Ethics and Compliance Policy
The Nichiden Group recognizes that ensuring compliance is an essential part of fulfilling its social responsibility and continuing to develop in the future. To ensure thorough compliance, we distribute to all officers and employees a Compliance Action Guidebook, which is based on our company motto of “Sincerity,” our management philosophy, our purpose, our action guidelines, and our charter of corporate behavior, and we endeavor to earn stakeholder trust by acting in accordance with high ethical standards.
Ethics and Compliance Policy
1. Compliance Promotion Framework
To strengthen compliance across the Group, the Nichiden Group has established a Compliance and Risk Management Committee chaired by the Representative Director and President Executive Officer. The Committee monitors compliance across the entire Group. The Board of Directors receives regular reports on matters reviewed by the Compliance and Risk Management Committee and oversees the compliance and risk management framework, verifying and evaluating its appropriateness and effectiveness. In the event of unforeseen contingencies, the Committee takes timely action in accordance with internal rules to minimize damage.
2. Key Initiatives
- Prohibition of Corruption
We comply with all applicable laws and promote fair business practices grounded in high ethical standards in order to contribute to the sound development of free and open markets. We strictly prohibit all forms of corruption, including bribery. - Elimination of Antisocial Forces
In accordance with our Manual for Addressing Antisocial Forces, we maintain no relationship whatsoever with such entities. By doing so, we safeguard public trust and contribute to a safe society and sound corporate management. - Prohibition of Misconduct and Misappropriation
The Representative Director and President Executive Officer bears responsibility for detecting and preventing misconduct and misappropriation*. All officers and employees are required to act with the highest level of sincerity and ethical standards in the conduct of business.
* Misappropriation refers to improper use of Group assets, falsification related to financial reporting, or the disclosure of material information by officers or employees for personal gain or the benefit of third parties. - Prohibition of Conflicts of Interest
In situations where personal interests may conflict with those of the company, officers and employees act in accordance with applicable laws, internal rules, and manuals, always prioritizing the interests of the company. - Prohibition of Unfair Trade Practices
We conduct business under fair and open competition in compliance with laws and internal rules concerning the prohibition of monopolies and the maintenance of fair competition. We do not engage in cartels, bid rigging, exploitation of position in trading, abuse of superior bargaining position, or any other practice that restricts competition or constitutes unfair trade. - Proper Disclosure of Company Information
We disclose company information in a timely and appropriate manner. We also manage company information responsibly, strictly prohibit insider trading by officers and employees, and uphold investor confidence in the securities markets. - Prevention of Money Laundering and Terrorist Financing
We take measures to ensure that our products and services are not used for the transfer of proceeds of crime, terrorist financing, or the financing of the proliferation of weapons of mass destruction. - Protection of Personal Information and Confidential Data
Personal information, confidential information, and data obtained or created in the course of business are handled appropriately in accordance with applicable laws and internal rules. - Protection of Intellectual Property
We protect the intellectual property owned by the Nichiden Group and respect the intellectual property rights of third parties. - Proper Export and Import Procedures
The Nichiden Group complies with domestic and international trade laws and regulations, including tax-related laws, and fulfills its corporate social responsibilities in order to maximize corporate value. - Whistleblowing System
As part of our efforts to ensure the effective implementation of corporate ethics and compliance, the Nichiden Group operates a whistleblowing system known as the Hotline. We maintain internal and external whistleblowing channels and accept reports, including anonymous reports, of any conduct that violates or may violate the Compliance Action Guidebook, internal rules, or applicable laws. Our internal rules ensure strict confidentiality and prohibit any disadvantageous treatment of whistleblowers. The whistleblowing system is communicated to employees through internal training and other initiatives. - Compliance Education, Training, and Awareness
The Nichiden Group provides ongoing compliance education, training, and awareness programs to ensure that all officers and employees understand and comply with legal and ethical requirements. Through these initiatives, we are committed to upholding the highest standards of corporate ethics and legal compliance.
April 2025
Toshikazu Fuke
Representative Director and President Executive Officer, NICHIDEN Corporation
Risk Management
Basic Approach
Our approach to risk management entails recognizing and evaluating risks with the potential to substantially impact our management as regards our business goals and taking steps to prevent those risks and minimize losses in the event of a contingency. The Compliance and Risk Management Committee, chaired by the Representative Director and President Executive Officer, plays a central role in comprehensively reviewing our risk management framework, policies, and measures, thereby strengthening the resilience of the entire Group.
Risk Management Framework
As with our compliance framework, the Compliance and Risk Management Committee monitors business and other risks across the Group. The Board of Directors, which oversees the Committee, receives reports on its deliberations and verifies and evaluates the appropriateness and effectiveness of the risk management framework.
