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Compliance

The NTT Group runs its businesses in compliance with its Corporate Ethics Charter

Recognizing that it is imperative to conduct business in compliance with laws and regulations, and maintain high ethical standards in order to promote sound corporate activities, NTT drew up the NTT Group Corporate Ethics Charter in November 2002.

The charter, which applies to all officers and employees of the NTT Group, lays out the basic principles of corporate ethics and provides specific guidelines for ethical behavior. The stipulations in the guidelines are intended to remind everyone of their duty as members of a telecommunications group that bears significant responsibility to society in terms of preventing dishonesty, misconduct, and the disclosure of corporate secrets, as well as refraining from exchanging excessive favors with customers and suppliers, and ensuring that they conduct themselves according to the highest ethical standards in both private and public activities.

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NTT Group Corporate Ethics Charter

  1. Recognizing the establishment of corporate ethics as one of its most important missions, top management shall exert its leadership to ensure that the spirit of this Charter is adopted throughout the Company, and shall assume full responsibility for solving any problems when any event inconsistent with that spirit occurs.
  2. Every person with subordinate employees shall not only act in a self-disciplined manner, but shall also always provide guidance and assistance to his/her subordinate staff to ensure that their conduct is in conformity with our corporate ethics.
  3. Every officer and employee of the NTT Group shall not only comply with all laws and regulations, social standards, and internal company rules whether in Japan or overseas, but officers and employees shall also hold the highest ethical philosophy within himself/herself both in public and in any private situations. Among other things, each officer and employee, as an officer or employee of a member of a Global Information Sharing Corporate Group, shall keep himself/herself fully aware that any disclosure of customer or other internal privileged information constitutes a materially wrongful act. Also, as a member of a group of companies which holds great social responsibilities, he/she shall strictly refrain from giving or receiving from customers, business partners, and other interested parties excessive gratuities.
  4. Each NTT Group company, at the first opportunity, shall take initiatives to provide training programs in order to help its officers and employees enhance their awareness of our corporate ethics.
  5. Every officer and employee of the NTT Group shall direct his/her efforts to prevent wrongful or scandalous acts which may potentially occur as specialization and advancement of our business proceeds. Each NTT Group company shall improve its system to prevent such acts, including, for instance, the re-assignment of contract representatives who have remained with the same customers for a long period of time, and the improvement of monitoring tools to protect customer and other information.
  6. Any officer or employee who may come to know of the occurrence of any wrongful act or any scandal shall promptly report the wrongful act or scandal to his/her superior or other appropriate persons. If he/she is not able to make such a reporting, he/she may contact the "Corporate Ethics Help Line (Contact Point)." It should be noted that every officer and employee who reports the occurrence of any wrongful act or scandal shall be protected so that the reporting party shall not suffer any negative consequences due to such reporting.
  7. In the event of an occurrence of any wrongful act or scandal, each NTT Group company shall be committed to the settlement of the problem by taking appropriate steps through a speedy and accurate fact finding process, and responding in a timely, suitable, and transparent manner in order to fulfill its social accountability.

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Initiatives to Promote Awareness of the NTT Group Corporate Ethics Charter

Corporate ethics website for employees

To instill the NTT Group Corporate Ethics Charter in all Group companies, NTT Group companies offer training sessions on corporate ethics to employees. In addition, the NTT Group Corporate Ethics Charter and examples of corporate ethics issues are explained in detail on a website for employees, and employees are reminded of the importance of ethics in June and December each year. In these ways, NTT is working to enhance the understanding of employees. Furthermore, NTT conducts annual surveys of employees to measure their awareness, and the results are then used for awareness enhancement initiatives.

Training

We strongly prohibit bribery of any kind, including facilitation payments. For the purpose of employee training we use our anti-bribery handbook which includes basic knowledge and case studies of bribery and facilitation payments. In addition, on a website for employees, examples of corporate ethics issues are explained in detail.

(PDF file will open)Anti-Bribery Handbook (a table of content)

Corporate ethics training is conducted as part of continuous educational activities for all officers and employees. This training is tailored to meet the specific compliance and corruption risks of each company throughout the NTT Group. In addition, corporate ethics awareness surveys are conducted on an annual basis to improve and reinforce internal checks. This includes anti-bribery training of employees, and ensuring that they conduct themselves according to the highest ethical standards in both private and public activities.

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Anti-Corruption towards zero tolerance of corruption

NTT demands that all our employees meet the highest ethical standards, and we have a zero-tolerance approach to corruption. The below framework sets out how we implement this.

NTT Group Approach to Corporate Ethics & Risk of Corruption

We have a zero tolerance approach to corruption. We strongly prohibit bribery of any kind, including facilitation payments.

Our Corporate Ethics Charter demands that every officer and employee of the NTT Group shall not only comply with all laws and regulations, social standards, and internal company rules whether in Japan or overseas, but officers and employees shall also hold the highest ethical philosophy within themselves both in public and in any private situations.

Internal Control System & Risk Assessment

Our Corporate Ethics Committee, chaired by a Senior Executive Vice President serving on the Board of Directors, is responsible for raising awareness concerning compliance, maintaining corporate discipline, and conducting investigations concerning reports of misconduct.

Within each subsidiary, there is also a senior management person responsible for assessing risk of corruption, and mitigating this risk.

Establishment of Corporate Ethics Help Line Contact Point

To prevent illegal conduct or a scandal, each Group company has set up an internal consulting center. In addition, NTT has established the Corporate Ethics Help Line as an external contact point and outsources its operation to a law firm.
The help line also handles consultations and reports related to human rights issues. The NTT Group Corporate Ethics Charter clearly states that people who file reports with these help lines are protected from any disadvantage arising from the fact that they filed a report. The content of the consultations and reports are investigated and handled by the staff member in charge, and a report is submitted to the Corporate Ethics Committee of each Group company. All reports are collected at least once a year by NTT, where the response status is ascertained and reported to the Board of Directors.

Number of Reports

The Whistleblowing Mechanism Guidelines , revised in December 2016 by the Consumer Affairs Agency, recommend that neutral and fair third-party assessments be carried out. We had such an assessment carried out in May 2017 and received the comment that overall, a whistleblowing mechanism is in place and is being administered appropriately.

Details of assessment

  • 1. Investigation of the mechanism and operational status of the help line in order to verify its effectiveness in terms of utilization and reliability.
  • 2. Sample survey on the establishment of regulations and responses to whistleblowers, etc.
  • 3. Confirmation of compliance with the Whistleblowing Mechanism Guidelines.
  • 4. Interviews with administrators and discussion about operational issues.

Going forward, we will continue to administer the help line in an appropriate manner.

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