NSD Group Behavioral Guidelines

Article 1: Relation with Society

  1. 1Contribution to society

    We will contribute to society in our daily lives to the extent possible as a member of society.

  2. 2Conservation of the environment

    We will act extensively to conserve the environment, such as promoting effective use of resources (e.g., paperless work, use of recycled paper), separating waste, and reducing energy consumption.

  3. 3Donations

    When making donations on behalf of the company, regardless of the amount of money involved, we will obtain the necessary approval in advance following the internal regulations on authority and responsibility. We will not make personal donations in the name of the company.

  4. 4Opposing antisocial forces

    We will resolutely oppose antisocial forces and groups that threaten the order and safety of citizens' lives and will not respond to any illegal or unreasonable demands. If trouble occurs or looks to occur with such forces or groups, we will by no means deal with it on our own but will immediately contact management and the General Affairs Department for advice. If we should unintentionally become involved with such forces or groups, we will without fear contact management and the General Affairs Department and follow their advice. As a company, we will coordinate internally and work in cooperation with lawyers and police.

  5. 5Relation with public officials

    We will not provide entertainment, gifts, illicit money or benefits, or other economic gains to public officials or those in an equivalent position. (This excludes entertainment and gifts provided overseas that comply with laws and regulations and are within socially reasonable limits, and entertainment and gifts provided in Japan that have been pre-approved by the Legal Office of our Corporate Planning Department.) If we are asked to provide such illicit benefits, we will immediately contact management and the Legal Office of the Corporate Planning Department for advice.

  6. 6Information disclosure

    We will work to increase transparency and gain the trust of society by disclosing corporate information in a timely, appropriate and proactive manner to shareholders, investors, business partners and society at large.
    We will disclose information according to established rules and methods. When we are asked externally to provide information, we will contact the Corporate Secretary Department without fail and follow their instructions.

Article 2: Relation with Business Activity

  1. 1Guarantee of fair trade and free competition

    We will always be open and fair in our relationships with all customers and business partners. In conducting transactions, we will strive to maintain fair transactions in compliance with relevant laws and regulations, including the Unfair Competition Prevention Act and the Antimonopoly Act.
    We will not attend meetings or engage in any action that may hinder the exchange of information, fair trade or free competition.

  2. 2Transactions with customers, providers and suppliers

    We will always treat customers, providers and suppliers with decency and integrity on an equal and fair basis.
    We will refrain from using our dominant position over business partners, providers or suppliers to pursue personal interests through actions such as coercing them into unfair transactions, demanding unfair profits, or asking improper favors.

  3. 3Transactions with overseas parties

    When importing or exporting software, products and technologies, we will comply with relevant laws and regulations such as the Foreign Exchange and Foreign Trade Act and the Export and Import Transaction Act and follow prescribed procedures.

  4. 4Entertainment and gifts with customers

    We will provide entertainment and gifts only between our company and our customers and only within the scope of societal common sense.

Article 3: Relation with Company

  1. 1Compliance with labor laws and regulations

    We fully understand the purpose of the Labor Standards Law and other such laws and will work to maintain safety and order in the workplace.

  2. 2Compliance with internal regulations

    We will comply with all work rules and other regulations and stipulations set by the company.

  3. 3Conflict-of-interest transactions

    We will not engage in any acts that could conflict with the company's interests. We will not become a counterparty to transactions with the company or conduct business that competes with the company without the company's approval.

  4. 4Political / religious activities

    We will not engage in our capacity as NSD Group officers and employees in activities such as soliciting support for specific political parties or political/religious/ideological groups, requesting election votes, or slandering or libeling others. When we participate as an individual in a particular activity, we will refrain from highlighting the company's name or our job titles so as to avoid misrepresentation of such acts as a company opinion or action.

  5. 5Protection and proper usage of company assets

    We will act to protect all tangible and intangible assets of the company and use them properly only for business purposes. We will not take any action that damages the company, such as loss, damage or fraudulent use of assets; fraudulent billing of expenses; or diversion of company assets for private purposes.

  6. 6Information management and preservation

    We will use confidential information only for business purposes. We will not steal, leak or disclose such information outside the company. We will not use confidential, undisclosed or personal information obtained in the course of business from other companies for any purpose other than that specified, and will not misuse or leak any such information.
    In places where an unspecified number of people gather, such as restaurants and trains, we will not speak with other employees about confidential information related to either our company or our customers, nor will we handle documents in public with any such information.

  7. 7Protection of intellectual property rights

    We will maintain and protect the intellectual property rights held by the company, while respecting the intellectual property rights of other companies or persons and not infringe or misuse them.

  8. 8Insider trading

    We will not buy, sell or otherwise trade stocks or other securities using undisclosed information belonging to our company or customers that is gained in connection with our duties.

Article 4: Internal Relationships

  1. 1Respect for human rights and prohibition of discrimination

    We will always mutually respect human rights both inside and outside the workplace, and will not act or speak in violation of human rights at any time.
    We will not discriminate on the basis of gender, age, educational background, race, ethnicity, nationality, ideology, beliefs or physical, intellectual or mental disability.

  2. 2Harassment

    We will eliminate unjustified harassment in the workplace, such as sexual harassment through sexual remarks and behavior, discrimination-based slander and jokes, and remarks and actions that undermine human dignity. We take a strict stance of "don't do it, don't cause it, don't permit it."