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Summary of Investigative Report from the Special Investigations Committee

Exhibit 1

(1) Summary of Investigation

  • Subject Period of Investigation: April 1, 2016 to March 16, 2021 (the date of the first meeting of the Special Investigations Committee)
  • Scope of Investigation: Dining events between members of management of NTT Group (Holdings, NTT East, NTT West, NTT Communications, NTT DOCOMO and NTT DATA) and senior officials at the department head-level or above at the Ministry of Internal Affairs and Communications as well as the three highest-ranking officials in in the Ministry of Internal Affairs and Communications
  • Method of Investigation: Conducting reviews of related materials (including settlement-related materials) and hearings

(2) Facts Determined as a Result of the Investigation

  • It was determined that there were 29 instances of dining events with senior officials from the Ministry of Internal Affairs and Communications in which costs were not shared equally.
    (Dining events with three highest-ranking officials: five instances; dining events with other government officials: 24 instances)
    * There were also eight instances of dining events in which costs were shared equally.

(3) Determination of Wrongdoing in Connection with the Case

  • As a result of the Investigation, it was not determined that there were any requests for favors made by officials of the Ministry of Internal Affairs and Communications, or requests for favors made by NTT Group, at dining events between members of NTT Group management and Ministry of Internal Affairs and Communications officials.
  • In addition, no evidence was found to suggest that the government's judgment regarding the acquisition by NTT of NTT DOCOMO as a wholly owned subsidiary, or in NTT DOCOMO's reduction of mobile phone rates, was distorted.
  • However, the dining events attended by officials from the Ministry of Internal Affairs and Communications led to violations by such officials of the National Public Service Ethics Code as promulgated under the National Public Service Ethics Act, and management of NTT Group cannot avoid criticism for inducing and promoting such violations. Furthermore, the events attended by the three highest-ranking officials of the Ministry of Internal Affairs and Communications were dining events that could cause suspicion amongst citizens.
  • NTT Group management must sincerely reflect on the fact that such dining events have led to severe criticism from citizens and society, and must make every effort to ensure that such a situation will not occur again.

(4) Analysis of Cause and Background

  • Based on the results of the hearings conducted by the committee, it was determined that management lacked awareness and sensitivity towards the National Public Service Ethics Act/Code of Ethics and the Ministerial Code.
  • As the background behind the lack of awareness and sensitivity, it was mentioned that there were no specific internal rules in place for holding dining events in compliance with the National Public Service Ethics Act/Code of Ethics and the Ministerial Code, and no trainings were being conducted to comply with the National Public Service Ethics Act/Code of Ethics and Ministerial Code.
  • In addition, the fact that the monitoring system for dining events as proposed by management did not work sufficiently is also believed to be one of the causes of the Case.

(5) Recommendations of Measures to Prevent Reoccurrence

  • New internal rules should be established to comply with the National Public Service Ethics Act/Code of Ethics and the Ministerial Code, and the purpose of existing internal rules should be clarified.
  • Training should be conducted on the National Public Service Ethics Act/Code of Ethics and the Ministerial Code in order to promote understanding of the significance of observing the National Public Service Ethics Act/Code of Ethics and the Ministerial Code and understanding of specific provisions, including that dining events with interested parties are not permitted unless costs are shared equally.
  • For dining events that are proposed by management, in addition to confirming whether such events are appropriately conducted in accordance with the newly formulated rules, measures should be put into place to require that checks are done by appropriate bodies beforehand in the event of dining events with politicians and public officials.
  • Furthermore, after convening any dining events, internal audit departments should implement post-event checks, such as confirming the number and concentration of dining events with certain politicians and government officials, and confirming the contents of discussions at the dining events and the purpose of such dining events.
  • Rather than solely implementing measures to prevent the reoccurrence of events such as the Case, in the future, the Company should also continue its efforts to investigate problems within its organization on its own.