It is imperative to conduct business in compliance with laws and regulations in the jurisdictions where we operate, and maintain high ethical standards in order to promote sound corporate activities. Recognizing this, 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.
The NTT Group has established the NTT Group Corporate Ethics Charter, which mandates compliance with all laws and regulations, social standards, and internal company rules whether in Japan or overseas. With regard to the prevention of bribery, we have prepared an Anti-Bribery Handbook containing important matters to be understood and complied with by our employees. The contents of this handbook are made known to all employees in Japan and overseas through emails and other means.
In addition, NTT, NTT East and NTT West stipulate that bribery is forbidden under the Act on Nippon Telegraph and Telephone Corporation, etc. (hereafter “the NTT ACT”) and that breaches are punishable by law. Following the Act on Prevention of Unjust Acts by Organized Crime Groups, contributions and other types of support are only given to charitable organizations deemed suitable by the NTT Group. We have a zero tolerance approach to corruption.
The NTT Group has adhered to the Anti-Monopoly Act to ensure its business activities align with a fair and competitive business environment. These initiatives have been effective, as evidenced by the fact that we have never been fined for violation of anti-monopoly regulations.
At NTT, top management demonstrates that compliance requires the NTT Group to comply with laws and conduct
business, with everyone having strong ethics. Also, the presidents of each NTT Group company have declared their
commitment to identify risks related to illegal or illicit activities and never tolerate any form of impropriety. To ensure the
effectiveness of the NTT Group Corporate Ethics Charter, we offer training sessions on corporate ethics to employees, and
through a website for employees, we explain the declaration in detail and give examples of corporate ethics issues.
Employees are reminded of the importance of ethics in June and December each year in an effort to raise their level of understanding. Furthermore, NTT conducts annual surveys of employees to measure their awareness, and the results are then used for awareness enhancement initiatives.
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.
Furthermore, training for officers is also conducted every year.
As a tool to help employees prevent corruption, we created the new Anti-Bribery Handbook in fiscal 2015, which is made known to all employees at NTT Group companies inside and outside of Japan through emails and other means. Along with a message from the president, the Anti-Bribery Handbook provides examples regarding the basics of bribery and facilitation payments to instill correct knowledge and understanding in all employees.
In FY2019 we made our “Competition Law Handbook” as a tool to spread compliance to competition law among employees, and notified Group companies both in Japan and overseas of the availability of this handbook. In this handbook we use actual scenes from sales activities as examples and write basic matters for complying with competition law in a Q&A format. This is how we are enabling our employees to have proper knowledge and understanding of competition law and comply with it.
NTT conducts an annual survey that includes NTT Group companies in order to ascertain the extent to which employees are aware of compliance. At each NTT Group company, monitoring is performed under four different functions, comprising the departments in charge of business operations, compliance and internal auditing, as well as the Audit and Supervisory Board members, to ensure neutral and multifaceted checks are being performed.
NTT checks the status of compliance audit implementation at NTT Group companies with an internal auditing department and directly confirms the status of compliance initiatives inside NTT and at NTT Group companies without an internal auditing department. In fiscal 2017, these checks were performed on 18 NTT Group companies, including NTT.
To prevent illegal conduct or a scandal, each Group company has set up an internal consulting center to handle reports of inproper activities. In addition, NTT has established the Corporate Ethics Help Line as an external contact point for NTT Group companies and outsources its operation to a law firm. The help line also handles consultations and reports related to human rights issues (see page 102). The NTT Group Corporate Ethics Charter clearly states that people who file reports with these help lines will be 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.
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.
A compliance violation or breach of the NTT Group Corporate Ethics Charter is dealt with using the disciplinary measures taken in accordance with the disciplinary code established at each Group company. This includes pay cuts and work suspension, and may also be reflected in assessments (evaluations) and personnel transfers.