on its top page a “Reporting Contact Point for Suppliers,” enabling suppliers to make a report in the event that any compliance violation were to occur in a transaction with our company.

We have established a system that leads to the early detection and correction of problems by taking appropriate action against reports to these contact points.

Group Compliance Hotline case count: 57 Number of compliance related reports from suppliers: 0

Anti-bribery and Anti-corruption initiatives

Our Group has designated bribery, corruption, and inappropriate donations as prohibited acts under the Employee Code of Conduct, Compliance Rules, and Anti-Bribery Regulations, and conducts training programs, especially in high-risk areas overseas. In our compliance newsletters, we raise awareness of the prohibition of bribes to public officials, as well as the prohibition of excessive entertainment and gifts that exceed social norms, even between private companies.

Security trade control

We set up regulations and detailed rules for security trade control and determining the applicability of export transactions in order to comply with laws and regulations regarding security trade control.