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Compliance Promotion Activities

Compliance Section in CSR Department fosters compliance promotion activities in cooperation with compliance facilitators stationed in the departments of the company and in the Group companies. The Nikon Group provides compliance education, raises awareness of compliance, conducts awareness surveys, and takes measures against violations, for employees in Japan and overseas. We are spreading and firmly establishing compliance awareness in the Group so that each employee should behave with a sense of morality and decency in his/her daily business.

Compliance education

The Compliance Section in the CSR Department at Nikon Corporation sends out an in-house compliance newsletter to local compliance facilitators, thereby reaching the local Nikon Group companies in Japan. In response to recent social trends, the newsletter took up such social news topics as the ban on relationships with antisocial forces. The section has also set up a compliance-related site on the Group intranet. In addition to calling attention to how to deal with public agencies and public servants, the site also handles inquiries.
In terms of group educational events, on top of workplace education delivered by the compliance facilitators in each department and company, we also provide compliance training for new regular employees, new mid-career workers and employees being promoted to managers, as well as education in response to individual requests. Compliance Section also obtain the latest information on compliance by attending conferences and seminars hosted by external organizations.
Education on compliance is also provided overseas, including group education delivered by the compliance facilitators in each company as well as e-learning sessions.

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Reporting / Consulting system

Code of Conduct Hotline Flow Diagram (Japan): The department in charge of the Code of Conduct Hotline accepts consultations from sources. The subjects of the consultations are reported to the Business Conduct Subcommittee as a general rule, and then discussed for countermeasures. If necessary, an investigation is undertaken in cooperation with related departments. Investigation results and countermeasures are explained to the sources and reported to the Nikon Business Conduct Committee.

The Nikon Group established the Code of Conduct Hotline as a central point of contact for employees of Group companies in Japan wanting to discuss a situation that might run counter to Nikon Code of Conduct.
For the sake of improving accessibility, in addition to the existing internal points of contact, we established new external points of contact serviced by external professionals in October 2011. At the same time, we renewed awareness for the Code of Conduct Hotline, by distributing a new handy card listing the Hotline details to all Nikon Group employees in Japan.
The Code of Conduct Hotline protects the privacy of its users and ensures that they are not disadvantaged in terms of human rights and treatment. In the year ended March 31, 2012, the hotline was used 41 times, and these matters have been dealt with in cooperation with the relevant departments. Appropriate follow-up is also provided as needed.
Our overseas Group companies have also established compliance reporting and consultation hotlines and are informing their employees about the services.

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Compliance awareness survey (monitoring)

Compliance Awareness Survey Result(Conducted in October 2011 / 11,714 respondents using e-learning) In response to the question "Did you know that the Code of Conduct Hotline has been set up?", 88.6% of employees responded with a "yes" in 2010. In 2011, the degree of recognition had increased thanks to promotional activities underscoring the creation of an external point of contact, to the point that 93.3% of employees responded with a "yes".

Every October, the e-learning system is utilized to survey all Nikon Group employees in Japan on their attitude to compliance (monitoring). Some departments and companies have inadequate Internet access, and so they were surveyed using a paper-based survey (443 employees). The overall response rate was 88%.
Survey answers are collected under anonymous conditions and a summary of the results is released via the intranet. Additionally, each department and company is given feedback based on their own survey results. For departments with weak scores, the Compliance Section explains the results, requests that improvements be made, and provides education directly. In our ongoing effort to raise awareness of compliance, the Nikon Group will pursue a PDCA cycle to increase awareness of relevant issues and improve performance in each department and company.

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Preventing corruption

The Nikon Group takes strict action against all violations of the working regulations of each Nikon Group company and the Nikon Code of Conduct based on its in-house disciplinary rules after investigating and confirming the facts.
In the year ended March 31, 2012, disciplinary action against the perpetrator (and their managers/supervisors) was taken in two cases at Nikon Corporation, and one case at a Group company in Japan. In order to prevent the recurrence of similar problems, the level of the action and its base article are disclosed internally.