COMPLIANCE

Nissan understands that acting with integrity and high standards is of paramount importance, not only because it is the right thing to do, but also because it allows all employees to perform at the highest levels. Nissan expects all employees to maintain the highest ethical standards as they carry out their duties. To raise compliance awareness throughout the company, Nissan has established a Global Risk & Compliance Office, as well as specialized departments, and appointed officers to promote compliance in each region where it operates.

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Enhancing Compliance
(Preventing a Reoccurrence of Nonconforming Final Inspections)

Regarding Nonconforming Final Vehicle Inspections at Nissan’s Plants in Japan

After the discovery in September 2017 of nonconformities in the final vehicle inspection process at its plants in Japan, Nissan began a full and comprehensive investigation of the facts, including the causes and background. We have since implemented appropriate countermeasures based on the results. Strict compliance is a top priority for our management, and we have taken it upon ourselves to examine the current situation with regard to compliance in every area of our business. When issues do arise, we take appropriate measures, and we are committed to promoting and enforcing compliance and awareness thereof in all operational areas.

  • Click here for more information on nonconforming final vehicle inspections.
Executing an Overhaul of Compliance Checks

At Nissan, following the discovery of nonconformities in the final vehicle inspection process at vehicle assembly plants in Japan, we were determined to ensure that such a thing could never happen again. Accordingly, in fiscal 2018, we carried out an overhaul of compliance checks. Legal professionals worked with the departments responsible to identify the laws and regulations that we must obey in each area of operations. A list was created of the laws and regulations thus identified, and the situation with respect to compliance was confirmed by the responsible departments based on check sheets created by an audit company. Additionally, instead of treating these overhauled compliance checks as a one-time project with a definite ending, we are building a robust system for regular monitoring of compliance.
In the future, comprehensive compliance checks will be undertaken at affiliated companies in Japan and overseas, and our compliance framework will be strengthened to give us visibility into legal compliance on a global level.

Anti-Bribery

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Anti-Bribery: Policies and Philosophy

Nissan does not tolerate corruption of any kind, whether individual or systemic, committed by a company or a government. The Nissan Global Anti-Bribery Policy* establishes a global framework for preventing and responding to corruption. Different cultural contexts may result in what seem to be gray areas, and Nissan respects local customs and traditions, but corrupt practices are never acceptable.

  • Click here for more information on the Nissan Global Anti-Bribery Policy.
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Anti-Bribery: Management

Nissan has established a Global Code of Conduct* and Global Risk & Compliance Office as well as departments and officers at each of its operations worldwide with responsibility for promoting compliance measures.
Moreover, all Group-affiliated companies have introduced their own codes based on the Global Code of Conduct. The Code of Conduct is supported by training courses to ensure full understanding of its content.
Nissan’s overall policy management strategy was redesigned in fiscal 2016 in order to support the promotion of compliance knowledge, including the creation of a Policy on Policies and related standardized procedures. With this enhanced process, Nissan seeks to ensure across-the-board understanding, making sure all employees are fully aware of Nissan’s policies and able to act appropriately when faced with compliance issues.
Nissan has created a series of internal regulations that are applied globally, covering areas such as decision-making, insider trading, personal information management, information security, bribery and corruption and use of social media. With these policies in place, Nissan is working to heighten awareness and reduce infractions.
Employee education programs to promote compliance are held regularly in all regions in which Nissan operates. For example, training sessions based on the Global Anti-Bribery Policy have been conducted in all regions.
Moreover, in fiscal 2018, one instance of potential bribery was discovered by the Global Compliance Office. Following investigations and on the advice of outside legal counsel, the instance was reported to the appropriate authorities. Disciplinary action has been taken against those involved.

  • Click here for more information on the Global Code of Conduct.
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Business Ethics

Business Ethics: Policies and Philosophy

Employees and Compliance

  • Each Regional Compliance Committee oversees various local compliance committees as appropriate.
Global Code of Conduct

Nissan’s Global Code of Conduct contains our core principles for doing business with honesty and integrity, in full compliance with established laws and regulations in all locations in which we operate. The Code of Conduct’s standards apply to all employees within Nissan Group companies, and every employee is responsible for upholding and adhering to the Code. The Code of Conduct is reviewed for revision at least once every three years to ensure that it evolves along with the company and society. The Code is also updated promptly, outside the regular review cycle, in response to significant changes to laws or other major factors affecting it. The Code of Conduct was most recently updated in 2017, when employee and customer safety were proactively added as a new key pillar of the Code. During fiscal 2018, executive messages regarding the Global Code of Conduct were delivered to employees through our intranet, covering areas of transparency and speak-up culture, and overall compliance.
In fiscal 2018, new global Code of Conduct training was launched in all regions. Materials for indirect employees were distributed via a specially developed e-learning platform. The e-learning training platform was accessible in number of formats including via portable devices like smartphones and tablets. The e-learning material was available in 19 languages. Factory-focused training material was prepared for factory workers, who received the training via regular shift-start messaging or in a seminar setting. This global Code of Conduct training is mandatory for all Nissan employees every year as well as Board members and Corporate Officers.

