Whistleblowing System

The NX Group has established an internal reporting system to prevent and detect compliance violations early on, as well as correct them. The Compliance and Risk Management Division manages this system and is responsible for compliance within the NX Group.
The NX Group provides various reporting channels. The Compliance and Risk Management Division manages an internal reporting channel for group companies in Japan. Additionally, we have set up an independent reporting channel operated by external counsel for group companies in Japan. We have also set up a Global Reporting Channel, which is an external channel managed by a third-party organization, for group companies outside of Japan. This structure enables us to receive reports from all NX Group officers and employees.
Furthermore, recognizing that respect for human rights of all stakeholders—not only NX Group officers and employees—is fundamental to our compliance management, we have established a reporting channel for external stakeholders, managed by the Compliance and Risk Management Division. This channel allows business partners, suppliers, and other external stakeholders to submit complaints or reports related to human rights and compliance matters. For more information about the NX Group’s human rights initiatives, please refer to the “NX Group Human Rights Policy”.
For the reporting system to be used effectively, it is crucial that reporters will be able to use it without experiencing psychological burden. It is especially important that they do not face retaliation or disadvantageous treatment as a result of their report. Therefore, each reporting channel accepts anonymous reports and ensures the confidentiality of reported content, as applicable. Furthermore, the “NX Group Whistleblowing System Regulations” state that strict confidentiality must be maintained regarding any information that could identify a reporter. The regulations also stipulate that reporters shall not suffer retaliation or disadvantageous treatment as a result of their report. Additionally, the regulations prohibit inquiries into the reporter’s identity, as well as any retaliation or disadvantageous treatment against the reporter or anyone involved in the investigation. Violations of these prohibitions may result in disciplinary action. The regulations also prohibit those receiving reports, those involved in investigations, those subject to reports, and those cooperating in investigations from disclosing investigation-related information to third parties. These provisions strictly enforce confidentiality obligations. The regulations state that these obligations apply to the operation of the reporting channel for external stakeholders as well.
The NX Group promotes awareness of the whistleblowing system and reporting channels on a regular and continuous basis. This is done through the distribution of the “NX Group Compliance Handbook” and portable compliance cards to all officers and employees of the group companies, as well as through the company intranet, internal newsletters, posters displayed in each workplace, and regular compliance training for all officers and employees at each group company. Other methods include new employee training and other group training sessions.

As the responsible division, the Compliance and Risk Management Division determines the necessity and method of investigating reported cases based on the “NX Group Whistleblowing System Regulations.” While protecting the reporter’s identity, the division confirms their intentions and conducts investigations in collaboration with relevant divisions. Based on the results of the investigation, the division reports back to the reporter, implements corrective actions, and confirms the status of improvements, as appropriate. Depending on the case, the division may also consult with external experts, such as attorneys, and conduct appropriate investigations and responses based on their advice.

If a compliance breach is confirmed, we will respond firmly and appropriately in accordance with applicable laws and the group company’s regulations, including disciplinary actions where necessary. We will also promptly implement corrective actions and take steps to prevent recurrence.