NSD recognizes that compliance forms an important foundation of its corporate activities. Accordingly, we have established the NSD Group Code of Conduct and the NSD Group Behavioral Guidelines, and have developed a compliance structure. In addition, through training and other means, we strive to increase awareness of compliance among officers and employees and to carefully abide by laws and regulations.
NSD Group Code of Conduct and NSD Group Behavioral Guidelines
The NSD Group Code of Conduct set forth the basic policies on compliance in business activities for all officers and employees of NSD and its subsidiaries as follows.
To actualize the NSD Group Code of Conduct, we have established the NSD Group Behavioral Guidelines as a set of guidelines for all officers and employees of NSD and its subsidiaries to follow from the standpoint of relationships with society, business activities, and the company, and mutual relationships within the company.
NSD has established the Risk Management Committee in order to carry out company-wide cross-functional risk management, and under this committee, we have established the Compliance Committee.
The Compliance Committee is chaired by the President & CEO and consists of members including related officers and department managers. It strives to ensure employee compliance with laws and regulations through response to compliance violations and the formulation of preventive measures.
Following the changing operating environment and increasingly diverse and complex nature of business activities, it is becoming even more important to foster awareness of legal compliance among employees and increase their compliance literacy. Toward this end, we are working to enhance our training and awareness program on compliance.
NSD considers compliance training to be a mandatory component of training on its Risk Management Rules. Every year, we provide comprehensive training to officers and employees and also offer separate training sessions as needed.
As follows, training curriculum is expansive and covers a host of subjects from laws and regulations to labor management and harassment.
Fair trade under the Subcontractor Act and disguised contracting, etc.
Prevention of bribery of public officials, etc.
Prevention of fraudulent accounting including circular transactions and fictitious transactions, etc.
Personal information and information security
Whistleblower reporting system (compliance and workplace harassment hotlines)
Compliance and Workplace Harassment Hotlines
From the standpoint of ensuring the effectiveness of our compliance structure and in an effort to prevent compliance violations and harassment in the workplace, NSD has established a compliance hotline and harassment hotline allowing all individuals involved in the NSD Group’s operations, including officers, employees and business partners, to submit a report or share a concern without fear of reprisal.
Each hotline has both internal and external (law office) contact points, providing an environment where reports or consultations can be made without hesitation.
Ensuring Fair Trade and Preventing Corruption
■ Ensuring Fair TradeThe NSD Group Code of Conduct and the NSD Group Behavioral Guidelines both require that our actions abide by correct corporate ethics and comply with relevant laws and regulations, including Japan’s Unfair Competition Prevention Act and Anti-Monopoly Act.
Whenever we commence business dealings with a new customer or business partner, the Development Support Department reviews the transaction to ensure compliance with various guidelines and laws, such as Japan’s Subcontractor Act and Temporary Staffing Services Act.
■ Actions to Prevent CorruptionNSD engages in fair business activities following social norms and complies with anti-corruption-related laws and regulations, including Japan’s Unfair Competition Prevention Act.
We established "Anti-Bribery and Corruption Policy" to prohibits business entertainment and gift giving, along with provision of improper money, goods, benefits, or other economic benefits to public officials and those in similar positions. Through compliance training, we ensure that appropriate action is taken in all relevant situations.
Anti-Bribery and Corruption Policy
All officers and employees of the NSD Group shall be aware of the potential serious impact of bribery of public officials and others on the NSD Group and on society, and shall not tolerate any forms of corruption or bribery. We shall comply with anti-bribery and corruption laws and regulations and conduct ourselves in accordance with this policy.
2. Prohibition of gifts and entertainment
We shall not offer anyone entertainment, money or other gifts, directly or indirectly through third parties, for the purpose of gaining unjust advantage. We shall always carry out the procedure for obtaining approval in accordance with internal rules before giving or receiving any entertainment or gifts within the scope of laws and regulations and within the bounds of social common sense.
3. Thoroughgoing management of accounting records
We shall prepare accounting books in reasonable detail and retain records of all of the transactions of NSD and its subsidiaries.
4. Development and operation of system for seeking advice and reporting
We shall report to our managers or the compliance division any requests for the payment of expenses or money received from public officials or others and deal with any such requests in an appropriate manner.
5. Continuous improvement
We shall develop appropriate internal systems for preventing bribery and corruption through monitoring and other means, and continuously review these systems and strive for improvement.
■ Disclosure of Fair Trade Violations and Corrupt ActionsNSD has never been investigated or punished by a government authority for violation of the Unfair Competition Prevention Act or Anti-Monopoly Act, nor for corruption-related offenses.
In fiscal 2021, NSD did not make any political contributions either in Japan or another country.
Under the following policy, NSD fulfills its tax obligations following the laws and regulations of the countries and regions where it operates.