Being aware that each of us is a constituent member of the business enterprise having a characteristic of a social and public institution, we hereby adopt this Code as our moral standard and code of conduct.
We can continue to operate the business only if customers support us and society trusts us.
We keep this in mind and have pride in having as our principle the lawfulness and sincerity that reflects the spirit in which the Company was founded.
We observe applicable domestic and foreign laws with regard for the underlying spirit of such laws and also “behave with integrity as a company and an individual” in order to continue to be fair and sincere to society. More specifically, we:
Management personnel should take the lead in observing this Code of Ethics and make it well known to people within the Company. If any breach of this Code occurs, Management should investigate the reasons therefore, make efforts to avoid recurrence of such breach and fulfill the responsibility of prompt disclosure of relevant information and explanations for such incidences.
The Code of Ethics, which sets forth our ethics and action guidelines, upholds the principle to “behave with integrity as a company and an individual.” To ensure that business activities adhere to laws and regulations, the Ethics Subcommittee, an organization in which external attorneys participate and which is directly controlled by the President, is held once every two months. The Ethics Subcommittee plans and manages programs seeking thorough compliance through enhancement of staff education and training, and makes final decisions on compliance with various business issues. An officer responsible for risk management reports the detailed activities of the Subcommittee to the Board of Directors.
To deal with doubtful matters on compliance in the Group, the Company has established an internal reporting system which allows executives and employees of the Group to directly inform the Ethics Subcommittee of such matters. The liaison contacts, which may be used by each domestic Group company, have been set both inside and outside the Company, and a system is in place which ensures that Audit & Supervisory Board Members are informed at the same time. The Company also receives information from external sources such as business partners.
The Ethics Subcommittee was established based on the Code of Ethics and the Ethical Action Standards for the purpose of raising the level of ethical behavior of the Company and the Group companies, and is convened six times a year.
In September 2018, the Nissui Principles was prepared and distributed to all employees. The Nissui Principles include the Corporate Philosophy, the Basic Management Philosophy, the CSR Action Declaration, the Employee Health Declaration, the Code of Ethics, the Quality Assurance Code, the Environmental Code, the Nissui Group Basic Procurement Policy, the Basic Information Security Policy and the method for using the whistle-blowing system. A Risk Management Month is set aside each year where, the members of each division take turns reading the Nissui Principles.
Additionally, Nissui conducts compliance seminars for its new employees, as well as conducting seminars on specific themes including personal scandals, the Subcontract Act and the Antimonopoly Act.
The Information Security Subcommittee is convened four times a year. Additionally, e-learning courses on information security are offered to employees are conducted for employees after which training on targeted email attacks and surveys to determine the level of comprehension of information security are conducted.