Strengthening of Compliance

Fortification of Compliance

Companies around the world are being required to comply with increasingly strict regulations in all regions. The Group's Compliance Committee has been established to maintain and promote awareness of compliance, and it deliberates and makes resolutions regarding the Group's annual compliance plan, policies for compliance-related activities, and other important compliance-related matters.
The Group's Compliance Committee convenes twice yearly and reports its agenda items to outside directors and Audit & Supervisory Committee members by way of the Board of Directors.
The NYK Code of Conduct, which sets forth norms that officers and employees must follow in the course of their duties, is reviewed periodically to reflect changes in the business environment and social conditions. September has been designated a compliancestrengthening month in which comprehensive compliance checkups are conducted that allow employees to take the initiative in reviewing their conduct and work processes. As part of comprehensive compliance checkup activities, the Company raises employee awareness of compliance issues by conducting a compliance awareness survey and then providing feedback on the survey results via its internal bulletin board.

The NYK Group's Compliance System

  • *Reports to a full-time Audit & Supervisory Committee member periodically and as required
Main Measures Aimed at Strengthening Compliance
  • Established NYK Business Credo
  • Established NYK Code of Conduct
  • Established position of Chief Compliance Officer
  • Established NYK Group Mission Statement
  • Established Internal Control Committee
  • Established Antitrust Law Task Force
  • Established Executive Committee Overseeing Thorough Antitrust Law Compliance
  • Introduced measures to prevent bribery of overseas public officials when establishing new business
  • Revised the NYK Code of Conduct
  • Implemented a written pledge of adherence to the NYK Code of Conduct
  • Revised the company's internal rules related to compliance
  • Revised the NYK Group Mission Statement
  • Revised the NYK Business Credo
  • Revised the NYK Code of Conduct

Compliance Training Programs

The Group strives to improve awareness regarding compliance, antitrust laws, and the prohibition of bribery, among others, through group training and e-learning.

Training Programs in FY2022 Number of programs Number of participants
Compliance training*1 45 1,129
Antitrust, anti-bribery / anti-corruption and sanctions training*2 71 1,896
e-learning 1 7,473
  1. *1Cumulative totals since fiscal 2002: 546 compliance training sessions and 14,876 participants.
  2. *2Training was conducted at 88 domestic and overseas Group companies in 19 countries. Training was conducted eight times in Japan (training for individual companies). Overseas, training is conducted once every one to three years in each region. A cumulative total of 48,338 employees have participated in this training since fiscal 2009.

Taxation Compliance

The NYK Group recognizes its social responsibility to comply with the laws of all countries and to fulfill its obligation to pay taxes, and constantly strives to improve taxation compliance.
In recent years, various problems have arisen with companies seeking to evade paying taxes by taking advantage of differences between corporate activities, national tax regulations and international taxation. We believe international taxation frameworks, such as the OECD's Base Erosion and Profit Shifting (BEPS) project, are essential for securing taxation transparency, and we seek to comply with such international standards.

Whistleblower System

The Company provides several consultation services for employees to discuss concerns about or report workplace misconduct, harassment, and non-compliance. Such services include the Yusen Chat Room, which allows employees to contact outside lawyers, and a consultation line, which is operated by outside contractors. The Yusen Chat Room is available to employees of roughly 64 Group companies in Japan and provides access to six personnel, including an outside lawyer, who are available to listen to a wide range of compliance matters and provide consultation and facilitate whistleblowing on said matters.
Every effort is made to ensure personnel contacting the Yusen Chat Room suffer no adverse treatment and, if desired, the identity of the person contacting the service is kept completely confidential, based on the objective that the information provided will help improve the work environment.

Compliance with Antitrust Laws

In the global shipping industry, which is subject to the principle of the freedom of shipping (free navigation in international waters and innocent passage in territorial waters), anyone is free to enter or leave the market, which means that it is easy for competition to intensify. To reduce the potential negative impacts therefrom, such as interruptions to the stable shipping network and reduced shipping and industry competitiveness in emerging countries, the industry has historically been exempted from the scope of antitrust laws under certain conditions.
With these legal protections diminishing in recent times, it has become common for shipping companies to cooperate through vessel-sharing agreements and slot exchanges in order to fulfill infrastructure responsibilities, maintain and improve diverse navigation networks, and manage the frequencies of port calls. As such, companies in the industry encounter many opportunities to make contact with competitors.
Since September 2012, the NYK Group has been subject to investigation by overseas authorities for allegedly violating antitrust laws regarding the shipping of automobiles and other cargo. The Company and certain overseas Group companies are also subject to class action damage compensation suits in multiple regions.
We offer all of our stakeholders a sincere apology for the concerns that we have caused.
We implemented various measures, including the president's declaring thorough compliance with antitrust laws, building and operating a control network spanning the entire Group in Japan and overseas, and educating and raising employee awareness through training and manuals on antitrust laws and rules concerning contact with other companies in the same industry. Nevertheless, we solemnly accept the fact that this situation occurred and are constructing and initiating a system to ensure absolute compliance with antitrust laws while continuing to raise the awareness of all Group employees* and executive officers.

