We have group-wide guidelines to ensure that our conduct is not only compliant with laws and regulations, but highly ethical.
The NTT DATA Group Code of Conduct is a key part of the guiding principles expressed in Our Way and describes our basic principles and standards, such as what NTT DATA Group values in conducting its business, and the manner in which employees of NTT DATA Group should conduct business activities. NTT DATA Group aims to instill its Group Code of Conduct to all employees.
Enhancement of Compliance Program
NTT DATA Group strives to ensure compliance by instilling the NTT DATA Group Code of Conduct in its directors and employees, building a corporate culture that prioritizes compliance with laws, regulations and corporate ethics, and developing internal organizations and systems for such purposes.
These activities are reported and discussed at an annual meeting of the Compliance Committee, which is chaired by a member of the board of directors.
Implementation of compliance assessments
NTT DATA Group carries out compliance assessments for all employees to verify how well-established the compliance system has become, and to raise awareness.
Comparing the answers each year, potential issues are clarified, and used for making ethical conduct more thorough and for further strengthening legal compliance. For example, items identified as having higher potential risk may be prioritized for further investigation or be chosen as the theme of increased compliance training for the next fiscal year.
Operation of whistleblower systems to detect incidents in a timely manner
NTT DATA Group has put into place and operates the "Harassment Hotline" and the "Whistle Line", which are whistleblower systems that can receive consultations and reports from everyone who works with the NTT DATA Group, including employees and business partners. Through these whistleblower systems, violations of laws, regulations or corporate ethics can be detected at an early stage and be promptly addressed, for the purpose of maintaining sound management.
In practice, internal policies provide for privacy protection, protection against disadvantageous treatment, and confidentiality of whistleblowers, and consultations and questions are always accepted. A consultation desk for general human rights issues is set up in the HumanRights Awareness Office of the General Affairs Department. The results of investigations and the details of any remedial actions are reported to senior management executives and statutory auditors, and are utilized for sound corporate management.
In addition, we disclose the number of whistleblower reports and year-to-year statistics to group companies, and as necessary, based on an analysis of trends in similar compliance cases, we would introduce remarkable cases, raise awareness, and work to prevent recurrence.
Compliance Training and Awareness Building
Through various training programs, NTT DATA Group strives to improve the compliance awareness of our employees.
NTT DATA Group aims to thoroughly educate employees by strengthening the content of training materials, which are designed to solve problems in the workplace.
Efforts to instill understanding among employees
In addition to general compliance training (e-learning, etc.) for all group-wide employees, totaling more than 110,000 employees, NTT DATA Group also provides targeted compliance-related training according to the business characteristics of organizations and group companies, such as incorporating corporate ethics seminars into level-based training programs given at promotion milestones.
In addition, in light of the globalization of our business activities, we are working to enhance education such as by raising awareness of stricter laws and regulations against corruption and bribery in the international community and revision of the law related to subcontracting.
Furthermore, in order to instill deeper awareness of the NTT DATA Group Code of Conduct, we prepared and disseminated “NTT DATA Group Ethics Guideline - Based on Real Life Examples” which provides explanations in the context of hypothetical dilemmas that may arise in day-to-day work. Employees may refer to NTT DATA Group Ethics Guideline anytime through the intranet.