Compliance

With the understanding that compliance and legal compliance is a minimum requirement for a company to be acting “fairly” as expected by society, we have the following measures in place at our company.

Establishment of Internal Control and Audit Department

We have established the Internal Control and Audit Department, and this department is responsible for taking compliance-related measures, operating a helpline, developing basic policies and annual plans for internal control, and developing and implementing measures to maintain and improve the level of our internal control system.
This department also submits a periodic report to the Board of Directors on the status of development and implementation of the annual plan for internal control (Internal Control Plan), matters related to the management of ESG risks and other risks including sexual harassment, workplace bullying, and other human rights issues.

Establishment of a legal affairs section and preparation of internal rules and contract templates

We have established the Legal Affairs and Intellectual Property Department, and through this department we take necessary steps to respond to the implementation of new laws and the revision of existing laws applicable to our business, provide consultation concerning contracts and legal compliance related to day-to-day business, and take all other necessary steps in managing our company in strict compliance with the law. We also assign a person responsible for contracts and legal affairs to each section and subsidiary as a contact person with the Legal Affairs and Intellectual Property Department, enabling the smooth sharing and transmission of information within the company and the Group.
As our internal rules and contract templates reflect our legal compliance policy and contract guidelines and other guidelines are readily available, day-to-day work can be systematically and routinely performed efficiently and in compliance with the law.

Legal and contract education

We provide our employees with legal and contract education at the time they join the company, and they participate in group training sessions for specific qualification-based promotions, to inform them of our legal compliance policy and the need for legal compliance in business. We also offer lectures within the company whenever necessary due to the revision of applicable laws or business development.

Thorough management and education regarding intellectual property

Protecting our own intellectual property, and respecting other companies’ intellectual property is one of the important issues in doing business in the information service industry. The Legal Affairs and Intellectual Property Department maintains and manages our intellectual property based on rules stipulating ownership of rights to employee inventions, compensation for inventions, and other matters. It also provides consultation concerning patents, trademarks, copyright, and other intellectual property rights and addresses risks of infringement of intellectual property rights.
We take all possible means to protect and manage our intellectual property by continuously providing our employees with intellectual property training, including company-wide e-learning programs, training menus for each level of our employees, section-based training tailored to their respective operations, and various intellectual property guidelines.
We inform the entire company of our policy on the management of intellectual property through the person responsible for intellectual property in each section, and the person in charge of intellectual property of each subsidiary.

Internal Control Awareness Survey and e-learning

• We ensure through mandatory e-learning that all directors, officers, and employees of NSSOL Group companies have thorough knowledge of all important compliance matters related to our activities (such as violations of labor laws or laws related to procurement from contractors, bribery and corruption, and insider trading).
• Furthermore, we provide our business partners with compliance education tools.
• We distribute to all personnel the Global Code of Business Conduct, which is a code of conduct applicable to all directors, officers, and employees of the NSSOL Group, and they carry it with them at all times.
• We identify potential human rights risks through an annual internal control awareness survey of employees, and give feedback to employees based on the result.

Establishment and operation of a helpline

In 2003, we established a Compliance Desk, and in April 2006, in light of the enforcement of the Whistleblower Protection Act, we upgraded it to a helpline and established a new external contact point. Since April 2008, the helpline has been in operation as a contact point for consultation and reporting of human rights violations, including harassment. Currently, the helpline accepts reports and consultations from employees of the Group and their family members, and their privacy is protected by anonymity unless approved by the individual.

Image of helpline system

Internal Audit

At our company, the Audit Office established within the Internal Control and Audit Department is the section responsible for internal audits. This Office prepares important audit topics and conducts annually both desk audits and field audits using a checklist. Once an audit is completed, they prepare a report containing audit findings and recommendations and submit it to the President. To ensure that we operate our business in a more appropriate manner, audit findings and recommendations are followed up as to how they are dealt with.

