Nissan 2011 Annual Report Download - page 33

Maintaining Trust Through Transparency
To ensure full understanding of the code in Japan, all employees, including executives, take an
e-learning or video training course based on the Japanese version of the Nissan Code of Conduct—
“Our Promises,” instituted in April 2004—after which they sign an agreement to abide by it. We revised
parts of the code in 2010 in response to legal amendments and have been retraining our employees
since fiscal 2010 to further strengthen the spirit of compliance within the company.
Education programs to promote compliance are held regularly for all employees in North America,
and a set of universal guidelines has been drawn up for each country in Europe. Compliance-related
training is also being carried out in the General Overseas Markets based on guidelines that take into
account conditions in each of those countries. Moreover, all Group-affiliated companies have
introduced their own codes based on the Nissan Code of Conduct.
Additionally, we have created sets of internal regulations covering the global prevention of insider
trading and the management of personal information. Nissan seeks to heighten awareness of
compliance companywide through such measures as well as various education and training programs.
Our Stance Against Discrimination and Harassment
Item 6 of Nissan’s Global Code of Conduct, “Value Diversity and Provide Equal Opportunity,” is our
requirement to accept, value and respect the diversity to be found among our employees, business
partners, customers and communities where we do business, and to reject discrimination and
harassment in all their forms, no matter how minor they may be. Nissan executives and employees
must respect the human rights of others, and may not discriminate against nor harass others based on
race, nationality, gender, religion, physical capability, age, place of origin or other reason; nor may they
allow such a situation to go unchecked if discovered. We also work to ensure that all employees, both
male and female, can work in an environment free from sexual and other forms of harassment.
Internal Reporting System for Corporate Soundness
Nissan employs the Easy Voice System to promote the spirit of compliance among employees and
facilitate sound business practices. This internal reporting mechanism allows employees to submit
opinions, questions or requests to the company. It has played an instrumental role in creating a self-
managed, compliance-oriented corporate culture. This system, which offers full protection to any
persons offering information in accordance with Japan’s Whistleblower Protection Act of April 2006,
has been put in place in all Nissan Group companies in Japan. Similar systems have been put in place
in other Nissan Group companies worldwide.
FISCAL 2011 GLOBAL COMPLIANCE COMMITTEE ORGANIZATION
A compliance committee has been established in each region under
the governance of the global compliance officer. The committees are
responsible for discovering compliance violations at an early stage
through internal auditing or reports, for solving problems, and for
maintaining and improving internal awareness of the Code of Conduct.
Global Compliance Officer
Africa, Middle East, India, Europe
Management Committee
Africa, Middle East, India, Europe
Compliance Committee
Americas
Management Committee
Americas
Compliance Committee
Japan, Asia Pacific
Management Committee
Japan, Asia Pacific
Compliance Committee
Nissan Motor Co., Ltd. Compliance Committee
Affiliated Companies Compliance Committee
Dealers Compliance Committee
Nissan Motor Co., Ltd.
Divisional Compliance
Committee
Global Compliance Committee
Operations Committee
NML Board of Directors
Efficient, Independent Internal Audits
Nissan has established a global internal audit unit, an independent Department under the direct control of
the Chief Operating Officer (COO), to handle internal auditing tasks. Under control of the Chief Internal
Audit Officer (CIAO), audit teams set up in each region carry out efficient and effective auditing of
Nissan’s activities on a group wide and global basis. Audits are implemented based on an audit plan
approved by the Operations Committee and the results are reported to the COO and other related parties.
Additionally, the audit plan and the results are also reported to Statutory Auditors on a regular basis.
Corporate Governance
Performance Corporate DataMid-term Plan
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NISSAN Annual Report 2011