Business and Other Risks
Among the risks that may affect the Group’s business, we recognize the following as key risks. In accordance with our risk management rules, the Compliance and Risk Management Committee designates responsible departments for each risk and periodically reviews countermeasures.
| Risk category | Main measures |
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| Economic fluctuation risk |
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| Country risk |
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| Foreign exchange risk |
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| Credit risk |
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| Compliance risk |
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| Information systems and information security risk |
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| Climate change and natural disaster risk |
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| Risk related to emerging infectious diseases |
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Business Continuity Planning (BCP)
We have formulated a business continuity plan to allow our businesses to continue to operate in the face of an array of contingencies, including a natural disaster or pandemic. We have put in place structures to quickly establish an emergency task force in the event of such an emergency.
Business Continuity Plan
- Purpose
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This plan was formulated with the goal of facilitating the continued operation of Nichiden’s businesses in the event of an emergency (such as an earthquake) while ensuring the safety of employees and their families.
- Basic Policy
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In the event of an emergency, Nichiden will take steps to ensure the continuity of its business operations in accordance with the following basic policy.
● Safeguard the safety of employees and their families.
● Maintain Nichiden’s operations.
● Safeguard trust with business partners by fulfilling supply responsibility.
● Safeguard employees’ jobs.
● Safeguard the vitality of the local economy.
Responding to Natural Disasters
In the event of a natural disaster or other emergency, we will immediately establish an emergency task force chaired by the president to address the situation, including by working closely with facilities and sites to assess any damage, aiding employees and securing resources, communicating through public relations activities, and assisting with recovery efforts. In addition, we have distributed an emergency action manual to employees. We are working to ensure the safety of employees regardless of whether they are at work, at home, or at another site on company business.
Emergency Supplies
We have distributed essential emergency supplies to all employees for use in the event that they need to return home or relocate to a shelter in the event of an emergency. We also maintain stores of helmets and other emergency supplies for offices. By periodically replacing these supplies and verifying their quantities, we ensure that they will be available for use in the event of an emergency.
Pandemic Response
Our business continuity plan includes measures to address the spread of a possible pandemic, including initiatives to prevent infections, regulate the activities of infected employees, and facilitate continuity of business operations under pandemic conditions (by, for example, limiting the number of employees who report for work, adjusting the manner in which employees do their jobs, and specifying the scope of such work).
During the recent COVID-19 pandemic, we lowered risk by putting in place restrictions on activities by employees who were or who were likely to be infected, as well as rules governing who could report for work and handling of leaves from work.
Disaster Preparedness Training
We designate every September as Disaster Preparedness Month so that each employee can ensure their own safety by mastering essential knowledge and judgment, and by acting appropriately in the event of an emergency. In addition to holding training on confirming safety, evacuation, firefighting, and emergency aid at each worksite, we are working to raise awareness of the importance of disaster preparedness by, for example, having employees read through our disaster preparedness manual, go over changes in the manual, and review the information on their personal disaster preparedness card. We are also working to enhance future training by administering a questionnaire after the training.
Information Security
We recognize information as an essential asset in our business activities and consider ensuring its integrity a top priority. We have put in place information management rules, and we are working to ensure that confidential information and personal data are not disclosed in an unauthorized manner. In fiscal 2022, we further strengthened our information security regime by establishing an information security policy and revising some information management rules.
Information Security Policy
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1. Management’s Responsibility
We will strive to systematically and continuously improve and enhance information security under the leadership of management.
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2. Development of Internal Systems
We will establish a management system to maintain and improve information security, establish information security measures as internal regulations, and act in accordance with these regulations.
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3. Initiatives by Directors, Employees, and Others
We ensure that our directors, officers, employees, and others understand the rules and regulations concerning information security and acquire the necessary knowledge and actions through education to uphold our commitment to information security.
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4. Compliance with Legal and Contractual Requirements
We comply with laws, regulations, codes, and contractual obligations related to information security and meet the expectations of our business partners.
● We handle the personal information of our business partners and our company in accordance with the Act on the Protection of Personal Information of Japan.
● We handle the confidential information of our business partners and our company in accordance with the Unfair Competition Prevention Act of Japan.
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5. Response to Violations and Accidents
In the event of any violation of laws and regulations, breach of contract, or accident related to information security, we will take appropriate action and strive to prevent any recurrence.
Strengthening Information Security
To strengthen information security, we augment companywide initiatives with irregularly scheduled awareness-raising activities designed to improve employees’ literacy in line with monitoring by the Information Systems Department.
Intellectual Property Initiatives
We strive to protect intellectual property rights and prevent infringement with the goal of respecting assets and rights and ensuring they are strictly managed, administered, and protected. We spread awareness about our approach to intellectual property and associated prohibited conduct among employees through a Compliance Action Guidebook in an effort to prevent violations of applicable laws and foster understanding of the value of Nichiden’s intellectual property.
(Nichiden Patents)
Number of patents as of the end of fiscal 2024: 2 (in Japan)
→ For details on business risks, refer to “Business risks” in our securities report.
