Compliance Office

Teruhiko Yoshida, Yutaka Inazu, Koichi Nabeta

Introduction

 Based on the reflection on the successive employee bribery cases that occurred in 2022 and 2023, the NCC issued a notice dated March 29, 2024, titled "Implementation of Reforms to Strengthen Compliance, etc." Based on this, the structure of the Compliance Office (hereinafter referred to as the "Office") was significantly strengthened in April, and the number of members increased from one to three. The Office planned and implemented the following measures with the aim of improving the awareness of legal compliance throughout the organization and promoting sound business operations.

(1) Establishment of "Compliance Promotion Regulations"

 In September 2024, we established the "Compliance Promotion Regulations," clarifying the basic policies for compliance promotion, promotion systems, and specific activity policies.

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(2) Holding of compliance promotion meetings

 In November 2024, the "Compliance Promotion Meeting" was held for managers of each department. At the meeting, the promotion system was explained and specific promotion measures scheduled for implementation within FY2024 were discussed, establishing a foundation for promoting compliance throughout the NCC.

(3) Implementation of compliance questionnaires

 To assess employees' awareness of compliance and identify future issues, we conducted an anonymous questionnaire for all employees in December 2024, analyzed the response results, provided feedback to the compliance officer, and shared issues that need to be addressed in the future.

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(4) Implementation of compliance training

 In January 2025, we conducted a compliance training with the aim of fostering awareness of compliance promotion among employees. The training provided an opportunity to learn about the importance of promoting compliance as “deemed public servants” and the basics of risk management by providing practical examples, and the training was well received.

Future Prospects

 In the future, we will work to verify the effectiveness of measures to prevent recurrence of past bribery cases, and as part of reforming the awareness of officers and employees, we will formulate a "Code of Conduct" for all employees centered on compliance, establish a consultation desk to receive consultations and questions about compliance, plan and implement training programs, and review methods for disseminating laws and regulations and NCC regulations. We will develop various measures to establish an organizational culture that values compliance.