EN
Governance
Remaining Trustworthy and Mission-oriented.
To achieve sustainable corporate growth and continuously contribute to realizing a sustainable future, we are committed to practicing efficient governance and solid compliance across the Group. In particular, as advances in the remote world have heightened the importance of ensuring information security as a social concern, we have been actively preventing problems and providing countermeasures.
We will remain faithful to our corporate mission, core beliefs, and policies in order to ensure each and every employee takes action with a sense of responsibility and strive to establish corporate governance and compliance systems throughout the Group to construct an efficient, legally compliant, and ethical management foundation.
Up to the present and into the future, we will endeavor to realize solid governance and enhance corporate value as we continue to advance as a company that has earned the public’s trust.
◆ Priority Activities
Corporate Governance
Corporate Governance Structure
NTT Communications has adopted a governance structure based on a system of Board of Directors and Board of Corporate Auditors and has recently assigned outside directors to bolster its governance functions. The board comprises eight members and is chaired by the president. In principle, it meets once a month to make key management decisions in compliance with laws and regulations, the Articles of Incorporation, and the Board of Directors’ rules.
We have set up an Internal Audit Department at the head office to conduct annual internal audits by selecting audit items based on the results of risk assessment to minimize or prevent management risks and boost corporate value. The Board of Corporate Auditors comprises three auditors. In addition to attending important meetings such as those of the Board of Directors, they hold meetings of the Board of Corporate Auditors to audit the execution of directors’ duties with an emphasis on confirming the legality and appropriateness of management decisions. A dedicated organization and staff facilitate efficient audit operations. The corporate auditors conduct their audits in close cooperation with accounting firms and the Internal Audit Department by periodically sharing information on audit plans and results.
◆ Corporate Governance Structure
Appointing Directors
Directors are appointed with the expectation that they will utilize their extensive knowledge and insight in their respective fields.
◆ Priority Activities
Thorough Compliance and Risk Management
Our Approach
Under the NTT Group Corporate Ethics Policy, NTT Communications will not only adhere to laws and ordinances but will also engage in its daily operations with high ethical standards as a corporate group that retains the trust of all stakeholders, including customers, business partners, shareholders, and society as a whole. We have been developing our compliance promotion framework in accordance with our Global Compliance Regulations, through measures such as establishing a Compliance Committee and assigning compliance promotion leaders and staff to each unit and Group company. At the same time, we consistently promote compliance management across the NTT Communications Group by disseminating top management messages, educating and training employees, and operating points of contact for internal reporting.
We also prepare against various business risks, including large-scale disasters, by establishing systems and mechanisms that enable us to effectively respond to risks in our business operations. This is done under the leadership of the Business Risk Management Committee and involves annually reviewing and revising risk identification, response policies, and countermeasures. In addition to improving Groupwide risk sensitivity and handling the risks that have materialized, these activities are intended to build a system for addressing environmental and social risks in the future through a concerted Group effort.
For more information, see: the NTT Group Corporate Ethics Charter (external site)
Compliance Promotion Framework
The NTT Communications Group acts in accordance with the NTT Group Corporate Ethics Policy, established by Nippon Telegraph and Telephone Corporation and applied throughout the NTT Group, as well as the NTT DOCOMO Group Code of Ethics, established by NTT DOCOMO, Inc. and applied across the NTT DOCOMO Group. To address compliance issues in Japan and overseas that have become increasingly complex in nature, NTT Communications will not only adhere to laws and ordinances but will also engage in its daily operations with high ethical standards as a corporate group that retains the trust of all stakeholders, including customers, business partners, shareholders, and society as a whole.
◆ Framework of Important Internal Rules on Compliance
Specifically, we have established the relevant rules centered on the Global Compliance Regulations that serve as the standard compliance policy for the NTT Communications Group. We also promote compliance under a framework led by the Compliance Committee, which is by a senior executive vice president and supervises compliance promotion leaders and staff assigned to each unit and Group company. Under this framework, we consistently promote compliance management across the NTT Communications Group by disseminating top management messages on compliance, training employees, operating points of contact for internal reporting, and conducting internal audits to confirm and improve the ongoing initiatives at each Group company.
