Compliance

Enforcement of compliance

The NYK Group has a number of initiatives to promote compliance. Among the most important are the Compliance Committee chaired by the president (meets twice a year), individual employee confirmations of compliance with the code of conduct, a comprehensive compliance checkup as an attitudes survey of employees (once a year), coordination and training meetings for domestic and international group companies, distribution of NYK compliance standards to domestic and international group companies, case-study-based compliance education (e-learning), and compliance group training. The company also has helplines (Yusen Chat Room,^*1 etc.) in place as warranted by local conditions and continues to enhance them so that it is able to collect information that will prevent improper activities in a timely manner and foster a more transparent corporate atmosphere.

*1 Yusen Chat Room
A six-member team, including an outside legal counsel, provides a broad range of consultations and receives reports regarding compliance questions. Currently open to NYK and 58 Japan-based group companies, this service is being expanded to encompass the entire group.

Compliance with antitrust/competition law

In July 2008, NYK established its Antitrust Law Task Force (ALTF) in the headquarters to respond to the rapid expansion and more strict enforcement of antitrust/competition law around the world and to regrettable violations of such law among our group companies. The ALTF has set up antitrust-law-related internal-governance systems, procedures, and schemes covering about 250 companies in 47 countries (as of the end of March 2011). The ALTF also conducted training courses, carried out e-learning training, and served as consultants on antitrust issues. In Fiscal Year 2010, we created and distributed Japanese and English versions of a Manual about Antitrust & Competition Laws^*1 for group companies and emphasized training for domestic and international organizations. In April 2011, the ALTF was replaced by the Fair Trade Promotion Group to encourage all NYK staff members to cultivate an appropriate understanding of antitrust laws and develop an unconscious law-abiding spirit among all NYK Group members.