The Nitto Group is committed to the spirit of being “open, fair, and best” as stated in our Corporate Philosophy. As such, we conduct business activities with integrity, based on high ethical standards that always prioritize compliance, without being distracted by short-term gains.
The Nitto Group Business Conduct Guidelines (hereinafter referred to as “BCG”) were published to guide everyone working for the Nitto Group around the world to share values and act ethically in compliance with laws and regulations in their business activities. We ensure that each and every member of the Group understands and thoroughly follows the guidelines, which have been translated into 18 languages so far.
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The Nitto Way and the BCG are aimed at each and every officer and employee of the Nitto Group (directors, executive officers, employees, dispatched workers, part-timers, temporary workers, etc.).
The relationship between these two is that if The Nitto Way is a set of values that define a code of conduct to be practiced, the BCG ties the set of values to behavior standards.
Today, social rules consist not just of laws and regulations, but also of responses to society’s demands.
The Nitto Group discloses how it responds to these demands in the form of basic policies such as the Basic Policy on Sustainability.
In developing the BCG, we have observed these basic policies and incorporated them into the daily behaviors of each and every one of us.
The compliance department, established under the vice president for compliance, collaborates with the heads of various sites and Group companies to not only abide by laws but also engage in a variety of activities, such as ensuring respect for human rights. The compliance department carries out compliance promotion activities using the BCG as a common standard for making decisions. The vice president for compliance addresses important matters by reporting them to higher management, e.g. at Corporate Strategy Meeting. Every effort is being made to ensure the early detection of legal violations and ethical issues by implementing a whistleblowing system available to all employees of the Group. For our business partners, the Partner Hotline is available for them to seek consultation on cases of noncompliance or suspected noncompliance involving transactions with the Nitto Group.
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The Nitto Group has established a whistle-blowing system and made it available to employees as a system for monitoring the spread of compliance awareness with transparency. The internal reporting channel is managed by the compliance department, which is a dedicated department for a whistle-blowing system, while the external reporting channel is handled by an independent third-party organization. Discrimination and harassment incidents can be reported through this system.
When a report is received, we will scrutinize the content and consider the need for an investigation. If an investigation is needed, we will begin it promptly. Based on the results of the investigation, we will determine whether there is a compliance violation. If a compliance violation is identified, we will take corrective measures and recurrence prevention, and take appropriate measures, such as disciplinary action, against those involved in the act based on the Nitto Group rules and the rules of each site.
The Partner Hotline, as it is called, is also available for business partners, including those from subcontracting businesses and construction services.
Both contacts keep whistle-blowers’ privacy strictly confidential, and anonymous reports are allowed. Respondents handle the reports thus made in line with confidentiality obligations under the laws. The operational rules of the system stipulate that whistle-blowers should never be treated unfairly and that no threat or reprisal against them should be tolerated, and that those who commit such acts will be subject to disciplinary action based on the Nitto Group rules and the rules of each site. Furthermore, we provide employees with necessary training on the use of a whistle-blowing system.
| Reporting Systems | For whom | Reported to / Handled by |
|---|---|---|
| a. For the entire Group | Group employees | Compliance department |
| b. For each country/region | Group employees in respective countries/regions | Third-party organizations |
| c. Partner Hotline | Business partners | Compliance department |
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The Nitto Group operates a compliance management system managed by the compliance department in order to meet the expectations of society and continuously improve our compliance standards.
As the Nitto Group carries out a wide range of business activities around the world, the management system takes the following three points into consideration.
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The Nitto Group does not engage in any form of bribery or corruption.
We abide by laws, regulations and guidelines regarding gifts and charitable or political contributions, and do not use either as a means of bribery.
Furthermore, we will implement measures to prevent bribery or corruption, such as providing employees with necessary training on the anti-bribery and anti-corruption.
We also establish procedures for handling breaches.
In the event of breach, we will cooperate with experts to conduct the necessary investigations and take the appropriate measures, such as disciplinary action, corrective measures, and recurrence prevention.
If the officers or employees of the Nitto Group violate compliance, appropriate measures such as disciplinary actions are taken along with prompt corrective measures and recurrence prevention based on the laws of each country or the Nitto Group rules and the rules of each site. In addition, the Nitto Group discloses on our website any compliance violations that should be disclosed.
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