Specific Action Guidelines Regarding Corporate Ethics

The NTT LOGISCO Group promotes initiatives towards establishing corporate ethics across the NTT LOGISCO Group in accordance with the “NTT Group Corporate Ethics” which is the specific action guidelines regarding corporate ethics for all officers and employees of the NTT LOGISCO Group.

Promotion of Corporate Ethics

The Corporate Ethics Committee has been established to discuss initiatives towards the enhancement of company-wide corporate ethics and the Committee is headed by the CEO and Representative Director. The Committee meets twice annually, discusses a range of topics and actively develops specific measures. It also conducts annual Corporate Ethics Training and gives a survey to all employees in its effort to promote corporate ethics. Survey results are shared in the Corporate Ethics Committee for discussion to reach specific measures. Rank-specific compliance training is also conducted annually for new employees and managers .

The NTT Group Corporate Ethics

1. 1. Recognizing the establishment of corporate ethics as one of its most important missions, top management shall exert its leadership to ensure that the spirit of this Charter is adopted throughout the Company, and shall assume full responsibility for solving any problems when any event inconsistent with that spirit occurs.
2. 2. Every person with subordinate employees shall not only act in a self-disciplined manner, but shall also always provide guidance and assistance to his/her subordinate staff to ensure that their conduct is in conformity with the corporate ethics.
3. 3. Every officer and employee of the the NTT Group shall not only comply with all laws and regulations, social standards, and internal company rules whether in Japan or overseas, but officers and employees shall also hold the highest ethical philosophy within himself/herself both in public and in any private situations. Among other things, each officer and employee, as an officer or employee of a member company of a Global Information Sharing Corporate Group, shall maintain full awareness that any disclosure of customer or other internal privileged information constitutes a materially wrongful act. Also, as a member of a group of companies which holds great social responsibilities, he/she shall strictly refrain from giving to or receiving from customers, business partners, and other interested parties any excessive gratuities. In addition, when dealing with civil servants and politicians, we will not engage in bribery or any act that causes the other party to violate or cause suspicion of violating the National Civil Employee Ethics Law, National Civil Employee Ethics Code or Ministerial Code.
4. 4. Each the NTT Group company, at the first opportunity, shall take initiatives to provide training programs in order to help its officers and employees enhance their awareness of our corporate ethics.
5. 5. Every officer and employee of the the NTT Group shall direct his/her efforts to prevent wrongful or scandalous acts which may potentially occur as the specialization and advancement of our business proceeds. Each the NTT Group company shall improve its system to prevent such acts, including, for instance, the re-assignment of contract representatives who have remained with the same customers for a long period of time and the improvement of monitoring tools to protect customer and other information.
6. 6. Any officer or employee who may come to know of the occurrence of any wrongful act or any scandal shall promptly report such wrongful act or scandal to his/her superior or other appropriate persons. If he/she is not able to make such a report, he/she may contact the “Corporate Ethics Help Line (Contact Point)”. It should be noted that every officer and employee who reports the occurrence of any wrongful act or scandal shall be protected so that the reporting party shall not suffer any negative consequences due to such reporting.
7. 7. In the event of an occurrence of any wrongful act or scandal, each the NTT Group company shall be committed to the settlement of the problem by taking appropriate steps through a speedy and accurate fact-finding process, and responding in a timely, suitable, and transparent manner in order to fulfill its social accountability.

Corporate Ethics Help Line Contact Point for Corporate Ethics Compliance

The Company has a Corporate Ethics Help Line Contact Point for Corporate Ethics Compliance.
Based on the Whistle-Blower Protection Act, the Help Line also accepts reports from employees of companies that are in a business relationship with the Company.