About NEC Compliance & Integrity Hotline
About methods of reporting
Key points to consider when reporting
Response after reporting & protection for reporters
About the reporting system “EthicsPoint”
About NEC Compliance & Integrity Hotline
What is NEC Compliance & Integrity Hotline?
NEC Compliance & Integrity Hotline is one of our speak-up channels to raise concerns about actions that do not comply with laws and regulations, the Code of Conduct (NEC Group Code of Conduct) and internal company rules, etc.
If you have concerns that you are not able to consult with your superiors or the relevant divisions, please report to the hotline.
Why should I report what I know?
We all have the right to work in a positive environment. Having this right means to be responsible for acting with integrity, and when finding an inappropriate act by someone, we must report it to an appropriate person(s).
By cooperating one another, we can maintain a healthy and productive environment.
Raising a concern can minimize the possible negative effect on NEC Group and its stakeholders regarding financial or legal risks, and safety and security threats.
Does management really want me to report?
Yes. As indicated in the Code of Conduct (NEC Group Code of Conduct), NEC Group requires employees and other stakeholders to raise concerns as soon as they become aware of potential corporate misconduct.
When should I use the NEC Compliance & Integrity Hotline?
Please report to the hotline immediately if you become aware of any act that violate laws and regulations, the Code of Conduct (NEC Group Code of Conduct) or internal company rules, etc.
You could report your concerns about ethical issues and potential corporate misconduct.
Should I need to consult with my superior or the relevant department before reporting?
Ideally, you should bring any concerns forward to your superiors or the relevant department.
We recognize, however, that there may be circumstances when you are not comfortable reporting the issue in this manner.
If you are in such circumstances, please report to the hotline.
We would rather you report than keep the information to yourself.
Who can use the NEC Compliance & Integrity Hotline?
The following people can use the NEC Compliance & Integrity Hotline, though depending on applicable laws and regulations in the certain territory, reports from individuals outside these categories may also be accepted.
- The officers, employees (including contract and part-time employees), temporary employees, and retirees (former officers, employees, and temporary workers) of NEC Group.
- Those who supply/have supplied goods or services to NEC Group.
What types of concerns should I report?
Concerns about actions that violate laws, the Code of Conduct (NEC Group Code of Conduct), internal company rules, etc. should be reported.
On the other hand, the following matters are not accepted by the hotline.
- Misconduct by other companies which are not related to the services of NEC Group;
- Complaints based on personal circumstances in the workplace;
- Complaints intended to slander the others; and
- False Report
What information do I need to provide?
Please provide information in as much detail as possible.
Details of the report should include the who (names of the people involved, including witnesses), what (description of the situation), when (date the situation happened), where (the place where it happened), why (the cause or reason), and how concerning the incident. Also "how much" if it can be measured.
If possible, you can attach evidence such as documentations or emails that help substantiate your claim(s).
Should I report a situation where I am not sure whether or not it violates laws and regulations, the Code of Conduct (NEC Group Code of Conduct) or internal company rules, etc.?
If you have any doubts, do not leave it and file a report.
NAVEX can help you prepare and file your report so it can be properly understood.
About methods of reporting
May I report either online or using the telephone?
Yes. With this reporting system, you can report online or telephone.
Please choose one channel. Please be careful not to report using both channels and duplicate reports.
Is there a difference depending on how I report (online/telephone)?
The first channel is reporting online through this website. We will ask you questions to find out what happened, who are involved, where and when did it happen, and how did it happen. If you have photos, documents, recordings, or videos, you can upload them.
The second channel is reporting by telephone. The operator will ask you questions to clarify the details. You may also be asked to provide supplementary information such as photos, documents, videos, etc. (Such documents can be provided by uploading to the system).
Both the website and telephone can be used 24 hours a day, 365 days a year.
What should I do if the company related to my concern is not listed in the pull down?
If you are working at a branch office located in the territory different from the HQ’s location, please select “Other”, and enter your company name in the reporting format which will appear in the later step.
If your company does not show up in the pulldown though you select the territory which the HQ is located, the company is currently preparing to implement this reporting system. In such case, please report your concern to the whistleblowing channel available at your company.
What should I do if the location I am in is not listed in the pull down when looking up the phone number?
