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Social Challenge 4
Establish shared ethical standards


Why it matters

As maintaining high ethical standards with society and sharing those high ethical standards with business partners is an essential part of resolving social issues and ensuring sound corporate activities, a range of initiatives will be implemented for establishing and sharing such ethical standards.

What can be accomplished

We set high ethical standards for ourselves and share them with our business partners.

Future vision

The NTT Group is committed to contributing to the development of society by acknowledging diverse cultures, and thus we will contribute to solving social issues by connecting people, goods, and cultures, including communities, nations, and society, while promoting high ethical standards, diversity, and inclusion in fair and equitable ways, and work towards creating a better workplace through powerful and new digital technologies.

Business Activity 12・13
Establishing and thoroughly complying with ethical standards / Appropriately managing conduct risk

Our commitment

We set high ethical standards for ourselves and share them with our business partners

Our objectives


Illegal actions involving anti-competitive behavior or bribery

Policies and Concepts

It is imperative to conduct business in compliance with laws and regulations in the jurisdictions where we operate, and maintain high ethical standards in order to promote sound corporate activities. Recognizing this, NTT established the "NTT Group Corporate Ethics Policy."

These standards, which apply to all officers and employees of the NTT Group, lay out the basic principles of corporate ethics and provide specific guidelines for ethical behavior. These stipulations are intended to remind everyone of their duty as members of a corporate group that bears significant responsibility to society in terms of preventing dishonesty, misconduct, and the disclosure of corporate secrets, as well as refraining from exchanging excessive favors with customers and suppliers, and ensuring that they conduct themselves according to the highest ethical standards in both private and public activities.

Organization for Implementation

NTT has a Corporate Ethics Committee with a senior executive vice president as chair. The committee meets twice a year with the aim of thoroughly promoting the NTT Group's corporate ethics and maintaining discipline. It reports to the Board of Directors twice a year, particularly concerning the status of reports made to the Corporate Ethics Help Line, and the Board of Directors discusses reported matters when necessary.

The NTT Group has Corporate Ethics Committees and corporate ethics officers at Group companies. We foster a corporate climate of observing laws and corporate ethics, investigate wrongful acts and scandals based on our Corporate Ethics Help Line rules, hold regular meetings for the compliance officers of Group companies, and work across the Group to promote compliance.


NTT Group Corporate Ethics Policy

  1. Recognizing the establishment of corporate ethics as one of its most important missions, top management shall exert i ts leadership to ensure that the spirit of these Standards is adopted throughout the Company, and shall assume full responsibility for solving any problems when any event inconsistent with that spirit occurs.
  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 our corporate ethics.
  3. Every officer and employee of 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 of a Global Information Sharing Corporate Group, shall keep himself/ herself fully aware 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 or receiving from customers, business partners, and other interested parties excessive gratuities. Furthermore, when interacting with public officials and politicians, officers and employees shall not commit bribery or commit any other acts that cause the other party to violate the National Public Service Ethics Act/Code of Ethics and the Ministerial Code, or that cause suspicion that such a violation has occurred.
  4. Each 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. Every officer and employee of the NTT Group shall direct his/her efforts to prevent wrongful or scandalous acts which may potentially occur as specialization and advancement of our business proceeds. Each 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. Any officer or employee who may come to know of the occurrence of any wrongful act or any scandal shall promptly report the wrongful act or scandal to his/her superior or other appropriate persons. If he/she is not able to make such a reporting, 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. In the event of an occurrence of any wrongful act or scandal, each 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.

Main Initiatives

Prevention of Bribery

The NTT Group Corporate Ethics Policy mandates compliance with all laws and regulations, social standards, and internal company rules whether in Japan or overseas. With regard to the prevention of bribery, we have an Anti-Bribery Handbook containing important matters to be understood and complied with by our employees. The contents of this handbook are made known to all employees in Japan and overseas through emails and other means.

