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 met twice a year in fiscal 2025 with the aim of thoroughly promoting the NTT Group's corporate ethics and maintaining discipline. It reported to the Board of Directors twice in fiscal 2025, particularly concerning the status of reports made to the Corporate Ethics Help Line, and the Board of Directors discusses 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

Sustainability Indicator

Boundary：NTT Domestic Group companies

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 2025 no illegal conduct associated with bribery or contribution/support was confirmed, and there were zero cases of legal measures taken against NTT related to bribery.

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

The NTT Group settled upon harassment prevention regulations 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 are 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.
We also engage in awareness-raising activities by conducting training targeted at all NTT Group 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. Group companies implement training on important risk management matters tailored to meet the needs of their business (such as compliance and misconduct). Furthermore, compliance training for officers is also conducted every year, and information is provided about a contact point for internal reports of improper activities.

Anti-Bribery Handbook

The Anti-Bribery Handbook (4th Edition, published July 2025) is a revised version of the one we produced in 2015 for the purpose of deepening understanding of regulations concerning the bribing of domestic and foreign public officials. This handbook contains the basic approach to bribery taken by legal systems in Japan and internationally, as well as case studies in an easily understood Q&A format.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 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 (3rd Edition, published July 2025).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. Results are reported to senior management, shared with each organization, and used to drive improvement actions where issues are identified.

Internal Audit

NTT's internal audit function is established as an organization directly reporting to the President and operates independently from audited entities, with the mission of enhancing the value of the NTT Group and contributing to the achievement of long-term strategic objectives.

Internal audits are conducted annually across the NTT Group, in accordance with Basic Policies Concerning the Development of Internal Control Systems approved by the Board of Directors, to assess the design and effectiveness of governance, risk management, and internal control processes. Compliance and ethical standards, are integral components of these processes and are therefore systematically incorporated into the scope of internal audits.

The Board of Directors approves the annual audit plan and regularly oversees the execution and follow-up of audit results, ensuring the effective functioning of the internal audit framework.

The annual audit plan is developed based on a risk assessment process, under which business ethics and compliance are identified as key risk areas. Relevant factors, including internal and external incidents and regulatory developments, are reflected in the selection of audit themes and entities.

In addition, ad hoc audits may be conducted when significant risks related to business ethics and compliance are identified during the fiscal year. The results are reported to senior management and the Board, and corrective actions and preventive measures are continuously monitored.

For subsidiaries that are directly audited by NTT, annual risk assessments are conducted and audit plans are developed based on the results. NTT evaluates both the design and operational effectiveness of corporate ethics and compliance frameworks, including whistleblowing mechanisms, and assesses the effectiveness of the subsidiary's overall internal control environment.

For subsidiaries that maintain their own internal audit functions, NTT periodically evaluates their internal audit frameworks, audit plans and execution, and audit quality. Where necessary, NTT provides support and strengthens coordination to enhance the quality and effectiveness of internal audit activities.

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. 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, in addition to individuals making reports as well as individuals assisting in investigations not being subject to revenge or detrimental treatment due to cooperating with reports or investigations, 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 assisting in an investigation will be grounds for disciplinary actions as established in internal rules.

Reports that come to a point of contact are investigated and responded to by departments in charge via NTT Group companies' Corporate Ethics Committee. In the case that an investigation finds a wrongful act or scandal, Group companies swiftly take corrective and other measures. In the case that corrective and other measures are taken, the person who made the report will be informed of the results of such measures if it is deemed necessary.

Also, 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 Committee. In addition, since the contact point is independent from management, there is an independent reporting route to NTT's Audit and Supervisory Committee. Reporting only to the Audit and Supervisory Committee is also possible. Furthermore, reports made through our Corporate Ethics Help Line (external contact point) are in principle sent directly to the Audit and Supervisory Committee 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.