NEC 2015 Annual Report Download - page 52

NEC actively promotes thorough compliance activities and the strengthening of its risk management, including within its supply chain.
In these ways, NEC strives to ensure sound business activities for society.
Thorough Internal Compliance and Risk Management
Strengthening Suppliers’ CSR
NEC believes that compliance and risk management are essential for a
company to exist within society and to meet society’s expectations and
requirements. Consequently, every year, NEC identifies risks
companywide that it needs to address on a priority basis, and carries out
improvement activities. NEC also conducts web-based training related to
compliance on a continuing basis for NEC Corporation and domestic
subsidiaries. In addition, the Company carries out the following initiatives.
l Compliance with Competition Laws and
Corruption (Bribery) Prevention
NEC and its domestic and overseas subsidiaries are thorough in abiding
by policies regarding competition-law compliance and corruption
prevention. To achieve this, we promote awareness-raising and system
improvement activities by which we conduct business activities that
place compliance as the highest priority in a fiercely competitive world.
In fiscal 2015, about 5,000 people, including officers and employees of
domestic subsidiaries, underwent group training. All the members of the
business units in charge of areas regarded as being at high risk for
bribes were advised to take part. At overseas subsidiaries, training for all
officers and employees was implemented through e-learning.
l Compliance Self-Checks
In fiscal 2015, NEC started new self-check compliance testing for all
general managers of NEC and officers of domestic subsidiaries (except
for listed subsidiaries). The self-checks encourage awareness of
compliance weaknesses in the checker’s own division and promote early
NEC is engaged in a variety of initiatives to bolster suppliers’ CSR based
on the NEC Group Procurement Policy.
One aspect of that has been CSR-Process Management Reviews
(CSR-PMR), which have been conducted since fiscal 2013. The reviews
involve visiting suppliers’ sites and conducting onsite assessments of
human rights, labor, health, and safety. Unlike a regular audit, a feature of
this activity is the concept of joint CSR capability building, which involves
dialog with the supplier to raise the CSR abilities of both parties.
In fiscal 2015, CSR-PMR assessments were conducted in
collaboration with a local NGO on three production contractors in China.
As a result, several problems were found that included employment
conditions, working hours, and health and safety management. We
issued corrective-action recommendations and subsequently confirmed
that progress had been made. Going forward, we will expand the
number of assessments carried out and the regions to assess.
detection and elimination of problems by giving feedback to each division
in the form of an analysis of the results and advice on best practices.
l Compliance Hotline
The Company established a compliance hotline at NEC Corporation and
a third-party organization as a point of contact for consultation and
reporting in the event an employee for some reason cannot consult a
superior or associated division about actions that are or may be a breach
of the "NEC Group Code of Conduct." In fiscal 2015, there were 65 cases
of consultations or reports, such as doubts about internal systems or
management and claims about the possibility of breaches of ethical
behavior. Details of the matters consulted on or reported were
evaluated by the internal divisions in charge to determine whether the
claims required a follow-up survey. Then, the results of any survey were
given to those who requested consultation.
NEC has been working to implement thorough compliance practices,
including through the above measures. However, in November 2014,
the Fair Trade Commission conducted on-site inspections on suspicion
of NEC’s violation of the Antimonopoly Act of Japan in connection with
transactions concerning radio systems for firefighting. Moreover, in May
2015, there were more such inspections in connection with
transactions concerning telecommunications equipment for electric
power systems. Taking these incidents very seriously, the NEC Group is
cooperating fully with the commission’s investigations.
Compliance and Risk Management
Assessment at a plant
51 NEC Corporation
Annual Report 2015