Compliance
Japanese
Charter of Corporate Behavior and Code of Conduct
NEC believes that compliance is essential for a company to coexist with society and fulfill the expectations of stakeholders. The NEC Group Charter of Corporate Behavior sets forth key corporate activities required of members of the
NEC Group from the perspective of fulfilling the NEC Group’s social responsibilities. Furthermore, the
NEC Group Code of Conduct specifies the behavior expected of each and every officer and employee of the NEC Group. The NEC Group Charter of Corporate Behavior and the NEC Group Code of Conduct are positioned as the foundation of all of NEC’s business activities.
The NEC Group Charter of Corporate Behavior and the NEC Group Code of Conduct have been established at all consolidated subsidiaries in Japan and overseas, with the same content at every location.
Framework
To achieve thorough compliance with the corporate ethics described in the NEC Group Charter of Corporate Behavior and the NEC Group Code of Conduct, a variety of organizations and people within NEC work closely together. They include the Risk Control and Compliance Committee, the Internal Control Division, Risk Control and Compliance Promoters, and the Corporate Auditing Bureau.
- The Risk Control and Compliance Committee, whose members are officers, investigates the underlying causes of serious compliance breaches, studies related preventive measures, and discusses policies for risk management activities and measures to address priority risks.
- The Internal Control Division has two primary functions: providing the necessary support, coordination and instructions to ensure that risk management is implemented systematically and effectively across the Company; and ensuring thorough compliance within the NEC Group. In regard to compliance promotion, NEC Corporation has specifically designated employees in corporate staff and other divisions specializing in matters described in the NEC Group Code of Conduct as concurrent assignment staff in order to assist the Internal Control Division. Through meetings on a variety of occasions, the Internal Control Division and these concurrent assignment staff exchange opinions on planning and implementing various measures to raise internal awareness of the NEC Group Code of Conduct.
- The Risk Control and Compliance Promoter system is designed to ensure compliance among all NEC Group employees. Risk Control and Compliance Promoters assigned to business divisions (381 people*) and NEC Group companies in Japan (135 people*) serve as points of contact for the Internal Control Division.
(As of April 30, 2011)
- The Corporate Auditing Bureau is an internal auditing division that performs internal audits to check that there are no problems in the execution of business operations from the viewpoints of accounting and legal compliance.
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