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Fair Trading
Basic Policy
NEC believes that ethics is the basis of economic activity, and top management emphasizes this fact at every opportunity. For a company to continue to exist, it must continue to be valued by society for its contributions to customers and the market. When unethical actions take place, they are censured by society and the company involved may ultimately be expelled from the market.
NEC Group conducts business operations on a global basis and faces stiff competition everywhere around the world. We believe that in the midst of this competition it is essential to maintain constant awareness of compliance and practice it accordingly. This is because if sales or profits are based on unethical actions that ignore the rules, we will not only be subject to monetary penalties for breaking the rules, specifically fines and/or compensation for damages, but also almost instantly lose the social credibility NEC Group has built up over the years and even potentially cease from existing as a company.
Policies and Regulations
Countries around the world have reinforced execution of competition laws and anti-bribery regulations in recent years. Since 2008, NEC Group has encouraged overseas Group companies to formulate competition policies. In Japan, NEC has for some time had a compliance manual to accommodate the Antimonopoly Act. It additionally formulated a Competition Law Compliance Policy in October 2011 mindful of complying with overseas competition laws.
The Competition Law Compliance Policy is comprised of a main text section with basic, enumerated reminders on compliance with competition law in Japan and overseas as well as commentary on each section. The policy is intended to raise the compliance awareness of corporate officers and employees of NEC and NEC Group companies in Japan while reducing the risk of competition law infractions.
NEC has also established the Rules for Contacts with Competitors and the Basic Rule on Anti-bribery. The Rules for Contacts with Competitors are intended to restrict unnecessary interactions with competitors to reduce the risk of being suspected of, or becoming involved in, collusion or cartel-like practices. The Basic Rule on Anti-bribery establishes basic systems for preventing bribery and corruption at NEC and basic rules for corporate officers and employees in order to ensure that bribes are neither offered nor received in Japan or abroad in connection with the business activities of the NEC Group.
NEC Group is actively involved in promoting fair trade by reinforcing systems for compliance with competition law and regulations for preventing bribery in order to continue to exist as company with a strong reputation in society.
Systems
Competition Law Compliance
It takes effort on various fronts to comply with competition law, including sales, technology transactions and materials procurement. NEC promotes compliance with the law through cooperation and coordination among multiple divisions involved in each of these areas. Specifically, the Legal Division serves as the lead management division, and the Risk Management Division in the Business Planning Unit (for domestic transactions), the Procurement Reform Management Department in the Software and Solutions Materials Division (for materials procurement) and other departments cooperate to promote compliance with competition law throughout NEC and the NEC Group.
Bribery Prevention
Led by the Legal Division and with the cooperation of the Internal Control Division, NEC enforces the Basic Rule on Anti-bribery and provides related instruction, support, direction and training for internal divisions and NEC Group companies. Checking daily operations is an important part of preventing corruption, so guidelines have been established by the General Affairs Division (for entertainment, gifts and donations), the planning divisions of each Business Unit (for operating expenses), and the Materials Division (for materials expenses), and expenditures requested by the company’s divisions are checked to ensure there are no problems.
