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NRI Group approach to compliance

The NRI Group strives to ensure total compliance with ethical codes and law and regulations, and to help maintain society's confidence in the Group. As a corporate member of Nippon Keidanren (Japanese Business Federation), NRI respects the spirit of the Federation's Charter for Corporate Behavior and puts it into practice.

The NRI Group's Human Rights Policy

The NRI Group respects the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work. Including the compliance matters which are expressed in "NRI Group's CSR Policy" and "NRI Group's Code of Business Principles", the NRI Group respects for basic human lights and works on a realization of safe, strong workplace environments.

Respect for international standards on human rights

The NRI Group supports and respects international standards on human rights and labor, such as the International Bill of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, and the UN Guiding Principles on Business and Human Rights.

Respect for workers' basic rights

The NRI Group respects workers' rights to organize and to engage in collective bargaining and other collective action in accordance with the laws and regulations and the labor practices in their country or local region.

No forced labor or child labor

The NRI Group shall not accept the use of forced labor or child labor in any form, in any of its business activities.

No discrimination

The NRI Group shall engage in absolutely no discrimination and shall commit no violation of an individual's human rights in any of its business activities on the grounds of for example race, ethnicity, nationality, place of origin, social origin, societal status, gender, age, language, religion, beliefs, disability, sexual orientation, or property.

No harassment

The NRI Group shall tolerate no conduct, such as sexual harassment or workplace bullying, that violates an individual's dignity.

NRI Group Anti-Bribery Policy

Policy

In order to pursue business fairly and in compliance with the laws and social norms, NRI Group will comply with the Japanese Unfair Competition Prevention Law, the US Foreign Corrupt Practices Act, the UK Bribery Act 2010, the Chinese Criminal laws on anti-bribery, and other applicable anti-bribery laws and regulations (hereinafter collectively called "anti-bribery laws and regulations"). By preventing any acts of bribery and any acts that may be considered as bribery, NRI Group will maintain its reputation as a company that is trusted by the customers and the society.
NRI Group has established the following code of conduct, applicable to all directors, officers and employees of NRI Group. NRI Group requires its agents and partners to comply with such standards.

Code of Conduct

  • NRI Group shall not, directly or indirectly, give, accept, or request or promise to give, accept any bribe. Such restriction shall apply to all dealings with any public officials or other persons/entities, regardless of whether at the expense of NRI Group or the individual.
  • When engaging agents who act on behalf of the NRI Group or act as intermediaries for NRI Group and other business partners, NRI Group shall conduct adequate due diligence procedures as well as make known and require compliance with the anti-bribery laws and regulations.

Bribery Risk Management

  • NRI Group will conduct bribery risk assessments periodically to prevent violations of the anti-bribery laws and regulations.
  • NRI Group will conduct education and training regularly to ensure due compliance with the anti-bribery laws and regulations and this Policy.
  • NRI Group will retain relevant approvals and accounting books and records, and establish an internal control system, to comply with the anti-bribery laws and regulations.
  • NRI Group will periodically review and update, as it may become necessary, its anti-bribery compliance program.
  • Compliance Hotline will receive and respond to any consultation, notification or report regarding any acts that violate, or may violate, the anti-bribery laws and regulations or this Policy.

NRI Group Competition Law Compliance Policy

Policy

In order to pursue fair competition, NRI Group will comply with the Japanese Anti-Monopoly Law, the Subcontract Proceeds Law and other Japanese Laws, the US Antitrust Law, the EU Competition Law, the Chinese Anti-Monopoly Law and other applicable competition laws and regulations.

Code of Conduct

NRI Group shall not participate in any of the acts listed below as examples that violates, or is suspected to violate, the applicable competition laws and regulations in any country or region.

  • Entering into agreements with competitors, formally or informally, that would impede fair market competition.
  • Unreasonable monopolization, predatory pricing that would impede fair market competition and other abuse of dominant position.
  • Discussions and exchanges of information with competitors on prices, contract terms, costs, inventories, marketing and product plans, market research and analysis, production plans and capabilities, and other commercially sensitive information.

Competition Law Compliance Risk Management

  • NRI Group will conduct competition law risk assessments periodically.
  • NRI Group will conduct education and trainings regularly to comply with the applicable competition laws and regulations and this Policy.
  • NRI Group will periodically review and improve, as it may become necessary, its competition law compliance program.
  • Compliance Hotline will receive and respond to any consultation, notification or report of any act that violates, or may violate, the applicable competition laws and regulations or this Policy.

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