Efforts for GovernanceCompliance

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Basic Philosophy for Compliance

The Company considers that in order to aim for a company which can respond to social requests through putting the corporate philosophy into practice, besides the legal compliance in each country and region, each employee must make efforts to develop moral fiber and establish ethics required of a human being, to act in sensible and responsible manner. We have established the "NITTAN Group Global Code of Conduct" as the policy which shows this basic idea and its framework.

Outline of Compliance System

The Company has formulated the global compliance program with commitments taken by the top management, and built the management system over the whole NITTAN group.
We have established the Governance Committee as the mechanism which raises awareness of compliance and ensures legal compliance. The said committee is composed of the Company's directors (inside) and company auditors (inside).
By establishing the persons responsible for compliance in affiliate companies and each department, we are promoting clarification of responsibility, and finely built management system.
We have established the Corporate Governance Department in charge of internal audit, as an independent department under the direct control of the President, which conducts an audit regularly to affiliate companies and each department, to realize an efficient audit.
We have introduced the whistle-blowing system available to all the officers and employees of the NITTAN group (established the contact points in an in-company department and an external law firm), to build and promote the system which can respond promptly and appropriately respond to compliance violations, etc. reported to the contact point.

Governance Committee

The Company has established the Governance Committee of which the Global Compliance Officer appointed by the President serves as chairperson of the committee, and the persons responsible for compliance in affiliate companies and each department on the global basis, to build the promotion system.
In addition to the progress report on the promotion plan formulated by affiliate companies and each department themselves to be provided regularly by them, the Company's internal audit department conducts an audit, and the chairperson of the said committee provides a report to the Board of Directors and the Board of Company Auditors, after the deliberation. We have also established the global office in the said committee, to seek the smooth operation of the said committee, as well as focus on the awareness building activities.

Whistle-Blowing System of the Group

For legal violations, misconduct, and harassment, we have established the whistle-blower contact points available to officers and employees of the NITTAN group. The "Corporate Governance Department" and "an outside lawyer" are to serve as the contact points for reporting.
By providing a plurality of whistle-blowing means, such as "telephone", "email", "post", and "fax", we have ensured convenience, and made the whistle-blower protection known to all. Although a whistle-blowing means from outside of Japan is limited to email, we make languages such as Japanese, English and Chinese available, in order to enable the whistle-blowing system to be operated globally.
In addition, the report on whistle-blowing cases is regularly provided to the Board of Directors, and the monitoring of operational status of the system is performed.

Promotion of Compliance Activities

By distributing the "Compliance Declaration Card" to each officer and each employee, and posting the compliance motto in each workplace, we make efforts to cultivate a compliance culture in each department. In addition, we make every endeavor to raise compliance awareness, such as in-house training provided by the Corporate Governance Department, and regular awareness building activities at the workplace level.