In addition, NTT, NTT East, and NTT West stipulate that taking bribes is forbidden under the Act on Nippon Telegraph and Telephone Corporation, etc. (hereafter "the NTT ACT") and that breaches are punishable by law. Following the Act on Prevention of Un- just Acts by Organized Crime Groups, contributions and other types of support are only given to charitable organizations deemed suitable by the NTT Group. We have a zero tolerance approach to corruption. In fiscal 2022 no illegal conduct associated with bribery or contribution/support was confirmed within the NTT Group.


Political Contributions

As a holding company, and in compliance with Japan's Political Funds Control Law, NTT does not make political contributions, while a few Group companies make political contributions at their own discretion and in accordance with the relevant laws and regulations as well as the companies' respective codes of corporate ethics.

Compliance with Anti-Monopoly Act

The NTT Group makes efforts to adhere to the Anti-Monopoly Act to ensure its business activities align with a fair and competitive business environment, but in October 2022 in a bid regarding computer devices ordered by Hiroshima Prefecture or Hiroshima City, NTT West was subject to administrative actions for violating the Anti-Monopoly Act. We deeply regret that this event took place, and will put renewed focus on adhering to laws and continue our thorough efforts to prevent recurrence.

Value Chain Management

Policies and Concepts

In recent years, companies find themselves required to monitor the ESG risks and impact on sustainability, including consideration of human rights and mitigation of environmental impacts, of not only their own group companies but also throughout the entire value chain, from raw materials and supplies procurement to disposal and recycling.Also, we expect our value chain to experience further expansion on a global scale and become more sophisticated, requiring us to enhance our value chain management initiatives. The NTT Group aims to take an independent and proactive stance in achieving a sustainable society, by enhancing mutual understanding and building relationships of trust with all suppliers that make up the supply chain, and working together with high ethical standards to develop and maintain a safe and secure supply chain. With this in mind, we have formulated the NTT Group Basic Procurement Policy and conduct procurement based on this policy.

Organization for Implementation

At the NTT Group, the management are responsible for supervising efforts regarding the promotion of sustainable supply chain management. Thus, the NTT Group has a management structure in which there are a Sustainability Committee and a Group Sustainability Committee (including the executive vice presidents of main companies, etc.) under the Board of Directors, with the President and CEO as chairperson. In these committees, basic strategy, the activity implementation situation, and information disclosure regarding supply chain management for the Group as a whole are discussed and decided.

NTT Group Supply Chain Sustainability Promotion Guidelines

A number of supply chain issues have recently come to light, including serious human rights violations such as forced labor and child labor, unlawful disposal of waste, response to stricter regulations on controlling chemical substances, bribery, and other examples of malpractice.

In light of this, we formulated the NTT Group Supply Chain Sustainability Promotion Guidelines in 2022 that contain detailed requirements for suppliers in the seven areas of human rights/labor, health/safety, the environment, fair trade/ethics, quality/safety, and information security to guide our efforts as we work together with suppliers in order to conduct procurement activities in a socially responsible manner.

We have published these Guidelines in Japanese and English as a way of communicating to a broad range of the NTT Group's suppliers both in Japan and overseas, and we have incorporated them into supplier contracts to ensure compliance. In addition, we have also published the NTT Group Green Procurement Standards as a supplement to our environmental guidelines, and are advancing efforts to reduce greenhouse gas emissions throughout the supply chain.

NTT Group Basic Procurement Policy

The NTT Group has created the "NTT Group Global Sustainability Charter" and is promoting initiatives aimed at achieving a "sustainable society" with both "Growth as a company" and "resolving social issues." With modern supply chains, advances in globalization mean there is a greater importance for dealing appropriately with issues such as human rights, ethics, the environment, disasters and pandemics, and security. To address issues like these, the NTT Group aims to take an independent and proactive stance in achieving a sustainable society, by enhancing mutual understanding and building relationships of trust with all suppliers that make up the supply chain, and working together with high ethical standards to develop and maintain a safe and secure supply chain that provides a range of assurances like the protection of human rights and conservation of the global environment.

