Reason for Prioritization

The global social situation facing companies continues to change rapidly. No matter how the times may change, we will continue to fulfill our social responsibilities by thoroughly complying with corporate ethics as well as laws and regulations.
Cases where even one misconduct has caused a loss of credibility that has endangered a company's existence are too numerous to mention. Therefore, in addition to preventing misconduct before they occur, it is important to strengthen compliance systems in a broad sense in accordance with international guidelines and directives, while simultaneously carrying out appropriate risk evaluation and training.

Commitment

The Nikon Code of Conduct constitutes the fundamental rules of the Group based on its Corporate Philosophy of Trustworthiness and Creativity. All employees working for the Nikon Group must be firmly aware of the importance of compliance based on the Nikon Code of Conduct in their daily business activities. Furthermore they must always maintain a high ethical standard and act sincerely and appropriately when making judgments and taking action. The Nikon Code of Conduct also represents the foundation on which we will strengthen global governance and respond to the expectations of the international community. We aim to become a company that meets the expectations of society by consistently educating and establishing our Code of Conduct, and by fostering a culture of sincere behavior, including compliance with laws and regulations, to prevent compliance violations and maintain the trust of the community.
In order to realize our Corporate Philosophy of Trustworthiness and Creativity and contribute to the sustainable development of society, I will continue to pursue thorough compliance through the practice of the Nikon Code of Conduct.

Goal

Vision	Zero compliance violations
Strategy	Spreading awareness of the Nikon Code of Conduct
Indicator: Goal (achievement year)	Establishment of compliance awareness*: 95% or more (FY2025) Awareness level of whistleblower system*: 95% or more (FY2025)

• *Checked by Nikon Group awareness surveys

Nikon Code of Conduct

The Nikon Code of Conduct is a specific set of standards that each and every employee should understand in depth and utilize to implement the concept of compliance. In the Code of Conduct booklet, we include messages from the president, company principles, explanations of terms, and Q&As to promote understanding of the Nikon Code of Conduct among all employees, both domestically and internationally. The Code of Conduct and explanatory materials have been translated into 16 languages and posted on the portal site so that all employees can refer to it whenever necessary. Furthermore, the content of the Code of Conduct and explanatory materials is reviewed regularly.
Additionally, to ensure thorough compliance with the Code of Conduct across the Nikon Group, the head of each department at Nikon and above, and the president of each Group company make a pledge each year to take responsibility for compliance with the code of conduct in the organizations of which they are in charge.

• Nikon Code of Conduct

System

The Nikon Group has established a Compliance Committee under the Risk Management Committee to strengthen governance and risk management. The committee is chaired by the General Manager of the Group Governance and Administration Division, who is also a Representative Director of Nikon. It deliberates and decides on measures related to priority compliance promotion issues, such as anti-bribery. The Compliance Section of the Legal and Intellectual Property Division, which spearheads compliance promotion activities, and the Internal Control Promotion Section of the Group Governance & Administration Division, both serve as secretariats of the committee.
The Nikon Group promotes compliance according to the system outlined in the diagram. In Japan, the Compliance Section undertakes compliance promotion activities in each of Nikon's departments and at Group companies, by holding liaison meetings of compliance coordinators, etc. Outside Japan, we cooperate with each group company, led by the regional headquarters, to address the risk of violations of local laws and regulations. Furthermore, we are promoting initiatives in line with the culture, customs, laws, and regulations, and laws and regulations of each country and region.

Code of Conduct Hotline (Reporting and Consulting System)

The Nikon Group has included provisions regarding a reporting and consulting system in the Nikon Code of Conduct and has established such systems at all Group companies in and outside Japan in order to respond to reports of violations or potential violations of the Nikon Code of Conduct.
Reporting can be done anonymously. When violations or potential violations of the Code of Conduct are reported, we promptly investigate the facts and take steps to resolve the matter and prevent recurrence. For each case received through the system, information is gathered from the reporter and persons relevant to the matter in order to understand the issue objectively. We then work together with relevant departments to resolve the case and follow up as necessary. We treat each case with the utmost care by respecting human rights, which includes keeping the matter in strict confidence, protecting privacy, ensuring anonymity, and preventing any negative treatment as a result of using the system.
To ensure that this reporting and consultation system is functioning properly, the secretariat operating the Code of Conduct Hotline reports regularly to the Members Compliance Committee on the development and operational status of the system, which is based on the regulations. The Committee is also informed of the status of overseas operations.
The Nikon Group makes employees aware of this system through a booklet on the Nikon Code of Conduct, which is accessible to all employees, and relevant training programs.

Sustainability Report

For more information, refer to Thorough Compliance in the Sustainability Report.

• Thorough Compliance（PDF:288KB）

Compliance

• Nikon Code of Conduct
• System
• Major Initiatives
• Prevention of Bribery
• Prevention of Competition Law Violations
• Responding to Misconduct

Related Policies

• Nikon Anti-Bribery Policy（PDF:242KB）