Fundamental Approach

The Nittobo Group is aware that it is a public instrument that operates for the benefit of society. It naturally complies with laws and regulations as well as with social norms, and it strives to remain a Company that is trusted by society. This is the starting point for the Company’s existence that must be unconditionally observed so long as this Company is a member of society.
All officers and employees understand the necessity of practicing compliance, and the Company will always conduct fair and just business activities with a spirit of complying with the law and a firm sense of ethics.

The Nittobo Behavior Program and the Nittobo Code of Conduct

The Nittobo Behavior Program and Nittobo Code of Conduct have been enacted to set the standards for all officers and employees of the Nittobo Group to ensure that the Nittobo Group will always be a company that is trusted by society.
To ensure that these are firmly established as the basis for the Company’s daily business activities, and that they are imbued in the core being of all officers and employees, all officers including senior management will strive to lead by example as they continuously and proactively promote awareness through education and training programs.

Internal Whistleblowing Contact

The Nittobo Group has established a whistleblowing program, the Corporate Ethics Helpline, to prevent and detect violations of laws and regulations at an early stage and to take appropriate corrective actions.
In cases where a violation of laws, regulations, or internal rules, improper conduct, or other such problem occurs at work but resolution at the business site is unlikely or an employee is unable to consult with workplace colleagues or superiors, any Nittobo Group employee can make reports to and consult with the helpline with peace of mind.
The reporting and consultation office is available not only within the Company but also externally through an outside law firm, which allows for anonymous reporting and consultation. The privacy and confidentiality of whistleblowers is protected, and measures are taken to prevent prejudicial treatment as a result of making a report. The reporting and consultation office also ensures independence from the executive side by handling reports and consultations that may involve directors and officers under the Audit Committee's supervision. The Company is committed to creating a system that whistleblowers can use with greater peace of mind by, for example, responding to reports and consultations in good faith, confirming the facts and taking corrective measures, and reporting the results of the investigation to the whistleblower.

The Nittobo Group Compliance System

The Nittobo Group has the following system in place for ensuring that the execution of duties of the Group's officers and employees is in compliance with laws, regulations and the articles of incorporation.

  • The Representative and Chief Executive Officer sets an example and ensures that the Group's officers and employees are aware of the Group's Corporate Philosophy, Nittobo Declaration which espouses shared values, and Nittobo Behavior Program and Code of Conduct, both of which provide a set of action guidelines, and also endeavors to make them known to all officers and employees in the Group.
  • Executive Officers and employees foster a healthy corporate culture that forms the basis for compliance by spreading and implementing the Nittobo Declaration.
  • Executive Officers and employees comply with laws, regulations, the articles of incorporation and internal rules, etc., based on the Nittobo Behavior Program and Code of Conduct, and the departments responsible for compliance strive to raise awareness of compliance to increase their effectiveness.
  • Violations of laws and regulations are prevented, quickly discovered and appropriately addressed through a Corporate Ethics Help Line, which is a whistleblowing program with an internal and external contact points.
  • The Executive Officer in charge of the Risk Management Department periodically reviews the state of establishment of the Nittobo Group's internal control system to ensure the current conditions are consistent with the Group's basic policy. The results of the review are reported to the Representative and Chief Executive Officer, who reports to the Board of Directors, which passes resolutions if any revisions to the basic policy are required.
  • The Audit Committee reports the results of operational audits and compliance audits, etc., to the Board of Directors as appropriate.

The Nittobo Group has the following other systems for ensuring appropriate operations by the Nittobo Group.

  • The Nittobo Declaration, the Nittobo Behavior Program, the Code of Conduct and the Corporate Ethics Help Line apply to the entire Group, and efforts are made to raise awareness of these.
  • Auditing offices are established in major subsidiaries to ensure appropriate operations, and the Company's Audit Office also conducts internal audits with a view to the entire Nittobo Group