Corporate Ethics and Compliance

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.

Targets and Performance

(7) Number of anti-competitive violations / number of anti-corruption violations
Fiscal 2023 results: 0 cases (NTT Group-wide)
Fiscal 2024 target: 0 cases (NTT Group-wide)

(14) Rate of direct dialogue with key suppliers requiring improvement requests [ethical]
Please see the following page:

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 2023 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.A few Group companies make political contributions in accordance with the relevant laws and regulations as well as the companies' respective codes of corporate ethics at their own discretion while keeping to their code of responsibility after approval from the Board of Directors.

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 such as training focused on new graduates and mid-career hires on subjects such as compliance with the Anti-Monopoly Act.

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.

To ensure the effectiveness of the NTT Group Corporate Ethics Policy, we offer training sessions such as Corporate Ethics and Compliance Training and compliance training 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 following an assessment of the efficacy of measures.

All officers and employees of the NTT Group observe the following points based on the NTT Group Corporate Ethics Policy.

Harassment prevention regulations

In 2020, the NTT Group settled upon harassment prevention regulations and made them known to all NTT Group companies in order to prevent harassment in the workplace.These regulations state that workplace sexual harassment, harassment relating to pregnancy, birth, childcare, or nursing, power harassment, and other types of harassment, as well as words and actions that could damage the dignity or character of someone else is prohibited, while also establishing initiatives to respond to consultations and reports, punish those who commit harassment, protect those seeking consultations or who want to make a report, and prevent reoccurrence.
These ideas are also reflected in training targeted at all company employees so that the regulations are more thoroughly understood, preventing various kinds of harassment at work.

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. Additionally, we thoroughly carry out our duty to protect the confidentiality of information that could identify individuals making reports, whether they are named or anonymous. Also, our internal regulations specify that it is forbidden to search for a person who made a report, and acts in violation of the prohibition on revenge or detrimental treatment of a person making a report or those involved in an investigation will be grounds for disciplinary actions.

Reports that come to a point of contact are investigated and responded to by departments in charge via NTT Group companies' corporate ethics boards. Once or more per year, a summary of the content of and the state of response to all reports is given to the Board of Directors by NTT's corporate ethics board.

In addition, since the contact point is independent from management, there is an independent reporting route to Audit & Supervisory Board members. Reporting only to Audit & Supervisory Board members is also possible.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 Corporate Ethics Helpline Reports and Breakdown

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.