① Comply with All Laws and Rules

Nissan employees are expected to follow all laws and regulations of the country in which they work as well as all Company policies and rules.

② Promote Safety

Nissan is committed to employee safety and wellness. Nissan employees are expected to engage in safe work practices to promote a healthy work environment. Nissan is also committed to the safety of our customers and their passengers and Nissan employees are expected to continually promote safety of Nissan products.

③ Avoid Conflicts of Interest

Employees are expected to act in the best interest of Nissan. It is not permitted for employees to behave, act, or use information in a way that conflicts with Company interests. Furthermore, employees must attempt to avoid even the appearance of a conflict of interest.

④ Preserve Company Assets

Nissan employees are accountable for preserving and safeguarding Company assets. The unauthorized or improper use of Company assets, including funds, confidential business information, physical property and intellectual property, is prohibited.

⑤ Be Impartial and Fair

Nissan employees must maintain impartial and fair relationships with business partners, including dealers, suppliers and other third parties.

⑥ Be Transparent and Accountable

Accounts and records shall be maintained with integrity. Nissan employees shall make accurate, transparent, timely and appropriate disclosures of the Company’s business activities to our stakeholders, including shareholders, management, customers, other employees and local communities.

⑦ Value Diversity and Provide Equal Opportunity

We value and respect the diversity of our employees, suppliers, customers and communities. Discrimination, retaliation or harassment, in any form or degree, will not be tolerated.

⑧ Be Environmentally Responsible

Nissan employees shall strive to consider the environment and environmental protection when developing products and services, promote recycling and conserve materials and energy.

⑨ Be Active; Report Violations

Nissan employees are expected to carry out their work in accordance with the Code of Conduct. Employees who suspect that a violation of the Code of Conduct has occurred are obligated to report it as soon as possible. Employees are encouraged to use the SpeakUp system to report their suspicions. Employees who act in good faith and report suspected violations will be protected from retaliation.

Business Ethics: Management

Internal Reporting System for Corporate Soundness

Nissan has established a globally integrated reporting system to promote thorough understanding of compliance among employees worldwide and facilitate sound business practices. The system, known as “SpeakUp,” can be used by employees to ask questions or voice concerns to the company, thereby improving workplaces and operations. Where allowed by law, SpeakUp permits anonymous reporting by and two-way confidential communication with employees and other stakeholders. It is available 24 hours a day, 365 days a year, in more than 20 languages. Employees are encouraged to report violations of the Code of Conduct or other company rules, and are protected from retaliation by our non-retaliation policy, a cornerstone of our compliance program.
In fiscal 2018, 1,585 issues and questions were reported globally. Among those, 780 compliance-related matters were identified. The number of reporting has been increased since SpeakUp was introduced. This trend is as expected, and indicates both that our compliance program is working effectively and that employees are taking an interest in using it to raise their concerns.

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Security-Related Export Controls

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Nissan’s Commitment to Tax Transparency

Based on its Global Code of Conduct, Nissan is committed to complying with the laws and regulations of all countries in which it operates, as well as with international tax treaties and tax-related financial reporting rules. Nissan is consistently fulfilling a number of tax disclosure requirements such as OECD Country-by-Country Reporting and other mandatory country-specific transparency requirements like in Australia or the United Kingdom.*
Nissan applies established international standards like OECD principles to its dealings between the companies within the group. Intercompany transactions are priced on an arm’s-length basis, which means that Nissan-related entities trade with each other as if they were unrelated.
Nissan is transparent about its approach to tax. Nissan aims to pay the appropriate amount of taxes in the jurisdictions in which it operates, and to avoid tax-related interests and penalties for failure to comply.

Nissan effectively manages tax risks within the Group by participating in and—through the delegation of authority process at a global, regional and local level—validating key business decisions from a tax perspective in a consistent manner.
Nissan seeks to maintain a long-term, open and constructive relationship with national tax authorities by proactively engaging with them, as well as other governmental and relevant industry bodies directly and indirectly.