To achieve this, we will conduct procurement in accordance with the following "NTT Group Basic Procurement Policy."

  1. NTT will strive to provide competitive opportunities with fairness to both domestic and foreign suppliers, and to build mutual trust and understanding.
  2. NTT will conduct economically rational procurement of competitive goods and services that meet its business needs, deciding on suppliers based on quality, price, delivery times, and stable supply in a comprehensive manner.
  3. NTT will conduct procurement in a manner that follows laws and regulations as well as social norms, and takes the environment, human rights, and other issues into account to contribute to society.


Supplier Engagement Initiatives

Based on various guidelines, etc., we are engaged in various activities with the goal of building partnerships of trust with our suppliers. To this point, we had given the Supply Chain Sustainability Survey, an original questionnaire created of NTT, to the NTT Group's major suppliers, but from fiscal 2022, we have newly begun ESG risk assessments by a third part evaluation organization (EcoVadis).

Based on the results of these surveys, we are engaged in activities to strengthen supplier engagement, such as direct dialogues with suppliers,. The direct dialogue covers subjects such as the environment, information security, and BCP (business continuation plans) as well as issues related to forced labor and human rights risks. In the dialogue meetings, we exchange opinions with all our suppliers, and check with our suppliers about occupational health and safety at the workplace and other factors.

In July 2022, NTT joined an alliance of telecommunications companies who globally perform CSR audits on ICT suppliers (JAC: Joint Alliance for CSR) as the first Asian telecommunications company to do so. From fiscal 2023, the NTT Group began performing CSR audits on its suppliers based on JAC auditing standards.

In cases in which, based on risk assessment results, corrective measures are necessary, we plan to have suppliers create a corrective measures plan, and to monitor the execution of that plan. By continuing to perform such supplier engagement activities with our suppliers, we are making efforts toward risk management of the NTT Group's supply chain as a whole.

Definitions of Major Suppliers at NTT Group

By Major Supplier Category Definition
(1) Suppliers involving high procurement amounts Suppliers who account for the vast majority of the procurement amount of the NTT Group (about 90% or more of the total procurement amount)
(2) Suppliers of important goods Suppliers who handle important goods necessary to the core businesses of Group companies
(3) Irreplaceable suppliers Suppliers who handle products which have no replacements on the market

* With regard to the above description, corrective measures are drawn up for suppliers with high environmental, social, and/or governance-related risk, and the execution of those measures is monitored.

Cooperation in Communications Industry

The three companies of NTT, KDDI, and Softbank have announced that they will jointly engage in the standardization of supplier engagement activities and in various initiatives with the goal of realizing a sustainable supply chain in the communications industry.

From fiscal 2023, sustainability questionnaires for suppliers have been standardized, and SAQs* (self-assessment questionnaires) common to the three companies are being utilized for the supplier engagement activities of each company.

We plan to continue partnering with various industries and companies to work toward the realization of a sustainable supply chain.

ESG Assessments when Selecting Suppliers

As a way of promoting a sustainable supply chain, in transaction selections, the NTT Group adds additional points in evaluations of suppliers engaged in superior ESG-related initiatives. Specifically, we prioritize procurement from suppliers promoting initiatives to reduce greenhouse gases, based on green procurement standards. Furthermore, Group companies have progressively introduced an internal carbon pricing system*, a system of promoting a reduction in the environmental burden by performing cost conversions of CO2 emissions, and add that converted cost onto proposed product prices for evaluations.

Overview of Internal Carbon Pricing System
A system in which when it comes to decarbonization-related project decisions and procurement (product selection, etc.), decisions are made while taking CO₂ emission costs into consideration. (Internal carbon price: 6,500 yen/t-CO2)

Request to Business Partners for Compliance in Fair Trade Practices

The NTT Group Supply Chain Sustainability Promotion Guidelines clearly outline prohibited items in fair trade practices and business ethics (seven articles), and of these, we request that procurement transactions are conducted in an honest, just, and fair manner based on agreements and so forth, and that behavior such as the abuse of a superior position is not practiced.

