Compliance

Basic Policy

NEG defines compliance with reference to “business activities conducted in good faith that not only comply with laws and regulations but also with the spirit behind such laws (sense of values and ethics required by society).” To ensure legal and ethical compliance practices, we have implemented the corporate motto of “activities in good faith” for the entire NEG Group.

Compliance System

In order to continuously ensure corporate ethics and legal compliance by NEG and the NEG Group, a compliance committee has been established as a special organization. This compliance committee is responsible for the following issues:

  • Drafting revisions to “Corporate Philosophy,” “The Group Code of Conduct,” and “Principles of Activities”
  • Gathering and analyzing information on compliance and providing compliance training
  • Operating an internal reporting system

Compliance Program

“The Group Code of Conduct” and “Principles of Activities”

The “The Group Code of Conduct” and “Principles of Activities” were both fully revised in 2006 to ensure compliance awareness. Such material, along with information on management philosophy and an outline of our internal reporting system, was printed on pocket-sized cards and distributed to all employees.

Internal Reporting System

In January 2006, NEG established an internal reporting system to prevent, detect early, and swiftly resolve any legal violations, fraudulent activities, or forms of unethical conduct. Internal (compliance committee) and external (law firm) call centers have been established where people can consult or report legal or corporate ethics violations as well as questionable acts. We are taking extreme care to protect the interests of callers and will continuously work to keep our employees aware of this system and ensure its effective use.

Case Studies for “Principles of Activities”

Once a month, written material listing common potential forms of noncompliance are distributed throughout the NEG Group. This helps employees become aware of possible compliance violations and enables continuous education regarding compliance-related matters.

Compliance Awareness Month

Starting from 2006, NEG has designated October as compliance awareness month. During such time, the Company hosts lectures, implements compliance training, and issues posters throughout its office and plants.

Compliance Training Seminars

All NEG Group employees are kept thoroughly informed of their compliance obligations through a proactive compliance training program. In addition to an annual training regime featuring new-employee orientation and anti-trust law seminars for sales staff, we hold compliance seminars for Japanese personnel and local managers at our overseas subsidiaries every year from 2015.

Statement

The Company has asked all its employees to submit a signed statement promising to comply with NEG’s Principles of Activities. We believe this will renew their recognition for the importance of compliance. We have also created opportunities for our employees to reread the code of conduct and to reexamine their daily business activities from a compliance standpoint.

Modern Slavery Act Transparency Statement

NEG has prepared its “Modern Slavery Act Transparency Statement for Fiscal 2016” pursuant to the requirements of United Kingdom’s Modern Slavery Act 2015 to measure to prevent slavery, human trafficking, and other violation of human right in its businesses and supply chains as follows; Modern Slavery Act Transparency Statement for Fiscal 2016 (PDF 109KB)