Compliance Approach and Policies
The Nippon Koei Group is increasingly engaged in business activities that span countries and regions with different administrative and economic systems, business practices, and values. In order to conduct business appropriately in a global society and to prepare for all kinds of risks that may hinder business activities, initiatives and guidance that serve as common guidelines worldwide are becoming increasingly important.
We are thoroughly aware that compliance is a source for increased corporate value, and we are striving to achieve highly transparent management. The Group is promoting various activities with the aim of visualizing risks as much as possible in the course of promoting our business, so that we can share information on risks as quickly as possible and share wisdom on how to overcome and respond to them.
Compliance Organizational Chart
Code of Conduct
The Nippon Koei Group has established the Nippon Koei Group Code of Conduct as a basic policy for the Group's common code of conduct, and aims to truly enhance corporate value by incorporating it into the daily actions of each and every executive and employee. It has been translated into seven languages, including Japanese, English, and Spanish, and shared with employees around the world. We aim to create a highly transparent management system and build a relationship of trust across the entire Group, and comply with laws and regulations, respond to social needs. To put into practice our Management Philosophy "Act with integrity and contribute to society through technology and engineering,” we will identify various risks in our business and respond appropriately.
Compliance awareness survey
Since 2007, we have conducted an annual compliance awareness survey targeting all Group employees, including those outside Japan, with the aim of accurately grasping the current state and issues of employee awareness related to compliance and using this information to promote effective compliance activities in the future. In the latest survey, 3,806 employees (78% response rate) from Nippon Koei and domestic Group companies and 590 employees (69% response rate) from local companies overseas of international consulting business responded. All surveys are conducted anonymously with the results disclosed to employees and reflected in our compliance activities.
We conduct compliance training by career level, arrange lectures by outside lecturers for directors and executives, and exchange opinions on compliance violation cases conducted by each department. During training sessions, lectures are given on causes and preventive measures with reference to specific cases, as well as on the Anti-Monopoly Act, Subcontract Act, and Unfair Competition Prevention Act (prevention of bribes to foreign public officials, etc.), acts which are closely related to our business. In addition, E-learning is also used to provide education and testing on compliance and harassment as topics, giving more employees the opportunity to learn about compliance and harassment.
Compliance Reporting System
In order to detect and prevent compliance risks at an early stage, we established the Consultation/Reporting System Regulations in 2003 and have set up a system where employees who become aware of compliance violations or actions that may violate compliance can directly consult or report to the department in charge of compliance or an outside attorney. This system is available not only to our employees but also to temporary employees, Group companies, and business partners. In the past few years, we have received more than a dozen reports annually, most of which were due to poor communication and have not led to any major problems.
Number of Internal Reports
|Fiscal year ended June 30, 2018||Fiscal year ended June 30, 2019||Fiscal year ended June 30, 2020|
Our Group has established overseas business sites all over the world, including sites in Asia, Latin America, and Africa, and is engaged in many projects. While negotiating with local government agencies and companies in various locations with different laws and business practices, we are sometimes faced with risks that could lead to bribery, such as being asked for money in the form of donations, margins, etc. The Nippon Koei Group referred to the United Nations Global Compact in formulating the Nippon Koei Group Code of Conduct and incorporates the four areas of human rights, labor, environment, and anti-corruption and the Ten Principles of the Global Company into our Code of Conduct which we follow. The Code of Conduct stipulates that we will not pursue profits by unfair means and that we will conduct our business activities in compliance with laws and regulations based on fair, transparent, and free competition. In addition, we have established internal regulations for compliance, such as Anti-Bribery Regulations, Appropriate Overseas Expenditure Standards, Antitrust Act Compliance Regulations, and the Antitrust Act Compliance Manual, which we are committed to following. In addition to setting standards for what cases constitute inappropriate expenditure in our Appropriate Overseas Expenditure Standards, we have also established rules that require us to consult with the Head Office in the event of an unreasonable request, rather than making decisions on site alone. We take appropriate measures in accordance with these rules, the Nippon Koei Group Code of Conduct, and relevant anti-bribery laws in Japan and overseas.
As part of our efforts to prevent corruption in the fiscal year ended June 30, 2020, we implemented thorough risk management by conducting anti-bribery training for employees of overseas group companies, checked the understanding of the Appropriate Overseas Expenditure Standards and expenditures through International Consulting compliance audits, and conducted spot checks related to the same standards.
Anti-bribery training for employees of overseas Group companies
We conducted compliance training based on the theme of anti-bribery for employees of overseas Group companies so that basic knowledge regarding anti-bribery can be spread within each Group company in order to prevent bribery.
The training is open to all executives and employees of each company, including non-regular employees, and is held through a system that allows each individual to participate online, with more than 800 Group employees participating in total.