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.
- NRI Group Policy on Human Rights
- NRI Group Anti-Bribery Policy
- NRI Group Competition Law Compliance Policy
- NRI Group Global Tax Policy
NRI Group Policy on Human Rights
The NRI Group is committed to respecting the human rights of all people impacted by our business activities in the process of achieving our business philosophy, and will make Group-wide efforts to carry out our responsibility in promoting human rights.
The NRI Group adheres to international standards of human rights including the International Bill of Human Rights, The International Labour Organization's Declaration on Fundamental Principles and Rights at Work, and The Ten Principles of the United Nations Global Compact. This policy is based on these standards and the United Nations Guiding Principles on Business and Human Rights, and establishes the human rights activities to be implemented by NRI Group companies and their officers and employees.
Scope of Application
This policy applies to all officers and employees of the NRI Group. The NRI Group also encourages all business partners to adhere to and comply with the policy, thereby collaboratively bearing the responsibility to promote human rights.
Respect for Human Rights
The NRI Group prohibits all types of discrimination and harassment based on such as race, ethnicity, nationality, place of origin, social status, social origin (lineage), gender, marital status, age, language, disability, health, religion, belief or creed, wealth, sexual orientation, gender identification, and type of job or occupation. The NRI Group rejects any type of forced labor or child labor.
The NRI Group respects workers' right to freedom of association and the basic labor rights to collective bargaining and collective action.
Responsibility to Respect Human Rights
The NRI Group understands the risk of affecting human rights directly or indirectly through our business activities. The NRI Group seeks to avoid causing or contributing to violation of human rights which we may be involved through its business activities, and in the event it causes adverse human rights impacts through its business activities, the NRI Group will take appropriate actions to correct them. If a business partner is suspected to have an adverse impact on human rights linked to our business, and if this is in connection with the NRI Group's business, the NRI Group will request our business partner to abide by international human rights standards.
Compliance with Applicable Laws and Regulations
The NRI Group will strictly comply with applicable laws and regulations in the countries and regions in which it carries out business activities. Where there are conflicts between internationally recognized human rights standards and the laws of a country or region, the NRI Group will strive to respect the internationally recognized human rights standards.
Training and Education
The NRI Group will offer appropriate training and education to all officers and employees to ensure that this policy is embedded throughout our business activities, is well understood, and is implemented effectively.
Human Rights Due Diligence
The NRI Group will establish a system for human rights due diligence and will operate it continuously. The human rights due diligence system will identify and prevent/mitigate adverse human rights impacts.
Where we identify that we have caused or contributed to adverse human rights impacts directly or through a business partner, the NRI Group will take appropriate corrective measures to provide remediation.
Dialog and Discussion
The NRI Group will make use of independent expert external knowledge on human rights and engage in discussions with stakeholders about addressing potential and actual human rights impacts.
Disclosure of Information
The NRI Group will report on the progress of its efforts to respect human rights pursuant to this policy on our official website and elsewhere.
Enacted on Feb. 5, 2019
Chairman and President & CEO,
Representative Director, Member of the Board
Nomura Research Institute, Ltd.
NRI Group Anti-Bribery 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
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.
NRI Group Global Tax Policy
This policy is established to set forth the NRI Group's core principle of tax matters. All the NRI Group's executives and employees comply with laws, social standards and company rules, and pursue sustainable growth and the enhancement of corporate value. In relation to tax matters, the NRI Group seeks to enhance tax governance based on this policy. The NRI Group contributes to the local community through appropriate tax compliance while acting in good faith and with sound judgment.
Compliance with laws and regulations
The NRI Group shall comply with the relevant tax laws and regulations in the countries it operates.
The CFO of NRI is responsible for the NRI Group's tax governance. As to the day to day management, it is controlled by each NRI Group companies through consultation with NRI and external advisors when necessary. NRI supervises tax risk management for the NRI Group. Tax matters are reported to the management of NRI when necessary and the management conducts tax governance for the entire NRI Group.
Tax Risk Control
The NRI Group properly identifies, evaluates, and manages tax risks with consideration for materiality and rationality. In the case that tax treatment is uncertain, there are several options regarding its interpretation, or significant uncertainty with regard to tax risk is foreseen, the NRI Group controls such risk by seeking the advice from external advisors and conducting advance inquiries to the tax authority when necessary.
The NRI Group seeks to take advantage of available tax incentives, reliefs and exemptions in the scope of normal business activity which has a business purpose or commercial rationality. The NRI Group shall adopt no tax planning for which there is no business purpose and commercial substance, for the sole purpose of reducing its tax liability.
Relationship with tax authorities
The NRI Group keeps an open and transparent relationship with the tax authorities. For the inquiry from the tax authorities, the NRI Group will make best efforts to disclose relevant information, and explain the NRI Group's tax policy and rationality of transactions.