Sustainability
Compliance
Compliance
Compliance System
Compliance is a fundamental prerequisite for building corporate value and is indispensable to putting our corporate principles into practice. We have developed a variety of compliance-related internal rules, based on the NITTA Group Mission and NITTA Group Code of Conduct, as well as established the NITTA Group Code of Conduct Practices Book in order to codify what is acceptable conduct for employees.
In addition, we have created a Compliance Committee chaired by a director and comprised of outside directors, Audit & Supervisory Board members and others, as well as established a subordinate Compliance Subcommittee, in order to ensure thorough compliance. The Compliance Subcommittee generally meets once a month and performs duties related to the following matters.
- 1.Establishment of basic policies, internal rules, etc., concerning compliance promotion, and formulation of proposals for revision or abolition of such policies, rules, etc.
- 2.Formulation, progress management, and evaluation of proposed compliance promotion plans
- 3.Matters concerning initiatives for the sharing of internal audit findings
- 4.Handling of compliance cases
- 5.Surveys and research of the enactment, revision, and abolishment of laws and regulations related to our business, as well as administrative and social trends
- 6.Compliance program formulation and implementation
- 7.Disclosure of information on the status of the Group’s compliance promotion to stakeholders
- 8.Instructions to and information coordination with other departments involved in compliance promotion
Compliance Subcommittee
| Subcommittee chair | Officer in charge of General Affairs and CSR Promotion Department |
|---|---|
| Subcommittee members | Persons responsible for the Strategic Management Department; General Affairs and CSR Promotion Department; Safety, Environment, and Quality Department; Management Administration Department; Purchasing Department; Human Resources Department; and Intellectual Property Department |
| Secretariat | General Affairs and CSR Promotion Department |
NITTA Group Code of Conduct
The Nitta Group strives to provide excellent and valuable products and services in order to earn greater trust from public society and grow together with it. Toward this end, we have established the NITTA Group Code of Conduct, which all employees of the Nitta Group pledge to faithfully observe and put into practice.
- 1.Providing high-quality products and services
- 2.Compliance with laws and regulations
- 3.Proactive and fair disclosure of company information
- 4.Mutual respect and a comfortable work environment
- 5.Contribution to society
- 6.Contribution to the resolution of global environmental issues
- 7.Co-existence with the international community
- 8.Fair dealings
- 9.Suitable handling of data
- 10.Establishment of a system to promote corporate ethics
Priority Compliance Initiatives
Prohibition of Bribery
The NITTA Group Code of Conduct calls for compliance with laws and regulations, fair dealings, and establishment of a system to promote corporate ethics. We have also established the NITTA Group Anti-bribery Policy to prevent violations by prohibiting bribery of civil servants and other parties.
Eliminating Dealings with Antisocial Forces
To help eliminate antisocial forces, the Nitta Group acts in accordance with laws to resolutely deal with forces and groups that threaten the order and safety of business activities and people’s lives. We have incorporated this aim into the NITTA Group Code of Conduct, which stipulates that we will cut off any relationships with antisocial forces and will engage in no actions that encourage their activities.
The General Affairs and CSR Promotion Department is in charge of responding to unreasonable demands or otherwise dealing with antisocial forces. The department prepares manuals and other materials for reporting and responding to incidents, and cooperates with police, the National Center for Removal of Criminal Organizations, and other bodies to systematically deal with antisocial forces.
Preventing Insider Trading
To ensure that officers and employees of the Nitta Group comply with Article 166 and Article 167 of the Financial Instruments and Exchange Act, the NITTA Group Code of Conduct forbids the buying or selling of shares on the basis of unpublished information. We have also established information management systems based on our Regulations for the Management and Disclosure of Important Information and Regulations for the Prevention of Insider Trading to eliminate unfair trading. In addition, we have registered information concerning officers in the J-IRISS (Japan-Insider Registration & Identification Support System) of the Japan Securities Dealers Association, to cooperate in the prevention of violations of insider trading laws and regulations and to assure trust in securities markets.
NITTA Group Anti-bribery Policy
The Nitta Group has established the NITTA Group Code of Conduct and NITTA Group Code of Conduct Practices Book and has made public its stance on, as well as uses employee training to guarantee there is Group-wide awareness about, ensuring legal compliance in business activities, prohibiting unjust enrichment or favors to specific individuals, and engaging in honest and fair transactions.
