Basic Concept
The Nisshinbo Group is working to establish corporate governance based on its corporate philosophy to ensure sustainable growth and enhance corporate value.
Also, the Nisshinbo Group included "Thorough-Going Compliance" in its Business Conduct Guidelines, which clearly states that the Group will act in constant fairness and sincerity across a broad range of issues, respecting social norms and corporate ethics, and in addition to establishing a system, will provide education to all employees.
Promotion System
Nisshinbo Holdings Inc. reorganized its organizational structure in April 2025 to establish a Managing Officer system for each functional division with the aim of building and overseeing a structure that would lead to urgent change. Under the leadership of the Managing Officer in charge of the Legal & IP Department, the Legal Group now leads activities to promote thorough compliance and corporate philosophy. In addition, based on the "Nisshinbo Group Code of Corporate Ethics," the Company has established a "corporate ethics committee" as an organization directly under the president and the director, with the president as the chief officer for corporate ethics, to handle matters related to compliance throughout the Nisshinbo Group. Business Ethics Committee members are appointed from among managers at the level of section chief or above.
Moreover, the Nisshinbo Group also established a "Corporate Ethics Reporting System" for the purpose of early detection of suspected violations of laws and regulations and the prevention of recurrence of such violations and has put in place a system to receive reports from both inside and outside the company. The Group employees can file reports directly with internal Corporate Ethics Committee members as well as to outside counsel. The Group strictly protects the confidentiality of whistleblowers and takes care not to cause any disadvantage to whistleblowers. The Corporate Ethics Committee takes appropriate action in response to the content of the report.
For an overview of our organizational structure for promoting sustainability, please see "Promotion System for Sustainability Activity".
Specific Initiatives of The Nisshinbo Group
5th Sustainability Promotion Plan (to be achieved by FY2024)
In the 5th Sustainability Promotion Plan with FY2024 as the target year, the Nisshinbo Group set the following two items as targets and KPIs to ensure thorough compliance as a priority activity and achieve the goals of Raising awareness of compliance and operating the corporate ethics reporting systems.
- ① Rate of compliance training participation by management-level personnel, 100%
- ② Response rate to corporate ethics reporting system, 100%
We promoted activities such as compliance education, thorough confidentiality measures, and the establishment of a corporate ethics reporting system, achieving a participation rate of 99.4% for ① and appropriate responses (100%) for ②.
6th Sustainability Promotion Plan (to be achieved by FY2027)
In the 6th Sustainability Promotion Plan, which targets FY2027, the Nisshinbo Group will continue to focus on ensuring thorough compliance and will set the following two goals to achieve Raising awareness of compliance and operating the corporate ethics reporting systems.
- ① Rate of compliance training participation by management-level personnel, 100%
- ② Response rate to corporate ethics reporting system, 100%
Nisshinbo will enhance its activities through regular compliance training to raise awareness of the importance of compliance and by continuing to respond appropriately to reports.
Please refer to "Sustainability Promotion Plan and KPIs" for details regarding of the "Sustainability Promotion Plan."
Compliance Training
In order to ensure fair and honest business practices, the Nisshinbo Group conducts a variety of compliance training, such as training for different employee levels and work sites and training for employees who will receive assignments abroad.
New educational videos are released and repeated every year through the Learning Management System introduced in 2021. In FY2024, Nisshinbo conducted two compliance training sessions and released new videos to further strengthen governance and raise ethical awareness.
- ・For all group employees: Basic knowledge of compliance, importance of preventing misconduct, etc.
- ・For all group managers: Role of managers in compliance and other measures
In addition to the Japanese version, the English and Chinese versions of the above video were prepared and distributed to overseas group companies.
In FY2024, Nisshinbo distributed four videos as part of its export control training. One was an educational video for general employees, which was updated in line with the latest laws and regulations to ensure that all employees of the Group in Japan have a basic understanding of export control. The other three videos were specialized training videos for export control personnel, which were also updated in line with the latest laws and regulations, focusing mainly on points to note when determining whether an item is subject to export control and when applying special measures.
Furthermore, in response to the growing global focus on economic security, which has led to strengthened export control regulations both domestically and internationally, Nisshinbo compiles and distributes monthly updates on regulatory information and other relevant topics through each business company within the group.
Anticorruption Efforts
In recent years, international legislation on bribery and corrupt practices have been strengthened, and detection has grown more rigorous. Nisshinbo Holdings Inc. formulated the "Guide to Prevent Corruption" in response to related legislation in other countries. The Group has rolled out the guide across the Group, including all subsidiaries in other countries. This guide encompasses Article 18 of Japan's Unfair Competition Prevention Act (Prohibition to Provide Illicit Gain, etc. to Foreign Public Officers, etc.), the United Nations Convention against Corruption (UNCAC), the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions, the United States Foreign Corrupt Practices Act (FCPA) and related guidelines, and the United Kingdom Bribery Act, Unfair Competition Prevention Law of the People's Republic of China, and other international anti-corruption treaties and laws, including criminal laws and anti-corruption laws in Asian countries. The contents of the handbook were revised in 2024 and are being used throughout the entire group as measures to prevent bribery.
Adhering Strictly to a Policy of Confidentiality
The Group has entered into confidentiality agreements with its partners to prevent leaks of intellectual property, technology and expertise disclosed throughout the supply chain from the design and development stages. To ensure appropriate trade secrets management, the Group conducts annual internal audits.
