At Nakanishi, in order to achieve our corporate mission and contribute sustainably to society, we have set out Compliance Behavioral Guidelines which all officers and employees must comply with in their daily work. In addition, we require all our overseas bases to comply with the laws and regulations of each country in our Group Governance Code.
Initiatives
Compliance Promotion Structure
We have established a Compliance Committee chaired by the President and Group CEO, and its activities work toward resolving compliance issues such as monitoring and supervision of the state of compliance with laws and regulations and implementation of compliance education.
Education
A compliance newsletter is issued monthly for all employees in an effort to improve compliance awareness within the company. Additionally, by periodically distributing commentary on the Compliance Behavioral Guidelines, we aim to improve the understanding of its content. On an individual level, we conduct education on overall compliance and training for managers via e-learning with the objective of thorough observance of compliance.
Preventing Corruption
In the Compliance Behavioral Guidelines, we specify our policy stating, “We never offer inappropriate gifts or entertainment of any kind. Nor do we ever receive inappropriate gifts or entertainment of any kind.” and explicitly prohibit any form of corrupt practices. Specifically, in addition to prohibiting any exchange of inappropriate gifts or entertainment with business partners, we prohibit the provision of benefits with the intention of inciting fair trade, and include conduct such as conflicts of interest that would go against the company’s interests and the mixing of public and private affairs on our list of prohibited acts. While providing internal education for all employees through initiatives including commentary on behavioral guidelines and explanations on specific cases, we will work toward putting in place internal checks and audit systems and ensuring thorough corruption prevention.
Preventing Child Labor and Forced Labor
We declare that child labor and forced labor are banned in its Business Partner CSR Guidelines. Setting either the minimum working age or the end of compulsory education, whichever is greater in that particular country or region, as a condition for employment, we comply with laws and regulations stipulated by various countries and regions, and prohibit labor resulting from forced labor, indentured labor, slavery, and human trafficking, etc.
Preventing Harassment
We strive to prevent infringements on human rights by providing training designed to prevent all forms of harassment and ensuring people are fully versed with the correct knowledge for working. If an issue is discovered, we investigate the facts and deal with it in accordance with our company regulations.
Whistle-blower System
We operate a whistle-blower system through which employees are able to discuss issues they have discovered that violate compliance. Hotlines for this system have been established with the Internal Audit Office internally and with an external agency outside the company, and it is possible to engage in whistleblowing through telephone, fax, email, and postal mail. Information regarding the details involved in whistleblowing and the privacy of the inquiring party is handled strictly, and the system is operated based on regulations which ensure employees will not be penalized in any way because of whistleblowing or consultation.
Appropriate Relationships with Medical Workers
We comply with the regulations set by the Japan Federation of Medical Devices Associations (JFMDA) and the Japan Fair Trade Council of the Medical Devices Industry, and with our internal regulations and employee behavior policies, to carry out corporate activities that maintain high ethical standards.
With the goal of achieving a broad understanding of how we contribute to the development of the life sciences, including medicine and medical engineering, and promote corporate activities that ensure a higher standard of ethics, in compliance with the JFMDA’s “Transparency Guidelines for the Medical Device Industry and its Relationships with Medical Institutions and Other Organizations,” we publish information about our corporate activities related to medical institutions and medical personnel.
Dealing with Antisocial Forces
We take a firm and organized stand against antisocial forces and groups that threaten the order and safety of civil society, and will not provide them with benefits of any sort. In addition, we cooperate with investigating authorities to the fullest extent provided by law.