In light of the increasingly global demand for stronger action to prevent bribery, the Nitta Group has made a greater effort to promote the NITTA Group Code of Conduct and has established the NITTA Group Anti-bribery Policy to clarify the Group’s position that bribery will not be tolerated under any circumstances.
Based on this policy, the Nitta Group is working to prevent bribery, as well as to expand its anti-bribery system, not only in Japan but in all countries and territories where it does business, thereby maintaining and developing society’s trust in the Nitta Group.
It should be noted that the efforts of Nitta Group officers and employees alone are not enough to prevent bribery; business partners’ understanding and cooperation are also essential. We therefore ask for all of our business partners’ understanding and support in putting the NITTA Group Anti-bribery Policy into practice.
NITTA Group Anti-bribery Policy
- 1. Compliance with Laws and Regulations The Nitta Group and its officers and employees comply with the relevant anti-bribery laws and guidelines (anti-bribery laws and regulations) of all countries and regions, and under no circumstances engage in acts of bribery or other unauthorized methods.
- 2. Prohibition of Acts of Bribery
(1)Bribery
The Nitta Group and its officers and employees, whether in Japan or overseas, do not provide, or promise to provide, payments or other benefits (generally also includes Small Facilitation Payments: SFP), directly or indirectly with the intention of forcing government workers or other officials to engage in or ignore their professional duties, with the aim of attaining or maintaining business interests. (2)Bribes
The Nitta Group and its officers and employees, whether in Japan or overseas, do not directly or indirectly demand, promise to receive, or receive payment of fraudulent or inappropriate funds or other benefits. - 3. Response to Third Parties
The understanding and cooperation of the Nitta Group’s business partners is essential for ensuring the prevention of bribery. The Nitta Group requires compliance with anti-bribery laws and regulations by third parties (distributors, consultants, agents, hereafter referred to as “business partners”) that have business dealings with the Group or that the Group outsources operations to.
If business partners are found to have engaged in actions that violate anti-bribery laws and regulations, the Group will take disciplinary action including rejecting transactions in accordance with this policy. - 4. Ensuring Management of Accounting Records The Nitta Group creates and stores accurate accounting records for business dealings, expenses and disposal of assets in a timely manner in accordance with internal regulations and manuals covering paperwork.
- 5. Audit The Nitta Group regularly monitors officers and employees for the compliance status of this policy. The targets and methods of monitoring are determined by taking the country and region, business characteristics and extent of risks into consideration.
- 6. Education and Training The Nitta Group provides ongoing education and training required for implementing this policy to officers and employees.
- 7. Disciplinary Action The Nitta Group strives to identify actions that violate, or have the risk of violating, this policy by operating an internal reporting system. In the event that such actions or risk of such actions are identified, investigations are conducted and handled appropriately based on the facts presented. Should investigations be conducted by authorities, the Group takes the appropriate actions.
- 8. Revisions If revisions need to be made to this policy, the Nitta Group will make those revisions as soon as possible.
Nitta Corporation
Representative Director/President
Compliance Education
We conduct annual education for managers and employees who are vital to compliance. In fiscal 2021, we conducted educational activities for managers on the theme of increasing the rate at which male employees take childcare leave, in line with revisions to the Child Care and Family Care Leave Act.
As a means of supporting the practice of compliance in workplaces, we also provide on-site compliance education materials to all employees in the Nitta Group in Japan every other month.
Whistleblowing System
The Nitta Group has introduced an internal reporting system that enables all employees, including officers, Audit & Supervisory Board members, employees, contract employees, fixed-period employees, part-time workers, nonregular employees, dispatched employees, and retirees (within one year of retirement), as well as employees of business partners, to make reports to dedicated contact points for the prevention, early detection, and remediation of organizational or personal misconduct within the Nitta Group.
Whistleblowers can submit these reports via a toll-free telephone line, online form, email, or in a written report.*
The dedicated contact points work through an external organization that is independent from management, to ensure the protection of whistleblowers.*Reports from overseas or business partners must be submitted via online form.
Whistleblowing System
Monitoring
Monitoring is an important part of any compliance program. The Nitta Group monitors existing and new compliance risks that exist within a wide range of corporate activities, as well as trends in risks, to discover issues before they become apparent.
Specific measures include voluntary inspections at group companies and internal audits of our company and group companies.