Nikon 2014 Annual Report Download - page 40

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CSR (SOCIAL AND ENVIRONMENTAL RESPONSIBILITY)
Nikon CSR Activities That Support Growth
Nikon’s Approach to Compliance
The Nikon Group defi nes compliance as “meeting the expecta-
tions of stakeholders and earning their trust by not only comply-
ing with laws and regulations but also conducting business
activities that are sound, fair, and conform to corporate rules
and social norms.” In April 2011, to put greater emphasis on
global CSR, the Nikon Code of Conduct was revised, simplifying
content such as fair business practices, human rights, CSR pro-
curement, and anti-corruption, and became the shared code for
conduct throughout the entire Group. Currently, the Nikon Code
of Conduct is available in 19 languages.
Compliance Promotion System
The Business Conduct Committee, chaired by the senior execu-
tive vice president of Nikon Corporation, performs the functions
of deliberation and decision of the action plans for the purpose
of strengthening compliance. The Compliance Section of Nikon
Corporation’s CSR Department under the Business Conduct
Committee works in cooperation with persons in charge of pro-
moting compliance stationed in the various departments of the
Company and in Group companies. Outside Japan, regional
holding companies of the Group, in collaboration with the
Compliance Section, are playing a major role in facilitating the
promotion of compliance activities relevant to the region.
Compliance Promotion Activities
Establishing a Group Anti-Bribery Policy
In April 2014, to reinforce measures to prevent bribery, we estab-
lished the Nikon Anti-Bribery Policy after evaluating the bribery
risks and surveying opportunities to interact with public offi cials
in the course of work by interviewing employees who had returned
from postings outside Japan or were dispatched to Group compa-
nies. This step reiterates the Nikon zero-tolerance approach
toward bribery. Going forward, we will propagate this policy to
ensure that it is known to all employees. We will also develop
guidelines suited to the realities on the ground in each region.
Compliance Education
We implemented compliance education through e-learning as
well as Group training conducted by compliance facilitators at
all departments and companies in and outside Japan. In the
year ended March 31, 2014, we took steps to spread awareness
of changes to the Nikon CSR Charter, which was revised in
February 2013.
As of the year ended March 31, 2014, we started to distrib-
ute a global compliance newsletter that is available in English,
Chinese, and Japanese. The newsletter takes up compliance-
related news reported around the world and explains the
thinking on compliance in the Nikon Group.
Code of Conduct Hotline
The Nikon Group established the Code of Conduct Hotline as a
central point of contact for employees of the 22 Group companies
in Japan, including fi ve non-consolidated Group companies. In
the year ended March 31, 2014, the hotline was used 50 times
to report concerns related to harassment, alleged noncompliance,
and other issues. These concerns are addressed and solved by
relevant departments working in cooperation with each other.
Group companies outside Japan have their own reporting/
consulting hotlines. However, since the hotlines have a low
track record of use, we will conduct information campaigns
through the holding companies in each region.
Global Awareness Survey
The Nikon Group conducts awareness surveys on a global scale
among its employees in an effort to understand the degree of
penetration of its corporate philosophy and awareness of the
Code of Conduct as well as the implementation of compliance
education. In the year ended March 31, 2014, we expanded
the awareness surveys already conducted in Japan, China, and
Europe to other regions, and we also made efforts to standard-
ize certain questions on the awareness survey for all regions. A
regional comparison of the standardized questions was reported
to the Business Conduct Committee. In the future, we will
continue to analyze survey results, which will be refl ected in the
activities to promote compliance.
CSR and Compliance Awareness Survey (Year ended March 31, 2014)
Yes
No
Have you read the Nikon CSR Charter and Code of Conduct?
Japan 95%
94%
88%
86%
92%
76%
Greater
China
Asia
Europe
Americas
Korea
5%
6%
12%
14%
24%
8%
Implementation of Compliance Activities
Encouraging Individual Employees to Make Decisions and Take
Actions Appropriately in Response to Global Social Changes
38 NIKON REPORT 2014