4.1 Relationships with Clients and Business Partners
In order to earn the trust of clients and business partners, NTT DATA Group carries out business activities in a highly ethical manner in accordance with the Code of Conduct, and implements the Code of Conduct even in a challenging, competitive environment.
We are committed to engaging in fair business practices, entering into appropriate agreements with our clients and in providing services to clients in accordance with such agreements, applicable laws and regulations as well as Company’s Policies and Procedures. We endeavor to communicate sincerely with our clients, to meet their expectations and to understand and solve their problems.
When we procure products and services from business partners, we endeavor to provide our business partners with opportunities to compete fairly, and comprehensively assess their quality, price, delivery dates, and stability of supply, and procure competitive products and services that meet our business needs based on economic rationale.
* For details: NTT DATA Procurement Policy
4.2 Anti-Money Laundering and Exclusion of Anti-Social Forces
Maintaining relationships with criminals, terrorists and other anti-social forces who threaten the social order and security through criminal acts such as violence, force, fraud, trafficking of illegal drugs, and terrorism, can undermine the trust in NTT DATA Group and puts the Group and ourselves at risk. Anti-social forces may also attempt to use sophisticated business transactions involving NTT DATA Group to launder illegally obtained funds.
NTT DATA Group takes a firm stance against anti-social forces, refuses to accede to unreasonable demands, will never maintain a relationship with any such forces, and will not facilitate or engage in money laundering.
When conducting business with clients or business partners, we will comply with laws and regulations prohibiting money laundering and the provision of funds for terrorist activities, and will take necessary measures such as requiring the elimination of dealings with anti-social forces in accordance with Company Policies and Procedures.
4.3 Entertainment and Gifts
Providing or receiving entertainment or gifts by NTT DATA Group beyond the scope of social norms, even if permitted under relevant applicable laws and regulations, may exert an improper influence over the decision-making by the recipient.
When providing entertainment or gifts, we will do so appropriately for legitimate business purposes only, in accordance with Company Policies and Procedures. We will not directly or indirectly offer, promise or provide any illegal, improper or inappropriate entertainment or gifts to anyone including public officials and private individuals, whether or not it is intended to benefit the Company. We will not, under any circumstances, provide any entertainment or gifts that is illegal, improper or inappropriate to influence the behavior of others.
We also will not demand, approve or receive entertainment or gifts beyond the scope of relevant applicable laws and regulations or social norms.
Entertainment or gifts refers to providing a tangible or intangible benefit of value to a third party (including to their relatives and associates). Specifically, this includes the following examples, but is not limited to them:
- Giving money, goods or real estate
- Loaning money
- Loaning goods or real estate at no interest or low cost
- Providing services at no charge or low cost
- Transferring unlisted shares
- Hospitality (including travel, golf, meal and other recreational activities)
- Rebates such as gratuities, kickbacks, and promotional expenses
- Providing employment opportunities or other benefits
4.4 Anti-Bribery and Anti-Corruption
NTT DATA Group’s businesses may have contact with public officials worldwide and bribery and corruption of public officials are strictly prohibited under the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, the Japanese Unfair Competition Prevention Act, and other national and regional anti-bribery statues.
NTT DATA Group complies with applicable national and local anti-bribery laws and regulations in its business conduct, and does not tolerate bribery or corruption of public officials in any way. We do not offer, promise or provide any illegal, improper or inappropriate entertainment or gifts to public officials, and do not engage in bribery.
In cases where bribery and corrupt practices involving public officials are conducted indirectly through a business partner, NTT DATA Group may be held liable whether it knows what is occurring or not. In order to prevent the risk of bribery, we will always pay adequate attention to the risk of bribery and other corrupt practices when dealing with business partners. We will take appropriate measures such as examining the risk of bribery in advance and entering into contracts that include anti-bribery and anti-corruption provisions.
We do not make facilitation payments (generally, small payments to public officials to facilitate the performance of regular public services), regardless of the customs of the country or the region.
Public officials refer to a wide range of personnel, including executives, staff members and representatives of state-owned enterprises, government agencies, ministries and other public organizations.
4.5 Political Contributions and Charitable Donations
Support for political organizations and candidates for public offices and support for charitable organizations by NTT DATA Group must be for appropriate purposes and be carried out with adequate transparency and in any case in compliance with applicable laws and regulations.
NTT DATA Group does not, in principle, engage in political contributions related to the Company’s business or other political activities, unless permitted under applicable laws and regulations and Company Policies and Procedures.
We will, in the event of providing donations or support to charitable organizations related to the Company’s business, conduct such activities in accordance with the steps specified in the Company’s Policies and Procedures and after conducting necessary due diligence and confirming of its reasonableness. However, this does not prevent Employees from providing political contributions or charitable donations privately.
4.6 Fair Competition
In many countries and regions where NTT DATA Group operates, there are competition laws (laws and regulations such as antitrust law or competition law) aimed at protecting fair and free competition, and any conduct that impedes competition is very strictly regulated. Violating competition laws may result in large penalties imposed on the Company and Employees by competition authorities, or may even result in criminal penalties (including fine or imprisonment). In addition, there is a risk that clients and consumers may claim compensation for civil damages from the Company.