ESG Education for Procurement Department Staff

The NTT Group implements training on ESG for staff in procurement departments to reduce the burden of procurement activities on the environment and ensure they persistently comply with the laws, regulations, and norms of society.

Highest rating in 2022 Supplier Engagement Ratings by CDP

The NTT Group was praised for its efforts aimed at reducing CO2 emissions throughout its entire supply chain, and has been selected as the highest "Supplier Engagement Leader" in the "Supplier Engagement Survey*" run by CDP, an international non-governmental organization assessing environmental-related matters.

*Supplier Engagement Survey: Assesses company supply chain activities that affect climate change. Companies assessed with the highest ratings are selected as "Supplier Engagement Leaders."


Initiatives to Promote Awareness of the NTT Group Corporate Ethics Policy

At NTT, top management demonstrates that compliance requires the NTT Group to comply with laws and conduct business with everyone having strong ethics.

Also, the presidents of each NTT Group company have declared their commitment to identify risks related toil legal or illicit activities and never tolerate any form of impropriety. To ensure the effectiveness of the NTT Group Corporate Ethics Policy, we offer training sessions on corporate ethics to employees and, through a website for employees, we explain the declaration in detail and give examples of corporate ethics issues. Employees are reminded of the importance of ethics in June and December each year in an effort to raise their level of understanding. Furthermore, NTT conducts annual surveys of employees to measure their awareness, and the results are then used for awareness enhancement initiatives.

Corporate Ethics and Compliance Training

Corporate ethics training is conducted as part of continuous educational activities for all officers and employees.
This training is tailored to meet the specific compliance and corruption risks of each company throughout the NTT Group. Furthermore, training for officers is also conducted every year.

Anti-Bribery Handbook

The Anti-Bribery Handbook is a revised version of the one we produced in 2015 mainly for the purpose of deepening understanding of regulations concerning the bribing of foreign public officials. In 2021 it came to light that senior NTT Group executives had dined out with persons connected to Japanese ministries and agencies, and reflecting on these incidents, we enhanced the contents and altered the format such as increasing the number of explanations using case studies.

Competition Law Handbook

The NTT Group created a Competition Law Handbook in fiscal 2019 (and revised it once in fiscal 2021) as a tool for ensuring compliance with competition law among employees and it has been made known to all employees at NTT Group companies inside and outside of Japan.
The handbook contains the basics regarding compliance with competition law within a Q&A format, as well as specific examples that might be found within the Company's business activities, in order to instill correct knowledge and understanding of competition law compliance in employees.

Check System for Penetration of Corporate Ethics

The NTT Group conducts an annual survey in order to ascertain the extent to which employees are aware of compliance. At each NTT Group company, four-level monitoring is performed, comprising the departments in charge of business operations and compliance, the Internal Audit Department, and the Audit and Supervisory Board members, to ensure neutral and multifaceted checks are being performed.

NTT checks the status of compliance audit implementation at NTT Group companies with an internal auditing department and directly confirms the status of compliance initiatives inside NTT and at NTT Group companies without an internal auditing department.

Establishment of Corporate Ethics Help Line Contact Point

To prevent illegal conduct or a scandal, each Group company has set up an internal consulting center to handle reports of improper activities. In addition, NTT has established the "Corporate Ethics Help Line" (external contact point) for all NTT Group companies and outsources its operation to a law firm. The NTT Group Corporate Ethical Standards clearly state that people who file reports with these contact points will be protected from any disadvantage arising from the fact that they filed a report, such as wrongful human resources actions (personnel changes, demotions, etc.).

The content of the consultations and reports made to these contact points are investigated and handled by the staff member in charge at the Corporate Ethics Committee of each Group company. At least once a year, the Corporate Ethics Committee of NTT compiles all reported content and response statuses and reports these to the Board of Directors.