Corporate Ethics Reporting System
Guided by its Corporate Philosophy, the Nisshinbo Group endeavors to instill and firmly establish corporate ethics among all employees in all aspects of its business activities. The Group has established a "Corporate Ethics Reporting System" with the aim of promptly discovering and preventing violations of laws and regulations and alleged violations of corporate ethics.
This system accepts reports not only from employees of the Group but also from a wide range of stakeholders inside and outside the company. Employees who become aware of any violation of laws or corporate ethics by the Group, or of any conduct that raises suspicions of such violation, are advised seek consultation and report the matter. The Group will respond appropriately after investigating the facts. Concerned parties are free to consult and report anonymously; however, if they leave a name and contact information, the Group will contact them with an outline of countermeasures.
Group employees can file reports directly with internal Corporate Ethics Committee members as well as to outside counsel. The Group strictly protects the confidentiality of whistleblowers and takes care not to cause any disadvantage to whistleblowers.
Compliance-related matters for the entire Nisshinbo Group are addressed by the "Corporate Ethics Committee," which reports directly to its president. The Board of Directors receives and reviews periodic reports on important matters related to corporate ethics, including whistleblowing matters.
In the future also, through such sincere efforts, the Nisshinbo Group will strive to fulfill its social responsibility as a company and further enhance its corporate value.
Contact for consultation and report
Reception Desk, Corporate Ethics Committee
fax:+81-3-5695-8851
Number of Compliance Violations and Corporate Ethics Reports
The number of reports made to the Corporate Ethics Reporting Desk of Nisshinbo Holdings Inc. in the past three years is as follows. The Corporate Ethics Committee responds to all reports appropriately, while ensuring that confidentiality is strictly maintained and that the whistleblower is not disadvantaged. If a violation is found, the whistleblower will be punished in accordance with the Company's employment regulations.
Corporate Ethics Reporting Desk Number of Reports
| 2022 | 2023 | 2024 | ||||
|---|---|---|---|---|---|---|
| The number of cases | Disciplinary action for facts | The number of cases | Disciplinary action for facts | The number of cases | Disciplinary action for facts | |
| Harassment Related | 3(3) | 0 | 3(1) | 0 | 3(1) | 0 |
| Violation of Law | 3(0) | 0 | 0(0) | 0 | 5(0) | 0 |
| Labor Issues | 2(1) | 0 | 1(1) | 0 | 4(2) | 0 |
| Accounting Irregularities | 1(0) | 0 | 0(0) | 0 | 0(0) | 0 |
| Others (Moral Violations, etc.) | 8(2) | 0 | 7(2) | Disciplinary Action 1 | 8(2) | 0 |
| Total number of reports | 17 | — | 11 | — | 20 | — |
| Total number of reports handled by the committee | 17(6) 100%Responded |
— | 11(4) 100%Responded |
— | 20(5) 100%Responded |
— |
* The number of reports in parentheses is the number of confirmed violations and other specific facts.
Specific Activities of the Group Companies
Implementation of Compliance Training
Japan Radio Co., Ltd., provides annual e-learning training on JRC Code of Conduct and Compliance as part of its compliance education program. The training incorporates actual violations and is repeated annually with updated information. Japan Radio also provides training for compliance leaders appointed from each department. Divided into sales and non-sales departments, lawyers serve as instructors and cover such topics as past cases of legal violations and current cases.
In FY2024, the company conducted training specifically focused on harassment as a measure to prevent harassment, which is on the rise. After watching a video on power harassment in the workplace, the company administered an e-learning test to assess understanding. Participants commented that their awareness of harassment had increased, and they were able to raise compliance awareness.
Japan Radio Co., Ltd. will continue to promote initiatives to ensure that each and every employee acts in compliance with the law.
Implementation of Workplace Ethics Activities
HYS Engineering Service Inc. designated November 2024 as Corporate Ethics Month and conducted workplace ethics activities for all employees as part of its efforts to further enhance corporate ethics and ensure strict compliance with laws and regulations. A total of 578 employees participated. Based on examples unrelated to harassment that are relevant to each department, such as harassment cases, appropriate transactions, and compliance with anti-bribery laws, the company conducted workplace-based discussions to identify whether risks similar to those in the examples exist in the workplace and how to address them through brainstorming.
HYS Engineering Service Inc. shares the issues and risks identified through discussions and implements and promotes the measures and action items decided upon in each workplace.
Through these initiatives, the company will promote the execution of business based on ethical conduct in each workplace and among each individual, raise awareness of this conduct, create an open and cheerful workplace environment, and build a corporate culture filled with passion, reason, and compassion.
Operation of the Corporate Ethics Reporting System
At Nisshinbo Mechatronics（Shanghai）Co., Ltd. in China, the general manager serves as the chief ethics officer, and the Corporate Ethics Committee, which reports directly to the general manager, has been established to address compliance-related matters within the company.
In addition, Nisshinbo Mechatronics（Shanghai）Co., Ltd. established a corporate ethics reporting system to detect suspected violations of laws and regulations and to prevent their recurrence and then put in place a system to receive reports from both inside and outside the company. In addition to the Corporate Ethics Committee, employees can also report directly to external legal advisors. Confidentiality regarding the identity of the reporter will be strictly maintained, and care will be taken to ensure that no disadvantage is caused to the reporter. Reports will be appropriately handled by the Corporate Ethics Committee, and feedback will be provided to the reporter.
The corporate ethics reporting system is communicated to all employees through internal notices and training upon joining the company.