The Compliance Committee consists of compliance promotion leaders (heads of each unit) of NTT Communications and presidents of each Group company and meets regularly every six months to provide a forum for sharing the status of reporting at internal points of contact and holding discussions on measures for establishing corporate ethics. The committee reports on the content of its discussions for each fiscal year to the Executive Council and Board of Directors of NTT Communications.
◆ Compliance Promotion Framework
Looking ahead, even as we respond to regulatory changes in Japan and overseas and the evolving business environment, management and all Group employees will engage in ethical business practices and seek to strengthen the Group’s compliance system worldwide.
In light of the increasing importance of supply chain compliance, including enforcing legal compliance among subcontractors, we include a clause seeking compliance with guidelines such as the NTT Communications Corporation Guidelines for Sustainability in Supply Chain in our subcontracting agreements as part of an ongoing effort to ensure compliance across our operations, including the supply chain.
Awareness-raising Programs and Training for Thorough Compliance
To ensure thorough legal compliance and fair business activities, companies are required to implement ongoing awareness and training programs for employees and directors.
The NTT Communications Group is actively pursuing internal awareness-raising activities through various programs including compliance training, and by conducting employee awareness surveys on corporate ethics, inviting entries for compliance slogans, and regularly providing information via the internal website.
Initiatives for Preventing Corruption
To ensure compliance with the prevailing laws and regulations in Japan and overseas on preventing corruption, including bribery and bid-rigging, NTT Communications adheres to the Anti-Bribery Handbook compiled by its parent company Nippon Telegraph and Telephone Corporation, as well as its own internal rules, to prevent corruption.
We have stipulated detailed rules against bribery as well as prevention guidelines under the Global Compliance Regulations to clearly demonstrate we have proper measures in place to combat this concern, and we are determined to stringently address specific acts of bribery such as facilitation payments. As part of our Groupwide effort to prevent corruption, we follow procedures in various countries with regard to prior approval in cases where providing benefits to public officials are tolerated under law and examine the eligibility of agents and consultants hired to execute our operations. We also include prevention of corruption as a topic in our compliance training in an ongoing effort to raise awareness.
Appropriate Advertising
Telecommunication services such as the Internet and smartphones have become indispensable infrastructure for daily life and business. Moreover, these areas are undergoing rapid technological innovation in which the content, providers, contracts, and other aspects related to services used by customers are becoming increasingly sophisticated and diverse.
NTT Communications will create new value by proposing fixed-mobile convergence services and integrated solutions under the new corporate business brand “docomo business ” and will provide these services to all types of customers, from large corporations to small and medium enterprises. In light of the evolution of the business environment, such as expanded service offerings and the rising number of customers, we are required to provide customers with more appropriate information and to display advertisements in an easy-to-understand manner. To this end, NTT Communications practices established operational procedures, including an accountability system related to advertisements and a screening system for advertising. At the same time, we continuously strive to ensure the proper display of advertisements by reviewing our advertising screening system and business processes in light of “docomo business.”
Initiatives on AI Ethics
Accompanying the rapid progress in technology, AI has spread through incorporation into products and service functions, while concrete applications of AI are being promoted in various areas. On the other hand, ethical concerns over AI-based evaluation and judgment, such as the potential for discrimination and prejudice, have also materialized. In view of our pursuit of businesses such as Smart World and B2B2X, we formulated the NTT Communications Group Basic Policy on AI in April 2021 with the objective of ensuring the sound and reliable use of AI founded on an understanding of its possibilities and inherent risks, and we began applying the policy to manage service development and other processes.