In addition, since an independent reporting route to Audit & Supervisory Board Members has been established and is operated as a contact point independent from management, this enables reporting to only the Audit & Supervisory Board Members. Reports made through our Corporate Ethics Help Line (external contact point) are in principle sent directly to Audit & Supervisory Board Members at the same time.

Number of Reports Received by the Corporate Ethics Help Line (External Contact Point)

The number and breakdowns of reports accepted by the Corporate Ethics Help Line are ascertained, and then published in our Sustainability Report and on the NTT Group's sustainability website.

Reports to the corporate ethics help line by type of violation

Disciplinary Actions against Confirmed Violations

A compliance violation or breach of the NTT Group Corporate Ethical Standards is dealt with using the disciplinary measures taken in accordance with the disciplinary code established at each Group company. This includes pay cuts and work suspension, and may also be reflected in assessments (evaluations) and personnel transfers.


Business Risk Management

The NTT Group faces a rapidly changing business environment, including intensified competition in the information and telecommunications sector. In this context, NTT Group companies are exposed to an increasing amount of business risk. The NTT Group strives to minimize the impact of losses that could result from the materialization of risk by anticipating and preventing the occurrence of potential risks. As part of these efforts, NTT has formulated the NTT Group Business Risk Management Manual and has distributed it to all Group companies so that the entire Group can work together to conduct risk management. This manual contains policies for addressing various forms of risk facing the NTT Group's business operations and approaches to coordination among NTT Group companies.

In addition, each Group company has formulated its own manuals and other guidelines, which reflect its specific business operations, business environment, and other factors, and is using these materials to control business risks.

Organization for Implementation

At NTT, Risk Management Regulations are in place, which define fundamental policies concerning inhouse risk management for effective and efficient business operations. Risk management is carried out based on a continuous PDCA cycle under the leadership of the Business Risk Management Committee, chaired by the representative director and senior executive vice president, and comprised of heads of departments and offices as committee members. At the NTT Group, the representative director and senior executive vice president of NTT is assigned ultimate responsibility for risk management, while each executive officer serves as the risk officer for the business area they are placed in charge of.


Identifying Material Risks

From time to time, NTT reviews assumed risks and management policies based on changes in the social environment.

In the identification of Companywide risks, the Business Risk Management Committee leads analysis processes for the risks faced by the NTT Group are formulated and periodically implements risk analyses in accordance with these processes. In addition, after a correlation analyses on these risks, it specifies those risks with the potential to have the greatest impact as material risks, and we decide on countermeasures.

Matters pertaining to risk management are discussed at meetings of the Business Risk Management Committee. As part of risk monitoring, each department in charge reports on the status of monitoring and risk mitigation effects to the Business Risk Management Committee, while the Internal Audit Department conducts individual audits on the status of initiatives to address material risks and reports results to the Board of Directors in the subsequent fiscal year.

Among other things, risks are also identified by focusing on the perspective of conduct risk--where customers and other stakeholders suffer negative consequences as a result of actions taken by the NTT Group--by ensuring better planning and implementation of appropriate measures.


Business Activity 14
Thoroughly reinforcing corporate governance and compliance

Our commitment

We set high ethical standards for ourselves and share them with our business partners

Our objective


Cases of legal actions for anti-competitive behavior, bribery

Basic Policy

We believe that strengthening the system of corporate governance in accordance with the purposes of each principle of the "Corporate Governance Code" of the Tokyo Stock Exchange is an important management issue for maximizing corporate value while meeting the expectations of various stakeholders, including shareholders and other investors, as well as customers, business partners, and employees. Therefore, we are working to strengthen corporate governance based on our fundamental policies of ensuring sound management, executing appropriate decision-making and business activities, clarifying accountability, and maintaining thorough compliance.

