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When the Competition Law Compliance Policy and Rules for Contacts with Competitors, and the Basic Rule on Anti-bribery were established in October 2011, group training was held a total of 50 times for approximately 2,000 NEC employees, including corporate officers and upper level managers, in order to ensure full awareness of them. Continuing to perform this kind of training is critical to rigorously promoting fair trade.
Group training was also conducted internally in fiscal 2013 related to competition law compliance and corruption prevention. Approximately 950 employees participated.
The entire NEC Group must be involved in promoting fair trade. Led by NEC’s Legal Division, we also actively held group training for NEC Group companies in Japan. Sessions were held 27 times in total for 11 companies during fiscal 2013. Some 1,200 corporate officers and employees participated.
Overseas, we are committed to conducting fair trade training through our regional headquarters. In the U.S. and Europe in particular, the training is conducted for NEC Group companies in each region using e-learning and other tools in an effort to further raise the awareness of corporate officers and employees at NEC Group companies overseas regarding the promotion of fair trade.
In addition, for compliance with competition law, we created the Competition Law Compliance Policy Card to further raise awareness of NEC’s Competition Law Compliance Policy. The card is the size of a business card so it is easy to carry around, and it has been passed out to all corporate officers and employees of NEC and NEC Group companies in Japan.
NEC created the Basic Rule on Anti-bribery in October 2011 to prevent bribery and corruption, but we have also instructed NEC Group companies, both in Japan and abroad, to create their own equivalent regulations and build appropriate systems for that purpose. As a result, as of the end of fiscal 2013, over 90% of our domestic subsidiaries* had created basic regulations for preventing bribery.
At overseas subsidiaries, the relative risk of bribes as well as applicable anti-corruption laws differ depending on the region, so appropriate rules must be created after surveys have been done. As of the end of fiscal 2013, close to 90% of overseas subsidiaries* had created the regulations.
NEC intends to continue to provide instruction and support going forward, so that all NEC Group companies promptly formulate and enforce basic regulations for preventing bribery and corruption.
*Excludes listed companies and their subsidiaries and subsidiaries being liquidated, etc.