For more information, see the NTT Communications Group Basic Policy for Artificial Intelligence
Consultation Hotline
The NTT Group has established a common external contact point for consultation and reporting operated by a law firm for all Group companies. The NTT Communications Group has also set up its own hotline for reporting and consulting on compliance issues and a contact point for consulting on human rights issues. We are fostering an open corporate culture by creating an environment that encourages employees to seek consultation and by swiftly and appropriately responding to their concerns and reports.
Business Risk Management
The basic elements of risk management are defined in the Risk Management Rules we established to achieve sustainable corporate growth by anticipating and preventing the occurrence of potential risks that exist in and around our business and by minimizing any loss in the event they materialize. As a system and mechanism for effectively addressing major risks that may affect our business management, we set up the Business Risk Management Committee, chaired by the senior executive president, to construct and implement a PDCA cycle for risk management.
The heads of units and presidents of Group companies comprising the members of the Business Risk Management Committee meet twice a year to address the changing business environment by defining risks that require action, identifying material risks, and discussing issues such as initiatives for promoting risk management. In fiscal 2023, the committee focused on the current status of internal and external risks as well as their impact and scope to identify 19 items, which were also assessed according to their assumed frequency of occurrence and impact. As a result, information security was identified and addressed as a material risk for the second consecutive fiscal year. In addition, we have recently designated geopolitics as a key risk due to the need to promote and strengthen new initiatives in response to economic security legislation, as well as corporate governance, in order to strengthen effective initiatives under the “docomo business” brand, and measures for risk management were reinforced accordingly. Each risk item, including material risks, is handled by a Business Risk Management Subcommittee consisting of all units that meet each month to implement a practical PDCA cycle for risk management by examining and analyzing the occurrence of risks and discussing countermeasures. Operational audits are conducted to confirm the status of each unit’s measures against risk, and similar activities are extended to principal Group companies in Japan to promote risk management throughout the Group.
Crisis Management
Since the Great East Japan Earthquake, we have seen growing public interest in crisis management for times of emergency, such as large-scale natural disasters. With a renewed awareness of our mission as a company responsible for maintaining social infrastructure through communication, we have strengthened our management structure to accelerate our response to contingencies and have sought to instill that awareness in all departments by ensuring strict adherence to manuals and organizing drills. In the event that a material risk occurs, we will set up a Disaster (Accident)/Risk Response Headquarters, headed by the president or senior executive president, as needed in order to provide the structure for gathering accurate information and making effective decisions. Thereafter the Disaster Response Headquarters will take the lead in addressing the situation on the ground.
In July 2021, we established the Supply Chain BCP Guidelines to strengthen business continuity across the entire supply chain. We are working to ensure stable procurement with the cooperation of our suppliers.
Since fiscal 2013, we have laid out an operational plan to prepare against a pandemic in compliance with the Act on Special Measures for Preparedness and Response against Pandemic Influenza and New Infectious Diseases, and we are currently formulating a related concrete business continuity plan.
For more information, see: NTT Communications’ initiatives against disaster (in Japanese Only)
Internal Controls
In accordance with the new Companies Act, enacted in May 2006 and revised in May 2015, we have drawn up basic policies for establishing a system of internal controls for the entire NTT Group. Concurrently, as a member of the NTT Communications Group, the Board of Directors resolved to implement the measures necessary for the system. We are also working to reinforce and upgrade internal controls over financial reporting in line with the requirements of the Financial Instruments and Exchange Act, enacted in June 2006.
Basic Approach for Maintaining an Internal Control System
- 1. In maintaining a system of internal controls for complying with laws and regulations, managing any risk from losses and carrying out proper and efficient business operations, NTT Communications takes a variety of measures to prevent and minimize loss.
- NTT Communications has established the Legal and Internal Audit Department to maintain and assess effectiveness with regard to operational status of the above system of internal controls. As a monitoring organization, the department is responsible for regular audits and special audits of high-risk areas common to the NTT Group, in keeping with the standardized auditing criteria of NTT.