  • *Includes Company employees, personnel seconded from other companies, and temporary staff
Measures to Prevent Recurrence of Misconduct, Implemented Continuously Since 2013
  • Annual holding of the Executive Committee Overseeing Thorough Law Compliance

    Chaired by the president and attended by directors, executive officers, Audit & Supervisory Committee members, the regional governance officers*1 of overseas regional management companies, NYK head office general managers, and certain Group compliance managers.
    Conducted in September 2022 (195 attendees)
    As of September 2022, the committee convened 17 times, if meetings of the former Executive Committee Overseeing Thorough Antitrust and Anti-Bribery Law Compliance are included.

  • Formulation of guidelines and implementation of risk assessments of all operating divisions, including domestic and overseas Group companies
  • Acquisition of written oaths regarding compliance with antitrust and competition laws
  • Adoption of an application system*2 for officers and employees at the NYK head office and of domestic and overseas subsidiaries who want to participate in industry gatherings
  1. *1As part of governance-strengthening measures, the committee's membership was extended to include the regional governance officers (RGOs) of the four overseas regional management companies beginning from fiscal 2020.
  2. *2The system limits the opportunities of employees for interaction with competitors' employees. If any participation in a meeting with such employees is required, NYK employees must obtain approval in advance and report the agenda of the meeting.

Absolute Prohibition of Bribery

In January 2014, the Company updated its basic policy and guidelines related to prohibiting bribery to reflect the Japan Unfair Competition Prevention Act (prohibiting the bribing of overseas public officials), the U.S. Foreign Corrupt Practices Act, and the U.K. Bribery Act 2010. Since fiscal 2015, the Company has conducted anti-bribery training for employees in Japan and overseas.
In addition, the Company has been a member of the Maritime Anti-Corruption Network (MACN) since fiscal 2015. The MACN is a global network engaged in activities to prevent and eliminate corruption in order to realize fair trade across the entire maritime shipping industry while investigating the root causes of corruption. To reduce the incidence of corruption, the MACN has established cooperative relationships with major stakeholders, such as government officials, government authorities, and international organizations.
In April 2016, the Company established a system to prevent the bribery of overseas public officials. When considering new businesses in high-risk countries, our legal department screens candidate partners and agents for bribery issues and provides advice and checks, including establishing anti-bribery clauses when creating agreements.

Exercising Due Diligence Regarding Bribery

In April 2016, we established a system under which legal departments confirm matters related to bribery when the launch of new business in a high-risk country is being considered. In addition to screening partner and agency candidates for bribery-related problems, suggestions regarding incorporation of clauses related to the prohibition of bribery when concluding contracts are provided and relevant matters are confirmed.

Legal consultation system

When considering new investment and the launch of new businesses, our legal department implements risk management via screening and due diligence in order to conduct checks regarding antitrust laws, bribery, and economic sanctions.

Certification from anti-bribery business organization

The Group has received below certification from Ethixbase360, a globally recognized anti-bribery business organization and leading provider of third-party risk management solutions.

Ethixbase360 has completed a Tcertification due diligence review of Nippon Yusen Kabushiki Kaisha. Certification by Ethixbase360 signifies that Nippon Yusen Kabushiki Kaisha has completed internationally accepted due diligence procedures and has been forthcoming and cooperative during the review process. Tcertification underscores Nippon Yusen Kabushiki Kaisha's commitment to transparency in international commercial transactions.

Tcertification ID: TC3182-6961 (Valid through: 2024/1/15~2025/1/14)

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Political Contributions

As part of its lobbying activities, NYK makes political contributions that comply with the political funds control law, are based on company performance, and are made in accordance with proper internal procedure.
Also, to remain socially responsible and expand business value, we carefully review our lobbying activities and make contributions at amounts considered acceptable.