NEC Corporation

Based on public information, there is some evidence that the President publishes a statement supporting the ethics and anti-corruption agenda of the company. TI notes that only one statement was found and although it was not focused on the ethics and anti-corruption agenda, anti-corruption is a component of the statement. The company therefore scores 1. TI notes that several shorter similar statements are also noted as references. However, these are not assessed to change the score. To score higher, the company would have to show that there is more than one clear statement of a commitment to ethics and anti-corruption from the CEO or Chair of the Board.

Based on public information, there is evidence that the company’s Chairman has been appointed as Chair of the Board of the Business Ethics Research Center. The company therefore scores 1.

Based on public information, there is some evidence that the company’s President demonstrates a personal, internal-facing commitment to the ethics and anti-corruption agenda of the company. TI notes that President Endo gives a keynote address at the company’s Business Ethics Forum. Further, the transcripts of this address are translated into five languages. The company therefore scores 1.

Based on public information, there is evidence that the company has some values listed that represent high ethical standards. The company refers to integrity, fair and open relationships, and fair and transparent competition. The company does not go into sufficient detail about what it means by these values and why they matter to the organisation. The company therefore scores 1.

Based on public information, there is evidence that the company belongs to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption. Specifically, the company is a member of the UN Global Compact.

Based on public information, there is evidence that the company’s Risk Control and Compliance Committee is responsible for its ethics and anti-corruption agenda. It investigates compliance breaches, recommends preventive measures, and discusses measures to address priority risks.

Based on public information, there is no readily available evidence that the company has appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda. TI notes that the company refers to a ‘CSR officer’ in its Supply Chain CSR Guidelines for Suppliers, but it is not clear that this individual has responsibility for implementing the company’s ethics and anti-corruption agenda.

Based on public information, there is evidence that there was an external review of the company’s ethics and anti-corruption agenda in 2013.

Based on public information, there is no readily available evidence of a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management takes place, or evidence of improvement plans being implemented when issues are identified.

Based on public information, there is evidence that the company has a formal process for review and where appropriate updates its policies and practices in response to actual or alleged instances of corruption. The Basic Rule on Anti-bribery establishes strict systems for responding in the event a case of bribery is discovered; it sets forth a reporting route from the person that discovered the incident to the Legal Division, the managing division for anti-bribery initiatives.

Based on public information, there is evidence that the company has a formal compliance risk assessment procedure implemented enterprise-wide.

Based on public information, there is evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. However, from the available information it remains unclear to which business decisions this procedure would apply. The company therefore scores 1.

Based on public information, there is limited available evidence that the company conducts due diligence on third parties. However, it is not clear from publicly available information that this includes agents. In addition, there is no readily available information regarding the frequency of due diligence.

Based on public information, there is no readily available evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.

Based on public information, there is evidence that the company makes clear to suppliers, through policy and contractual terms, its stance on bribery and corruption; however, the consequences of breaches to this stance are not clear. The company therefore scores 1.

The company has informed TI that it does not engage in offset contracting.

The company has informed TI that it does not engage in offset contracting.

Based on public information, there is some evidence that the company has an anti-corruption policy that prohibits corruption in its various forms. However, TI notes that the policy focuses on the giving of bribes to government and public officials. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company’s anti-corruption policy is one of zero-tolerance.

Based on public information, there is evidence that the company’s anti-corruption policy is easily accessible and available in multiple languages.

Based on public information, there is evidence that the company’s anti-corruption policy is easily understandable and clear.

Based on public information, there is evidence that the company’s anti-corruption policy applies to all employees and members of the Board.

Based on public information, there is insufficient evidence that the company has a policy on potential conflicts of interest. TI notes that this falls short due to vague wording and not providing a definition or examples of conflicts of interest.

Based on public information, there is some evidence that the company has a policy for the giving and receipt of gifts, to ensure that such transactions are bona fide and not a subterfuge for bribery. However, there is no readily available evidence that the company sets clear upper limits or a requirement for senior authorisation. The company therefore scores 1.

Based on public information, there is evidence of a statement on the giving and receipt of hospitality (entertainment) that ensures that such transactions are bona fide and not a subterfuge for bribery. However, there is no readily available evidence that the company sets clear upper limits or a requirement for senior authorisation. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a policy that explicitly prohibits facilitation payments.

Based on public information, there is some evidence that the company regulates political contributions in order to prevent undue influence or other corrupt intent. However, TI notes that the information provided publicly is limited and it is unclear if the company publicly discloses such contributions. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, or discloses the issues on which the company lobbies.

Based on public information, there is no readily available evidence that the company regulates or prohibits charitable contributions in order to prevent undue influence or other corrupt intent. TI notes the reference to ‘contributions’ in the Code of Conduct; however, it is not clear that this covers charitable giving and guidelines on the application of the regulations referred to are not provided.

Based on public information, there is evidence that the company provides written guidance to help Board members and employees understand and implement the firm’s ethics and anti-corruption agenda. However, as this guidance is not publicly available it was not possible to assess it for ease of understanding. The company therefore scores 1.

Based on public information, there is evidence that the company has a training programme covering anti-corruption.

Based on public information, there is evidence that 98% of staff have been trained. TI assesses this to cover staff at all company sites.

Based on public information, there is limited readily available evidence that the company provides targeted anti-corruption training to members of the Board. There is some evidence that the upper level managers and the executives are trained in the new rules on anti-bribery, but there is no evidence of the scope of the training.

Based on public information, there is some evidence that the company provides tailored ethics training for employees in sensitive positions. TI notes that reference is made specifically to those in purchasing. The company therefore scores 1.

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest.

Based on public information, there is evidence that the company ‘may’ apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities. The company therefore scores 1.

Based on public information, there is evidence that the company has a well-publicised Compliance Hotline that is easily accessible for employees to report concerns or instances of suspected corrupt activity. Employees are able to use an internal or external Compliance Hotline, with the latter guaranteeing confidentiality.

Based on public information, there is evidence that across geographies all employees have access to the internal and external Compliance Hotlines

Based on public information, there is evidence that the company has formal and comprehensive mechanisms to assure itself that whistleblowing by employees are not deterred. The company conducts annual surveys to receive feedback on its ethics programme, publishes the annual number of cases reported using the Compliance Hotline, and issues case studies where inquiries led to corrective actions.

Based on public information, there is some evidence that the company has resources available to all employees where help and advice can be sought on corruption-related issues. TI notes that employees are directed to ‘their superiors, colleagues, and people from related divisions’. It is unclear that any of these individuals have been trained for the job. The company therefore scores 1.

Based on public information, there is evidence that there is a commitment to non-retaliation for bona fide reporting of corruption. The consequences for breaching this commitment are not made explicitly clear. The company therefore scores 1.