The necessary improvements are made following assessments of system effectiveness. - NTT Communications will cooperate with NTT DOCOMO,INC. and take appropriate measures to ensure the reliability of its system of internal controls for financial reporting under Japan’s Financial Instruments and Exchange Law.
- The president is responsible for ensuring the development and implementation of the system of internal controls.
- We will take all necessary steps to comply with NTT DOCOMO, INC.’s Basic Policies Concerning the Maintenance of Internal Control Systems.
Internal Audits
At NTT Communications, Internal Auditing plans to achieve its goal of implementing audits that benefit management by taking the lead in conducting internal audits of internal organizations and Group companies, with an emphasis on business risks. Through the audits, we seek to reduce and prevent the manifestation of management risks while also proposing operational improvements to enhance the corporate value of the entire NTT Communications Group.
◆ Priority Activities
Enhanced Value Chain Partnerships
Our Approach
We will manage the entire supply chain with high ethical standards by promoting and strengthening the sustainability of NTT Communications Group suppliers to ensure a reliable procurement system for our customers. To that end, we established NTT Communications Corporation Guidelines for Sustainability in Supply Chain and focus on developing mutual understanding and relationships of trust with our suppliers. At the same time, we are developing a procurement system based on the concept of sustainable procurement, which extends beyond environmental issues, with thorough consideration of humanitarian and social issues as well. We will strive to enhance our partnerships to properly understand and address the impact of our business activities on the value chain and engage in a dialogue with our stakeholders to meet the various requests and expectations from society, toward operating business on the trust of our stakeholders.
◆ Summary of NTT Communications Corporation Guidelines for Sustainability in Supply Chain
- NTT will strive to provide competitive opportunities with fairness to both domestic and foreign suppliers, and to build mutual trust and understanding.
- NTT will conduct economically rational procurement of competitive goods and services that meet its business needs, deciding suppliers based on quality, price, delivery times and stable supply in a comprehensive manner.
- NTT will contribute to realizing a sustainable society by doing procurement with an emphasis on human rights, the environment, safety,and other critical issues, in compliance with laws and social norms.
With the basic ideas of the previous Guidelines for CSR in Supply Chain, the new guidelines clarify the positioning of our requests to suppliers (code of conduct). The guidelines as a whole now require stronger cooperation, such as requesting primary suppliers to take responsibility for seeking compliance from upstream suppliers, establishing management systems to comply with each guideline, and taking actions such as suspending business with suppliers who do not correct violations. The content of each specific item has also been enhanced.
◆ NTT Communications Corporation Guidelines for Sustainability in Supply Chain★Indicates the main additions and enhanced item
Click here for our Procurement Activities
Dissemination of Sustainable and Green Procurement
We have formulated the NTT Communications Corporation Guidelines for Sustainability in Supply Chain, which encourage procurement policies for respecting human rights and protecting the environment, ensure the quality and safety of products and services, and recognize the overall needs of society. When selecting and entering into agreements with new business partners, we have designated our own sustainability compliance items, in addition to credit screening criteria, which include confirming corporate initiatives on human rights and labor issues. When we determine that a company has failed to meet our criteria and thus represents a risk, we do not trade with them.
To promote sustainable procurement, we conduct SAQs using EcoVadis, a global rating organization, and also hold meetings to exchange ideas on details and confirm that there are no risks.
Enhance Stakeholder Engagement
Building and enhancing stakeholder relationships are extremely important for the NTT Communications Group toward becoming a corporate group that creates the future and maintaining business operations. In a renewed effort to improve stakeholder engagement by disclosing information on sustainability, we have categorized our disclosure from the perspectives of required information, information that should be shared, and communication media. In addition to this report, we will engage with our stakeholders through our website, various events, and surveys.
◆ NTT Communications Stakeholders
◆ Priority Activities
Continuously Strengthening Information Security
Our Approach
To address information security issues that are growing in sophistication and severity due to social trends for realizing a remote world, we are continuously promoting our security governance and strengthening our cyber security measures. We are conducting information security audits and implementing cyber security measures in accordance with the ISO/IEC 27001 international standard for information security management systems to reinforce its governance across the NTT Communications Group. As ICT professionals, we will also focus on establishing environments that prevent the occurrence of personal information leakage by developing human resources capable of maintaining a seamless framework across information and operational technologies.