NTT DATA Group will conduct business in a fair and free competitive environment in compliance with competition laws.
Therefore, we will not engage in conduct that impedes fair competition, whether with competitors, business partners or any other third party. Such conduct includes:
- Agreements with competitors that violate competition laws, such as agreeing to increase or maintain the price of a product or service; allocating markets or clients; bid-rigging; and joint refusals to deal.
- Conduct with business partners that violates competition laws, such as making a business partner sell its products or services at a fixed price, or imposing a financial disadvantage on a business partner that does not sell at the fixed price.
- Unfairly disadvantaging a business partner by using our dominant position
- Providing a product or service at an unreasonably low price in order to eliminate competitors.
In addition to the above, we must be extremely cautious when contacting and communicating with our competitors. We will not propose or agree to the aforementioned agreements in any form, nor will we exchange competitively sensitive information with our competitors, such as information relating to price and cost or information relating to business partners and clients, in order to avoid suspicion of such arrangements.
4.7 Insider Trading
In the course of business execution, Employees may come across undisclosed information about the Company or other listed companies. Knowing the material facts of a listed company that have not yet been publicly disclosed and using that information to trade in shares or securities, is prohibited in many countries because it impairs the fairness and soundness of the stock market.
We consider the unpublished material information of these listed companies, particularly those material facts that may affect the investment decisions of investors, to be insider information, and if we become aware of such insider information pertaining to NTT DATA Group or other companies, we will not trade in the shares or securities of the company until such information is made public. We also do not communicate insider information to others, including family members, business or social acquaintances and we do not recommend transactions to others based on insider information, unless where an Employee needs to transfer the information for a legitimate business purpose and with required confidentiality measures.
Insider information includes, for example, information that is not publicly disclosed, such as:
- Progress toward revenue and revenue goals
- Forecasts and fluctuations of future earnings or losses of a company
- Information regarding mergers, acquisitions or tender offers under consideration
- New products or services, important agreements, etc.
- An event that has a material impact on a company’s financial situation
4.8 Technology Ethics
NTT DATA Group engages in a variety of research and development activities. The new technologies that are created through such research and development activities must be able to maintain the symbiosis between humans and nature. To this end, NTT DATA Group believes that it is necessary to deepen our understanding of the characteristics of new technologies, constantly explore them, and pursue research and development activities, utilization, and implementation of new technologies to society with high ethical standards such as respect for human rights and consideration for nature.
In particular, Artificial Intelligence (AI) will become more prevalent in society and will affect people’s behavior and decision-making. For the purpose of reducing the number of negative incidents potentially arising from AI, and realizing a human-centered society in which humans and AI truly coexist, NTT DATA Group, as a position to promote research, development, operation, and utilization of AI, will promote the development activities and application of AI technology to business in accordance with applicable laws and regulations, as well as NTT DATA Group’s AI Guidelines.
In accordance with NTT DATA Group’s AI Guidelines, we will promote innovation through dialogue and collaborations with diverse stakeholders by realizing fair and trustworthy AI, while preventing potential discrimination and use of biased data and giving due consideration to privacy and security.
* For details: NTT DATA Group’s AI Guidelines
4.9 Trade Control and Economic Sanctions
In many countries and regions where NTT DATA Group operates, applicable export and import laws and regulations and economic sanctions restrict transfer to designated countries of certain goods, services and technologies, including software and data, in order to maintain international peace and security and protect human rights. Such laws and regulations may also restrict transactions with specific individuals and organizations that threaten international peace, security and human rights, including transferring goods and services and receiving payments.
NTT DATA Group complies with such laws and regulations, economic sanction regimes and trade control requirements established at international and national levels, including implementing appropriate due diligence procedures to ensure compliance.
4.10 Disclosure and Reporting
NTT DATA is a public company listed on the Tokyo Stock Exchange and promotes the understanding and appropriate assessment of NTT DATA Group by all stakeholders, including shareholders and investors, by providing timely and appropriate disclosure of material corporate information such as financial information, management policy, and business activities related to NTT DATA Group in compliance with applicable laws and regulations.
NTT DATA Group prepares financial statements based on applicable accounting standards and accounting policies.
NTT DATA Group complies with applicable tax laws and regulations in the countries and regions in which it conducts business activities, and pays taxes accordingly. NTT DATA Group is committed to maintaining and enhancing its tax compliance processes and controls to mitigate tax risks.
NTT DATA Group provides appropriate information to tax authorities in a timely matter and makes inquiries regarding financial processing, and if tax authorities discover an issue, NTT DATA Group immediately investigates and identifies its cause and adopts appropriate corrective and reform measures to prevent recurrence.
We understand and comply with applicable laws and regulations related to taxation.
4.12 Corporate Citizenship
NTT DATA Group strives to understand global and local social issues through dialogue, collaboration and cooperation with all stakeholders, and fulfills its responsibility as a good corporate citizen towards the development of global and local communities and through social contribution activities that utilize IT.
Our social contribution activities do not end at the workplace. NTT DATA Group encourages Employees to be actively involved in local communities through volunteer and pro-bono activities.