The NSSOL Group explicitly states in its Anti-Bribery Rules that all directors, officers, and employees are prohibited from giving bribes to public officials of any governmental agencies in or outside Japan (including so-called deemed public officials, such as directors, officers or employees of certain corporations and organizations), or performing any other acts in violation of laws and regulations. The Anti-Bribery Rules also provide that even if no law or regulation is violated, any gifts, business entertainment, etc. offered to individuals other than public officials must be kept within reasonable bounds according to social norms.
The Anti-bribery Guidelines of the Nippon Steel Group are also made available on NSSOL’s corporate portal site so that all directors, officers, and employees can check the details of these guidelines at any time as they conduct business operations.
Also, in an e-learning program that all directors, officers, and employees of the NSSOL Group are required to take, prevention of bribery and corruption is identified as a compliance priority in corporate activities and a matter that must be thoroughly observed.
Under the Purpose of “Dream our future, unleash the possibilities of society, with technology and passion,” the NSSOL Group has established the Global Code of Business Conduct and requires all directors, officers, and employees to abide by this code of conduct and prevent bribery.

Code of Conduct

In the Global Code of Business Conduct as well, the NSSOL Group provides as follows regarding the prevention of bribery.
We promote fair and free competition and ensure that our transactions are appropriate. We maintain healthy and fair relationships with political and administrative bodies and business partners.

• No bribes to public officials in or outside Japan; Anti-corruption
  We do not offer, promise or propose to offer business entertainment, gifts or other favors to public officials of any governmental agencies in or outside Japan (including so-called deemed public officials, such as directors, officers or employees of certain corporations and organizations), in an attempt to reap illicit benefits in connection with such public officials’ duties. We are in compliance with all laws, rules, and regulations applicable to us concerning our relationships with political and administrative bodies. There have been no investigations conducted or penalties imposed on us in the past that are related to unfair or corrupt practices.
  (No political contributions were made in FY2022.)
• Proper supervision of Partners
  We exercise proper supervision over our Partners to ensure that no bribes are offered indirectly through our Partners. When we select a Partner who may come into contact with a public official in connection with our business, we make efforts to have the Partner pledge, represent and warrant that it will comply with anti-bribery laws and regulations. Our agreements with such Partners shall be designed to prevent any bribery-like behaviors, through the provisions related to specific scope of work to be performed, monetary compensation for the work to be rendered and other terms and conditions.
• Restrictions on excessive business entertainment and gifts offered to or received from private-sector partners
  Business entertainment and gifts to and from private-sector partners shall be offered in accordance with the laws and regulations of each country, limited to the extent considered reasonable according to social norms and in an appropriate and common-sense manner, and we shall not offer or accept excessive business entertainment or gifts beyond such bounds.

Addressing Bribery Risks

The NSSOL Group has established the Anti-Bribery Rules as a measure against bribery risks. Some of the key provisions of these rules are shown below.

• Anyone who works for the NSSOL Group shall not offer, promise or propose to offer gifts to public officials in Japan in connection with their duties.
• Anyone who works for the NSSOL Group shall not offer, promise or propose to offer gifts to foreign public officials with the aim of reaping illicit commercial benefits in connection with their duties.
• Anyone who works for the NSSOL Group shall not offer gifts, business entertainment or any other benefits to individuals other than public officials (including but not limited to customers, partners, and vendors; hereinafter the same) in violation of laws and regulations in or outside Japan, or receive gifts, business entertainment or any other benefits from individuals other than public officials. Even if no law or regulation in or outside Japan is violated, any gifts, business entertainment or any other benefits offered to or received from individuals other than public officials must be kept within reasonable bounds according to social norms.
• The compliance promotion system within the NSSOL Group for preventing bribery shall be created and executed as part of the PDCA cycle for routine internal control provided in the Basic Rules for Internal Control.
• We operate a whistleblowing system appropriately by establishing a helpline to serve as a whistleblowing contact point for receiving reports and consultations on acts that violate the Anti-Bribery Rules.
• Employees who have violated the Anti-Bribery Rules are subject to disciplinary action according to the Employment Regulations and other rules.

Information Assets Protection Policy

We are taking positive action to protect information assets by, among other means, establishing the “Basic Policy for Information Asset Protection” and “Personal Information Protection Policy” applicable to all Group companies, providing all of our members including contractors with information assets protection education, and conducting periodic information assets protection audits.

Acquisition of Privacy Mark

“Privacy Mark” certification was granted to our company in February 1999, and has been renewed every two years. This certification was also granted to many of our subsidiaries by September 2008. In December 2001, we acquired both domestic and international information security management system certifications (two certifications: ISMS and BS7799) for the information system operation service at our data centers.

• Privacy Mark