Ensuring Information Security
Basic Policy
“The NTT Communications Security Declaration has been our basic policy for conducting business based on our belief that adhering to strict security management standards will lead to improving security and delivering benefit to our customers.”
NTT Communications Security Declaration
At NTT Communications, we believe that our most important mission is to provide our customers with services which they can use with the assurance that their critical information is being protected and to contribute to improving the security of our customers. We view security as the single most important issue to be addressed in providing services, and we pledge to work together with our customers to provide the best in security for their needs. To achieve this end, we do our utmost to ensure security throughout all aspects of the value chain, from the development of technologies and services to the construction and operation of systems. As ICT professionals, all of us at NTT Communications are committed to improving our capabilities to respond to security issues.
Three Resolutions
- We regard security as our top priority in providing services to our customers, and we will do our utmost to enhance their security.
- As an ICT solution partner entrusted with our customers’ vital information, we will work with them at all times to ensure their security.
- Business partners and contract employees are also important supporting members of NTT Communications. We will therefore collectively strive to ensure our own security.
Protection of Customer Information and Personal Information
We protect customer personal information in compliance with the relevant laws and regulations as well as guidelines published by the Ministry of Internal Affairs and Communications, operating under an effective system of information management to stringently implement our Personal Information Management Rules , which define the basic elements of protecting customer information and personal data. When subcontracting the handling of customer personal information, we select subcontractors that meet the required standards.
We have been operating since 2002 under the ISMS certification*1, which is primarily for our corporate sales and maintenance divisions, and since 2004 under the PrivacyMark certification*2. In response to the revised Personal Information Protection Law that came into effect in April 2022, we have revised our internal regulations to strengthen our operations, including lifecycle management of customer information. With regard to raising employee awareness, we are taking actions such as conducting annual training sessions for all directors, employees, and partner employees. With regard to GDPR, we had been operating under the EU Customer Personal Information Management Guidelines, which stipulate the handling of personal information in the EU. In addition, in fiscal 2022, we took the opportunity of becoming a member of the new DOCOMO Group to introduce the Privacy Impact Assessment System (PIA System) to ensure appropriate use of personal data based on the Behavioral Principles of the NTT DOCOMO Personal Data Charter. We will continue to protect customer privacy and promote the appropriate use of data so they can use our services without concern.
*1 A screening and certification system for assessing whether an information security management system conforms to JIS Q 27001 (ISO/IEC 27001) standards.
*2 A registered trademark granted for use by companies that have been certified by the Japan Information Processing Development Corporation as having established a system for appropriately protecting personal information in compliance with Japanese Industrial Standard JIS Q 15001 requirements for personal information management systems.
For more information, see: our policy concerning the handling of personal information
For more information, see: the NTT DOCOMO Personal Data Charter (external site)
Raising Workplace Awareness and Providing Thorough Training
We have consistently pursued our initiatives by positioning “Continuously strengthening information security” as a key item in the Priority Area of “Governance” under our Sustainability Policy and by designating it as a main initiative. These encompass a wide range of activities such as strengthening the reliability of our information handling processes, obtaining and maintaining ISMS certification, and conducting security surveys. We proactively provide training for employees in order to raise workplace awareness as a critical responsibility for an ICT enterprise.
◆ Information Security Training Attendance
Information Security Management Structure
We set common targets on information security management for our operations in Japan and overseas, based on the requirements of ISO/IEC 27001. Specifically, we implement the following measures under the leadership of the chief information security officer (CISO): formulate rules and standards and educate all employees to raise their awareness, draw up and implement Companywide information security policies, monitor compliance with information security regulations and take any necessary corrective action, and ensure a unified response to information security incidents.
◆ Security Management Framework
