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.
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: 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.
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.
Business Ethics: Policies and Philosophy
Employees and Compliance
Fiscal 2018 Global Compliance Committee Organization (As of June 25, 2019)
Nissan’s sustainability efforts are based on each employee’s ability to do his or her job with a high level of integrity. In 2001, we established a Global Code of Conduct containing practical guidance for employees. Today this Code of Conduct is applied at all Nissan Group companies worldwide. We also provide guidance on compliance for directors and corporate officers, holding regular seminars and educational activities to ensure strict adherence to the rules. Under the oversight of our Global Compliance Committee, we have established a Regional Compliance Committee in each region of operation, forming a worldwide system for detecting and deterring illegal and unethical behavior. Global Headquarters works with all regions and bases of operation to ensure full awareness of compliance issues and prevent illegal activity, and has processes in place to take appropriate disciplinary action against those who violate or infringe the Global Code of Conduct or the law. Our Global Risk & Compliance Office further increases the rigor of our compliance management. In addition, to enhance compliance at the regional level, stand-alone, independent, regional compliance officers have been hired in the Japan, Asia and Oceania (A&O), China, North America, Latin America and the Caribbean (LATAM), Europe and Africa and Middle East and India (AMI) regions.
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.
Security-Related Export Controls
Global Export Control Policy Framework
To help maintain both national and international peace and security, we rigorously comply with export control laws and regulations in Japan and other countries and regions where we operate to keep sensitive goods and technologies from reaching sponsors of terrorism, espionage or human rights violations. Our export controls are implemented under a system headed by the representative executive responsible for export control. Specifically, our Export Control Global Secretariat works with each of our businesses to set control and monitoring mechanisms ensuring compliance with security-related export controls, and these mechanisms are strictly applied to all operations. We recognize our responsibility for compliance with all regulations related to export controls on goods, software and technologies in our areas of operation. In 2017, we formulated a Global Export Regulatory Compliance Policy to ensure proper compliance with such regulations across the Nissan Group. Based on this global policy, we are working to develop local policies for each of the different countries and regions where we operate, such as national trade and export regulatory compliance policies issued in fiscal 2018 for Turkey, and to establish export control structures. We also respond in a timely manner to export control regulation changes and related developments around the world, including the enforcement of the Export Control Reform Act (ECRA) in the U.S., amendments to the EU export control list and moves to strengthen export control regulations in China, Thailand, India and the Philippines. With the overall aim of improving our level of internal control, we strive to conduct regular risk-assessment activities in connection with export controls in each region, create monitoring mechanisms aligned with regulatory requirements and business demands, and continually improve our operations. To make employees more familiar with compliance risks, we are reviewing our training system and materials, including information about complying with relevant customs and trade laws. From fiscal 2018, we began training in Japan based on the new system, and we intend to extend this training globally starting in fiscal 2019. We have been addressing export control of advanced technology on a global level to prepare for the future of our company. To hasten the implementation of our Global Export Regulatory Compliance Policy, we continue to promote export control for advanced technologies, such as autonomous driving and connected-car technologies, at Nissan sites in Silicon Valley and elsewhere around the world. At our development sites in Japan, we are improving our classification process for sensitive goods, software and technologies using IT systems. By making export control procedures an integral part of our development and design operations, we aim to strengthen our compliance. In addition, we are renewing and collecting information on controlled goods and technologies in each region and are implementing comprehensive and sound export controls for each business operation through the systematic global sharing of this information.
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.
Click here for information on Nissan’s U.K. tax strategy.
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.