Preamble

To Be a Trusted Company

Trust by customers, shareholders, suppliers and the societies is indispensable for a company to sustainably grow. A company can be trusted upon by being aware of its social responsibility (“CSR”) and by fulfilling the expectation of, and enhancing the satisfaction of, customers and other stakeholders through good dialogues.

We also believe that it is fundamental to gain trust not only by complying with laws, regulations and agreements but also by respecting various international norms, including human rights, acting with good moral and integrity, and performing fair and transparent business activities.

Furthermore, our mission is to create new “mechanisms” and “values” with IT and to materialize more affluent and harmonious societies, and we aim to resolve the issues that the earth and societies are facing.

With these in mind, everyone at NTT DATA will act in accordance with this “Global Compliance Policy” and we all do our utmost to be a trusted company.

Application

All directors, officers and employees shall fully understand this Global Compliance Policy, and act as follows to achieve its purposes. Directors and officers shall take their initiatives and exert to cultivate the high morals in employees.

Principles

We will:

  • Comply with all relevant laws and regulations of the jurisdictions where we do business, including international laws, and act in accordance with good integrity.
  • Be aware of our corporate social responsibility, and perform fair and transparent business activities.

For Customers

We will:

  • Execute appropriate agreements with our customers, and provide systems and services pursuant to the agreement.
  • Thoroughly manage customer information in accordance with the agreements, relevant laws and regulations related to the protection of personal data.

For Shareholders

We will:

  • Undertake sound corporate management and strive to increase the interests of our shareholders.
  • Timely and appropriately disclose management information in order to perform transparent management.

To Competitors

We will:

  • Restrict ourselves from performing any acts that would impede market competition, including defamation, dumping, cartels, and other unfair/anti-competitive conducts, and perform fair and free competition.
  • Protect our own intellectual properties and respect the same of others.

To Suppliers

We will:

  • Act with integrity without abusing a superior position.
  • Comply with relevant laws and regulations applicable to transactions with suppliers, and observe agreements with suppliers.

To Government

We will:

  • Not provide any gift or hospitality against our policy or applicable laws, nor conduct any act that would be suspected of corruption.
  • Not be involved in any bribery with government officials in any manner and in any jurisdiction.

To Society

We will:

  • Actively undertake social contribution, such as volunteering or other community activities, to fulfill our responsibility as a good corporate citizen.
  • Respect the diversity of cultures and values, and contribute to the development of societies where we do businesses.
  • Refuse to do any business with anti-social forces.

To the Environment

We will:

  • Propose IT systems and solutions to contribute to the reduction of the environmental load.
  • Strive to reduce the environmental load caused by our business operations.
  • Increase our awareness of biodiversity, and undertake activities to protect the natural environment.
  • Observe laws and regulations related to the environment.

To Employees & Co-workers

We will:

  • Respect the individuality and personality of our people.
  • Respect human rights and will not discriminate based on gender, nationality, belief or religion.
  • Not commit any harassment.
  • Maintain fair and equal treatment of employees and provide employment opportunities on the basis of individual merit, in a working environment safe, secure, and free of violence, drugs or child labor.

As Employees

Each employee will:

  • Ensure that information security be maintained and not conduct any privacy infringement, unauthorized access and other unlawful acts.
  • Observe the company policies and not engage in any act that conflicts with the interests of the company or that provides personal gain to the detriment of the company.
  • Not engage in insider trading in any manner.
  • Not provide or receive any gifts or hospitality against our policy from/to customers, suppliers or business partners.
  • Not post to any social media any confidential or proprietary information or any message that harms the trust or rights of any parties.
  • Promptly report any breach or suspected breach of this policy or other unlawful act to your manager, local compliance officer, or whistle blowing line where appropriate. The company will not make any retaliation to those who made good faith reporting through the whistle line.