The Nichirei Group is engaging in a variety of initiatives aimed at improving its corporate ethics by ensuring compliance with the laws and social norms of all the countries in which it operates. Accordingly, we have created guidelines for proper employee behavior in line with laws, our internal regulations, and corporate ethics, as well as a Code of Conduct and a Code of Conduct casebook, which provides clear examples of appropriate behavior. These documents also include information concerning matters related to the prevention of corruption that have been deemed important from the perspective of international compliance, including insider trading bans and the prohibition of engagement or trading with antisocial forces. In addition to providing this information, we conduct employee compliance training aimed at ensuring a more pervasive understanding of compliance management and a more universal compliance management framework.

Code of Conduct

Nichirei formulated its code of conduct in April 1999, with content focused mainly on Japan. Much of the content became irrelevant as Nichirei expanded globally so, in April 2014, we created an international version of the code of conduct, designed to strengthen corporate governance for the entire Group, and ensure legal compliance and ethical business activities. The main points of the revision include the addition of “respect for human rights” as part of the first principle, derived in part from the Ten Principles of the UN Global Compact. We also incorporated principles we judged to be important from the standpoint of global compliance, including the prohibition of insider trading, and involvement in, or dealings with, antisocial forces.

Nichirei Group Code of Conduct
(Table of Contents, revised April 2014)

  1. Compliance with Laws and Regulations Concerning Respect for Human Rights and Labor
  2. Environmental Protection
  3. Compliance with Laws and Regulations and Internal Regulations
  4. Management and Preservation of the Company's Property
  5. Prohibition on Personal Use of the Company's Property
  6. Prohibition on Insider Trading
  7. Ensure the Reliability of Financial Information
  8. Management and Use of Information
  9. Prohibition of Personal Acts Conflicting with the Company's Interests
  10. Prohibition on Unfair Benefits Given to/Received from Public Officers or Business Partners
  11. Prohibition on Involvement/Trade with Antisocial Forces
  12. Compliance with/reporting of and Consultation on Code of Conduct
Educating Employees about the Code of Conduct to Ensure Compliance

The Group seeks to continue commanding trust, based on the high ethical standards of its board members and employees. Following the April 2014 revision of our code of conduct, we included it and the Group management principles in the employee handbook.

In addition, a guidebook on the use of social media has been distributed to all employees and, on the Group's intranet, we publish a monthly series of slideshow-style materials designed to help employees understand case studies related to the code of conduct.

In addition, the Nichirei Group has been offering e-learning sessions to educate and train employees, based on its in-house educational rules.
The Nichirei Group is committed to continue providing compliance training.

Internal Whistleblower Hotline and Consultation Service

In October 2003, Nichirei introduced an internal reporting and consultation hotline. This allows employees to report, or seek advice on, actions that violate laws or company regulations, or that are ethically questionable.
In FY2015, Nichirei updated its whistleblower hotline in response to the requirements of Japan's new Corporate Governance Code. This requires that internal whistleblower systems be independent from a company's management. To ensure that all employees are aware of the new hotline, Nichirei created and distributed promotional posters for its workplaces and reminder cards for employees.

In accordance with company policy, all reports received are relayed to top management by the administration office, which also conducts an investigation to confirm the facts, implements corrective measures, and provides feedback to the person who made the report (when not reported anonymously).
Anonymity is preserved to protect the identity of the person reporting, while the process is carefully managed to ensure there is no retaliation against, or adverse treatment of, those who are the subject of complaints.