• Basic Approach
• Compliance Promotion System
• Compliance Management System
• Responses to compliance violations

Basic Approach

The Nitto Group is committed to the spirit of being “open, fair, and best” as stated in our Corporate Philosophy. As such, we conduct business activities with integrity, based on high ethical standards that always prioritize compliance, without being distracted by short-term gains.

• We abide by the laws of each country, including Japan, and respect their spirits and social norms.
• We engage in fair and free market competition based on competition laws.
• We do not engage in any form of bribery or corruption, including kickbacks.
  Furthermore, we do not use charitable or political contributions as a means of bribery, and we abide by relevant laws.
• We do not do business with inappropriate parties that may hurt the reputation of our company.
• We always conduct business correctly, following laws and common sense.

Business Conduct Guidelines

The Nitto Group Business Conduct Guidelines (hereinafter referred to as “BCG”) were published to guide everyone working for the Nitto Group around the world to share values and act ethically in compliance with laws and regulations in their business activities. We ensure that each and every member of the Group understands and thoroughly follows the guidelines, which have been translated into 18 languages so far.
Please follow the link for details.

Relationship between the Nitto Way and the BCG

The Nitto Way and the BCG are aimed at each and every officer and employee of the Nitto Group (directors, executive officers, employees, dispatched workers, part-timers, temporary workers, etc.).
The relationship between these two is that if The Nitto Way is a set of values that define a code of conduct to be practiced, the BCG ties the set of values to behavior standards.
Today, social rules consist not just of laws and regulations, but also of responses to society’s demands.
The Nitto Group discloses how it responds to these demands in the form of basic policies such as the Basic Policy on Sustainability.
In developing the BCG, we have observed these basic policies and incorporated them into the daily behaviors of each and every one of us.

Compliance Promotion System

The compliance department, established under the vice president for compliance, collaborates with the heads of various sites and Group companies to not only abide by laws but also engage in a variety of activities, such as ensuring respect for human rights. The compliance department carries out compliance promotion activities the BCG as a common standard for making decisions. The vice president for compliance addresses important matters by reporting them to higher management, e.g. at Corporate Strategy Meeting. Every effort is being made to ensure the early detection of legal violations and ethical issues by implementing a whistleblowing system available to all employees of the Group. For our business partners, the Partner Hotline is available for them to seek consultation on cases of noncompliance or suspected noncompliance involving transactions with the Nitto Group.

Whistle-Blowing System

The Nitto Group has established a system for monitoring the spread of compliance awareness with transparency. We have introduced and operated a whistle-blowing system for employees that allows them to file reports to both internal and external contacts.Discrimination and harassment incidents can be reported through this system.
The Partner Hotline, as it is called, is also available for business partners, including those from subcontracting businesses and construction services. Both contacts keep whistle-blowers’ privacy strictly confidential, and anonymous reports are allowed. Respondents handle the reports thus made in line with confidentiality obligations. The operational rules of the system stipulate that whistle-blowers should never be treated unfairly and that no threat or reprisal against them should be tolerated.

Compliance Management System

The Nitto Group operates a compliance management managed by compliance department in order to meet the expectations of society and continuously improve our compliance standards.
As the Nitto Group carries out a wide range of business activities around the world, the management system takes the following three points into consideration.

1. The need to balance independent management that fits the circumstances of specific regions and individual companies, and integrated management that is unified across the globe.
   • → Councils are established on three levels (global, region, site) and designed to share information.
2. The need to respond to internal and external environmental changes.
   • → Compliance risks are identified based on a wide range of information, such as results from self-evaluations, monitoring, employee surveys and changes to internal/external environments.
3. Continuous engagement is needed to improve compliance standards.
   • → The PDCA cycle (plan, do, check, act) is carried out on a fiscal-year basis at each level to continuously engage in risk reduction.
     (From identifying problems and proposing action policies to reviewing execution results)

Responses to compliance violations

If the officers or employees of the Nitto Group violate compliance, appropriate measures such as disciplinary actions are taken along with prompt corrective measures and recurrence prevention based on the laws of each country or the Nitto Group rules and the rules of each site. In addition, the Nitto Group discloses on our website any compliance violations that should be disclosed.”