Declaration of Engagement in Accordance with the Corporate Compliance and Moral Code
NJS Consultants Co., Ltd. (hereinafter called “NJSC”) hereby declares its intention to act in full compliance with the Corporate Compliance and Moral Code that it has set in force.
NJS CONSULTANTS CO., LTD. COMPLIANCE DECLARATION
- We strictly adhere to rules of society and abide by it thoroughly.
- We do not seek profits using devious method.
- We observe rules and norms of society. This is common practice, but we abide by this thoroughly. We constantly observe applicable rules, work in good faith and strive to restore customer trust.
- We do not cheat and we do not strive for short-term profits.
- We learn the rules of society that are constantly changing and reflect it in our business practices to carry out lawful and honest activities.
Corporate Compliance and Moral Code
- This Corporate Compliance and Moral Code establishes the moral code for activities that should be observed by personnel of NJSC to ensure compliance with the corporate mission to always provide impartial, professional consulting services. The NJSC’s executive officers shall diligently and personally observe this code and take every opportunity to encourage all employees to observe the code.
- NJSC shall diligently observe and comply with the laws, rules and social ethics in Japan and other countries where NJSC performs its activities.
- NJSC shall establish and maintain appropriate systems for corporate financial management and establish transparent corporate financial reports.
- Each employee shall respect the human rights of other employees and outside personnel and shall not discriminate against and/or exercise and demonstrate any form of abuse of authority to such other employees and personnel, including sexual harassment.
- NJSC shall always engage in business activities and consulting services in a fair, transparent and freely competitive manner, and shall not attempt to gain corporate profits through fraudulent practices.
- NJSC shall hold no relation whatsoever with any person or group who may threaten to disrupt public order.
- NJSC shall exercise its best efforts to protect limited resources and the natural environment by means of saving resources and energy, minimizing waste, and promoting the recycling of used resources.
- NJSC shall not receive any unreasonable entitlements or gifts that may hamper normal business practices.
- NJSC’s executive officers and employees shall perform their duties with diligence and integrity without mixing private and public matters and in accordance with NJSC’s company rules and regulations.
Main Activities for Compliance Management
- To ensure all NJSC personnel understand that NJSC’s management policy is to fully comply with NJSC’s Corporate Compliance and Moral Code.
- To establish a contact point (hotline) both inside and outside the NJSC’s headquarters in order to receive comments or opinions from all employees and other interested parties.
- To require all NJSC personnel to acknowledge, in writing, their agreement to adhere to NJSC’s Corporation Compliance and Moral Code in all their activities.
- To initiate efforts to increase awareness and consciousness of all NJSC personnel on compliance management.
- To take disciplinary actions in accordance with the NJSC’s company regulations against any personnel who has been found to act in violation of NJSC’s Corporate Compliance and Moral Code.
NJSC’s Action Code for Compliance Management
In order to enforce the implementation of the NJSC Corporate Compliance and Moral Code, NJSC hereby sets in force the Action Code for Compliance Management for compliance by all NJSC personnel.
All personnel shall observe the Corporate Compliance and Moral Code, paying particular attention to the regulatory codes set out hereunder, while observing all laws, public rules and social ethics, as well as the NJSC’s company rules and regulations.
- Following NJSC’s policy on impartiality, as well as fair, transparent and free competition, all NJSC personnel shall refrain from violating existing Criminal Law and Anti-trust Law, such as engagement in fraudulent business practices and unfair deals with outsourced associates.
- NJSC personnel shall not request for business assistance or provision of information, of unreasonable extent from clients, outsourced associates, political and other business interests groups that constitutes (or might constitute) fraudulent business practices.
- NJSC personnel shall not pay undue attention to profit-oriented objectives over compliance management objectives.
- NJSC personnel shall accept the appropriate disciplinary given in accordance with the NJSC’s company regulations for violation of the Action Code
- NJSC personnel shall be responsible, not only during his/her engagement with NJSC, but also after retirement or resignation, to indemnify NJSC for any damages to NJSC resulting from actions that were in violation of the Action Code.
Inside Company: Responsible person in NJSC Compliance
Outside Company: (1) NJS Compliance Division, (2) Lawyer
(1) NJS Compliance Division
(2) OMOTESANDO SOGO LAW OFFICE, Lawyer : Yoshiya ISHIMURA
NJS Consultants Co. Ltd.
Head Office, Tokyo
1-1-1, Shibaura, Minato-ku, Tokyo 105-0023 Japan