| 1. Purposes and Application of the Code of Conduct |
| (1) |
WE (*) recognize that the key to enhancing the corporate value of the NEC Group is fulfilling our corporate social responsibility in our day-to-day work. Therefore, WE will faithfully observe the provisions of this NEC Group Code of Conduct (this “Code”).
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| * “WE” means the Officers (including directors, corporate auditors, and certain other personnel) and Employees (including temporary and part-time employees) of NEC Group companies. |
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| (2) |
This Code shall be applied to the Officers and Employees of each company in the NEC Group subject to the approval of each company’s board of directors. |
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| 2. Basic Position |
| (1) |
WE will comply with all applicable laws, rules, regulations, and in-house regulations, including this Code, in every aspect of our corporate activities at all times. WE will strive to ensure that all corporate activities are in compliance with normal business practices and social ethics. |
| (2) |
WE will respect the fundamental human rights of all people in every aspect of our corporate activities. Moreover, WE will not act in such a way that may offend the dignity of any individual or be prejudicial on the grounds of race, beliefs, gender, age, social position, family origin, nationality, ethnicity, religion, or physical or mental handicap. |
| (3) |
WE will respect the privacy of individuals, such as customers, business partners, and our Employees. |
| (4) |
WE will maintain impartial, fair, and open relationships with all the stakeholders of our company and will conduct business in a fair manner with them. |
| (5) |
WE will not take any action pursuing our personal or a third party’s interests against our company’s legitimate interests. |
| (6) |
WE will not carry out any actions whatsoever that may damage the NEC Group's social trust or honor. |
| (7) |
WE will establish an effective internal control system and implement it. |
| (8) |
WE will accurately and fairly maintain all accounting and other records in accordance with applicable laws, rules, regulations, and in-house regulations, and properly execute our duties. WE will not carry out any unlawful accounting transactions or actions that may cause losses to the NEC Group. |
| (9) |
With an awareness of our position as a member of society, WE will always act in accordance with a good social conscience based on high moral and ethical standards. |
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| 3. Accountability for Adherence to This Code |
| (1) |
WE will act faithfully in compliance with this Code. |
| (2) |
The Officers and the Employees who are in a managerial position will provide guidance and supervision to ensure that all their subordinates observe the provisions of this Code. |
| (3) |
The divisions concerned in our company will undertake the activities necessary to ensure that the corporate activities are in compliance with this Code, including the formulation of in-house regulations and behavior manuals, promotion of thorough awareness of specific rules to observe, and provision of advice and guidance. |
| (4) |
WE recognize that a violation of this Code may result in disciplinary action under and in accordance with applicable laws, rules, regulations, and/or in-house regulations. |
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| 4. NEC Help Line |
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The Officers and Employees of the NEC Group companies who are aware of acts that are, or that may be, in violation of this Code are encouraged to contact the NEC Help Line or a similar contact point in each company. The contact points of the NEC Help Line are designated as a consulting company as well as NEC Corporation (provided that the contact point designated as NEC Corporation is available only for the Officers and Employees of NEC Corporation). Such Officers and Employees will not be subject to any form of detrimental treatment as a result of their contacting the NEC Help Line. |
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| 5. Establishment and Revision of This Code |
| (1) |
The establishment of this Code was decided on by the board of directors of NEC Corporation following deliberations by the Risk Control and Compliance Committee of NEC Corporation. |
| (2) |
Each company in the NEC Group may modify this Code based on a decision by its board of directors, provided that the modifications do not contradict this Code. |
| (3) |
Any revisions of this Code, if necessary, will be decided by using the same procedures as used to establish the Code. |
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