NTT is implementing all the principles of the Corporate Governance Code it revised in June 2021

Overview of Corporate Governance Structure

NTT believes that an auditing system based on Audit & Supervisory Board Members, including outside independent Audit & Supervisory Board Members, is an effective means of supervising management. Accordingly, we have adopted the model of being a company with a Board of Company Auditors (Audit & Supervisory Board). In addition, through the election of outside independent Members of the Board, NTT has strengthened the function of appropriately supervising business execution. Furthermore, through its adoption of an executive officer system, NTT intends to clearly separate management-related decision- making and supervisory functions from business execution functions and improve its management flexibility.

Additionally, NTT has voluntarily established a "Nomination Committee" and a "Compensation Committee," each of which consists of five Members of the Board, including three outside independent Members of the Board, to further increase the objectivity and transparency of decisions relating to appointment and compensation.
NTT has determined that governance functions based on a Board of Corporate Auditors (Audit & Supervisory Board) are sufficiently effective to achieve this purpose.


Board Member Compensation Determination Policy and Process

Regarding the composition and level of compensation for Members of the Board of NTT under the Determination Policy, in order to secure objectivity and transparency, NTT established the Compensation Committee, comprising five Members of the Board, including three Independent Outside Members of the Board. Moreover, decisions on the ratios and calculation methods for compensation for Members of the Board, and amounts of compensation for individual Members, are delegated from the Board of Directors to the Compensation Committee. The reason for delegating these authorities to the Compensation Committee is that such committee is composed of two Representative Members of the Board and three Outside Members of the Board, and we believe that it is able to make the appropriate judgements from an outside perspective while also taking a bird's-eye view of the Company's overall performance.


Compensation of individual Members of the Board (excluding outside Members of the Board) consists of a monthly salary (base salary) and a bonus (compensation related to performance over the short term), NTT stock purchase through Board Members Shareholding Association and stock compensation (compensation related to performance over the medium to long term). The composition ratio of compensation in a case where standard business results are achieved is roughly as follows: Fixed compensation: Short-term performance-linked compensation: Medium- to long-term performance-linked compensation = 50%: 30%: 20%.

Clawbacks System

A performance-linked stock compensation system was adopted in fiscal 2021 for members of the board and officers of NTT and its major subsidiaries. A system has been established such that, in the event that an Eligible Member of the Board or Officer engages in significant illegal or inappropriate activity, or takes employment at another company in the same industry without the permission of the company, the system enables the revocation of rights to receive Company Shares under the Compensation System with respect to such person (malus clause) and the request for the return of funds corresponding to previously delivered Company Shares (clawback).



Governance Reinforcement Policy

  1. (1)Deployment of 10 directors (5 independent directors; outside Members of the Board account for 50% of the total).
  2. (2)Deployment of 5 Audit & Supervisory Board Members (3 are outside members, making up a majority).
  3. (3)Implementing a policy to increase the ratio of female directors, corporate auditors and executive officers to at least 30%.
  4. (4)A Nomination Committee and a Compensation Committee, each consisting of 5 members (3 members, being a majority, are outside independent Members of the Board) have been voluntarily established as preliminary deliberation organizations for the Board of Directors.

We are anticipating outside directors to provide a wide range of management perspectives and expert opinions, and we internal and external directors are appointed by actively considering the promotion of diversity (Gender, race, or ethnicity (Ethnicity)). As a result, more than 30% of executives are women, and we are actively promoting diversity. In addition, Article 10 (Directors and Audit & Supervisory Board Members) of the Act on Nippon Telegraph and Telephone Corporation, etc., provides that "Any person who does not have Japanese nationality may not be appointed as a director or an auditor for the Company or the Regional Companies." and therefore nationality cannot be included in the policy. Accordingly, we cannot invite foreign directors under the NTT Act. However, at the NTT DATA Group, which is in charge of global business, we have deployed foreign directors: one has been invited to the NTT DATA Group Corporation, and five have been invited to NTT DATA, Inc.

