Our Commitment to Compliance

The term “compliance” (compliance with laws and regulations) has become quite common in the business world, and not only our company, but most companies have expressed that they are giving high priority on compliance. Still, there is no end to the companies that lose the trust of their customers or consumers and suffer serious damage by a violation of laws or socially disapproved behavior if not unlawful.

This is not a problem for someone else. Over many years, our management philosophy and business practices have earned the trust of our customers, business partners and other stakeholders. That trust is a precious and irreplaceable asset that is now integral to the "Nihon Kohden" brand. Even just one compliance violation can destroy such a precious asset.

Compliance is a part of corporate social responsibility and a minimum requirement for companies to continue to exist. Even more so, we strive to create an ethical culture within our business. No violation of compliance is acceptable in Nihon Kohden Group. When faced with making a choice between unlawful act for profits and ethical choices in compliance with laws in our daily business activities, I believe we will choose compliance without question and hesitation.

Nihon Kohden Group is committed to establish and maintain a robust and effective compliance program with zero tolerance for any misconduct and violation of applicable laws and regulations. In order to enjoy perpetual growth as a company with social significance, each and every one of us must ensure compliance and act based on high ethics with good sense as a member of society. 

Hirokazu Ogino
President and CEO
Nihon Kohden Corporation

I. Our Compliance Policies

Nihon Kohden and all of its subsidiaries (collectively, “the Company”) are fully committed to a program of sound ethics and rigorous legal compliance. Aside from being the “right” thing to do, these principles ensure that Nihon Kohden does not lose one of its most valued assets—the trust of its customers, business partners, and stakeholders.

Nihon Kohden’s commitment to ethical and responsible actions is embodied by its Code of Ethics and Conduct (the “Code”). The Code requires all executives, employees, part-time employees, temporary employees, etc. (collectively, “Employees”) to comply with all laws, regulations, and Company policies.

The Code further requires Employees to abide by ethical standards and respect social justice. Employees are obligated to clearly explain the purpose and contents of the Code to customers, distributors, and business partners.

The Company’s Charter of Conduct sets forth guidelines by which the Company and its Employees must abide. These guidelines ensure that the Company’s business activities comply with the Company’s Management Philosophy. The Board of Director has adopted these policies, ensuring that these values are promoted from the highest levels of the Company. These policies are subject to refinement or change as the Board deems appropriate.

II. Compliance Organizational Framework

The Company has a global compliance program effective in all regions in which it conducts business. In order to ensure thorough compliance, the Company has created the following Compliance Organizational Framework:
Organizatoin Chart
Subsequent to the General Meeting of Stockholders, the Board of Directors is the highest decision-making body in the Company. The Management Council, consisting of all of the Company’s Directors and Officers, among other things, discusses all important compliance-related matters and submits them to the Board if the legal resolution is necessary.

The Compliance Committee is an organization consisting of directors, officers, and senior managers designated by the Board of Directors. The Compliance Committee ensures and enhances compliance by (i) establishing and amending the Company's compliance policies; (ii) supervising, evaluating, assessing, reviewing, and continuously improving the compliance program of the Company; (iii) coping with important compliance issues; and (iv) studying, assessing, addressing, and implementing other compliance matters.

The Chief Compliance Officer (CCO) is responsible for management, operation, and implementation of the compliance program throughout the Company.

The Divisional and Local Compliance Officers are empowered and authorized to implement, ensure, and enhance the compliance program in each division or subsidiary. The CCO carefully selects these individuals and regularly communicates with them to verify that global policies are implemented.

III. Internal Reporting System

The Company’s reporting system is an integral component of its strong compliance culture. Employees are required to report any violations of laws, regulations, or Company policies. If Employees do not feel comfortable reporting to their supervisors, they have the option to use an internal or external hotline service.


All integrity compliance-related matters reported through these systems are investigated by the CCO, in coordination with Local Compliance Officers as necessary. Furthermore, the CCO reports all such matters to the Compliance Committee.

The Company forbids all forms of retaliation against individuals who make reports in good faith. However, to alleviate any concerns of reporting Employees, the Company accepts anonymous reports.

IV. Preventing Corruption

Nihon Kohden Code of Ethics and Conduct prohibits any act of illegal bribery or corrupt act towards Japanese and foreign public officials, and ensures compliance with laws and regulations preventing corruption in every region in which Nihon Kohden engages in business, including bribery and corruption-related laws in Japan, the Foreign Corrupt Practices Act (FCPA) in the United States, and the Bribery Act in the United Kingdom. Furthermore, Nihon Kohden has established the Anti-Corruption Policies, which prescribe detailed rules and procedures to prevent bribery, and ensures thorough adherence thereto. The Company also asks business partners including overseas distributors to understand and cooperate for Nihon Kohden's anti-corruption efforts through providing the Nihon Kohden Code of Ethics and Conduct and educational materials for the anti-corruption.

V. Training

The Company provides annual compliance training to all Employees. The Legal Department develops the training, updates it on an annual basis, and distributes it throughout the Company. As necessary, Local Compliance Officers provide additional training, including additional events such as “Compliance Weeks,” in order to educate Employees on local laws, regulations, and policies.

The Company has also developed an Employee Compliance Handbook. This Handbook contains the rules, guidelines, and procedures that all Employees must follow. The Company distributes this Handbook to all Employees, so that it may serve as a reference tool when compliance matters arise on a day-to-day basis. The Handbook has been translated into several languages, ensuring that Employees throughout the world are able to understand and utilize it.

Employees of third parties who work on behalf of the Company in connection with public officials receive anti-corruption compliance materials at the outset of, and throughout the course of, the engagement. The Company conducts regular due diligence of these third parties to ensure that they provide regular anti-corruption compliance training to employees working with the Company.

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