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Exhibit 2

■ Formulation of Rules Related to Dining Events and Similar Events

In addition to clearly describing the code of conduct with respect to interactions with public officials and politicians in the NTT Group Corporate Ethics Charter, the holding company will establish a new Code of Hospitality for Outside Parties, with the main content including rules such as the general principle of not holding individual dining events with the three highest-ranking ministry officials or other public officials with conflicts of interest. Furthermore, similar codes will be implemented at Group companies as well.

(1) Clear Description of Code of Conduct with Respect to Interactions with Public Officials and Politicians

NTT Group Corporate Ethics Charter, Article 3 (with underlining indicating new revisions)
"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."

(2) Main Contents Promulgated by Code of Hospitality for Outside Parties

  • As a general principle, individual dining events with the three highest-ranking ministry officials or other public officials (together with local public officials, heads of government and deemed public officials, collectively, the "Public Officials") with conflicts of interest will not be held. Furthermore, gifts of goods, other than congratulatory or condolence messages, will not be given.
  • Dining events with Public Officials who do not have conflicts of interest will comply with the Code of Conduct for Ministers, Vice Ministers and Parliamentary Secretaries, the National Public Service Ethics Act, the National Public Service Code of Ethics and other regulations.
  • As a general principle, with respect to members of the Diet, private companies and similar persons other than those described above, costs for dining events shall be shared equally, and the number of such events will be subject to limitations.
  • Penalties will be imposed for violations of the code.