Tax Policy

Basic Policy

All directors and employees of NTT Group have declared their commitment to complying with all laws and regulations (including their spirits), social standards, and internal company rules, whether in Japan or overseas, and acting in accordance with the highest ethical standards in both private and public activities. In tax-related operations, we also strive to maintain and enhance tax compliance by setting up guidelines and educating our employees.

Governance Structure

NTT has established a basic policy of internal control systems for NTT Group to deal with various risks including tax risks which has been approved by NTT's board. We define each company's roles in tax-related operations as shown below, to the left.


Optimizing Tax costs

NTT and its consolidated subsidiaries should strive to utilize appropriately and effectively the tax relief measures with a view to maximizing shareholder value of NTT Group. NTT and its consolidated subsidiaries shall not implement any measures which may be considered or interpreted as tax evasion by regulators.

Tax Risks

When undertaking international transactions, NTT and its consolidated subsidiaries should ensure such transactions are given due consideration in advance of execution.
NTT and its consolidated subsidiaries should consult with tax advisors and seek advice as necessary.
Furthermore, we have laid out the following measures regarding transfer pricing taxation and controlled foreign companies rules.


Relationship with Tax Authorities

NTT Group aims to maintain good relationships with tax authorities through communication with them. All explanations given to tax authorities should be based on facts. NTT and its consolidated subsidiaries should work with them in a sincere and appropriate manner. If tax authorities were to notify NTT and its consolidated subsidiaries of tax adjustments, NTT and its consolidated subsidiaries should determine the cause of such issue(s) immediately, and take appropriate measures to prevent similar recurrences, unless NTT and its consolidated subsidiaries file a petition of objection or tax lawsuit.


The above amounts are based on "Country-by-Country Report" submitted to Japanese Tax Authorities, and not directly related to the Consolidated Financial Statements.

Business Activity 15
Sharing high ethical standards with business partners

Our commitment

We set high ethical standards for ourselves and share them with our business partners

Our objective


Cases of legal actions for anti-competitive behavior, bribery

Prevention of Bribery

Understanding that it is essential to comply with laws and regulations and to operate its business with high ethical standards, NTT Group prohibits all forms of corruption, including bribery, improper benefits and facilitation payments*1. In particular, with respect to the prevention of bribery, NTT Group has created a "Anti-Bribery Handbook" and distributed it to employees of Group companies, including its overseas subsidiaries, and has also posted the handbook on its internal website to ensure thorough awareness.

Furthermore, for NTT, NTT East, and NTT West, bribery is prohibited pursuant to the NTT Act, and any violations are subject to legal penalties.

  1. Facilitation payments: Small payments used only for the purpose of ensuring ordinary administrative services are processed smoothly

Began holding "NTT Group Sustainability Conferences"

In order to share superior sustainability initiatives across the NTT Group, we have held the NTT Group Sustainability Conference for the entire Group every year since fiscal 2013. This initiative takes the form of a conference setting where operating companies present their achievements of various measures implemented in line with nine challenges and 30 activities based on three themes. The best measures are commended by the President as "superior sustainability measures" at the conference. For the fiscal 2022 Sustainability Conference, which marked our tenth, a total of 113 measures were submitted by both domestic and overseas Group companies. Among these, six were granted the Grand Prize and another six were given the Superior CSR Measures Prize. Screening was conducted online, a continuation from last year. NTT Group employees all over the world could participate in the voting process by hitting the "Like" button for videos featuring the nominated measures. This meaningful time served to enhance employee awareness.

Additionally, the award ceremony was held in a group format in June 2023. As it was the first time members of the press had access to the event, there was a considerable media presence that lent great excitement to the proceedings, which culminated in the selection of an MVP based on a presentation of the twelve measures chosen for a Grand Prize or Superior CSR Measures Prize.

In fiscal 2023 and beyond, through the Sustainability Conference, we will continue to promote the improvement of motivation at Group companies and lateral deployment of measures across them as we aim for the further penetration of sustainability in the entire Group. Details of successful examples are also released outside the company so that they can be viewed by business partners.

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