If there is no telephone number for your location, contact us online through this website.
What should I do if the telephone number is not working?
If the telephone number listed is not working, contact us online through this website.
Please include in your report that the telephone number was not working.
Key points to consider when reporting
Is there anything I should be careful about contents of my report?
Please make sure that the contents you are attempting to report do not include any information that is not subject to disclosure by the laws and regulations which apply in your location or the location related to your concern, e.g. state secrets, military secrets, trade secrets, etc.
Is there anything I should be careful about after reporting?
To protect reporters and to conduct appropriate investigations, please keep the fact that you have made a report and any subsequent communication confidential, and do not disclose them to others, e.g., sharing with your colleagues, posting on social media, etc.
Response after reporting & protection for reporters
What happens when I raise a concern?
The information reported online or telephone is reviewed by the responsible compliance-related department within NEC Group after the report is being received. When the necessary information has been confirmed, the report is sent to the NEC Group department in charge of the investigation. The investigation department examines the report in detail and begins the necessary investigation.
Do I receive confirmation of my report?
Yes. You will receive a notification that your report has been received within a few days.
You will also receive a notification of the results of the investigation after it has been completed.
You can check the notification from "Follow-up" menu.
Is there a case where a report is made but no response to the report?
We may have difficulty responding to reports that fall under the following categories.
We appreciate your understanding in advance.
- Cases which have already been resolved;
- Cases which are lacking sufficient information to conduct an investigation; and
- Cases in which contact with the whistleblower is not possible, etc. and unable to verify the facts.
How is the information about the report handled?
The content of the report and the correspondence after the report are directly entered into a secure server on the system. The server is not connected to NEC Group's information system, and is accessible only by the limited persons in NEC Group who are responsible for handling reports and who are obliged to keep confidentiality of the reports.
May I remain anonymous?
Yes, anonymous reporting is possible. The system will provide you with a report key, and you will set a password. Please keep the report key and password in a safe place. Using this key, you will be able to receive questions from the investigators, and also will be able to provide additional information.
In addition, if you report the issue in real name, the investigation will be quicker and more effective.Even if you report the issue in real name, the investigation team will handle it with confidentiality, and they will not disclose your personal information without your consent. The investigation team will ensure that appropriate actions are taken to protect you from any potential retaliation.
If my superior or other managers are involved in a concern, won't they find out that I've reported it?
This system ensures that implicated parties are not notified or granted access to reports in which they have been named.
It is my understanding that any report I send from a company computer generates a server log that shows every website that my PC connects with. Won’t this log identify me as the report originator?
The reporting system does not generate connection logs that include IP addresses. Therefore, there is no information linking your PC to the reporting system.
Can I get in trouble for using the NEC Compliance & Integrity Hotline?
No. NEC Group guarantees that the fact and content of the report will be kept confidential. We will not tolerate any adverse treatment or retaliation against whistleblowers or those who cooperate with investigations. Those involved in adverse treatment will be subject to disciplinary action. If you are subjected to adverse treatment, please report it to the "NEC Compliance & Integrity Hotline".
Does the report via telephone keep confidential and anonymous?
Yes. You provide the same information as when reporting online, and the operator enters the report details into the system's secure server. The same security level and measures to protect anonymity as when reporting online also apply to reporting by phone.
About the reporting system “EthicsPoint”
How will I receive information on the status of my case?
You can check the status of your report from the "Follow-up" menu. You can access the report you submitted by using the report key and password you set when you submitted the report.
What if you have questions for me concerning my report?
Additional questions will be asked on the system. Please access the system regularly using your report key and password to check for any additional questions.
What if I remember something important about the incident after I file the report?
By using this report key and password you set when you submitted the report, you can access the original report and add any important related information.
Is there a function to temporarily save the report form?
No. If you close your internet browser while completing the report form, the information you have entered will not be saved.
Therefore, please take sufficient time to fill in the report form.
What if I lose my Report Key or forget the Password I created?
To ensure that security and confidentiality is maintained, if you lose your report key or password, you will need to file a new report. Mention in the new report that it is related to a report or question you previously submitted.
Who operates the reporting system “EthicsPoint”?NAVEX, an independent third party, operates the reporting system “EthicsPoint”.
Based on the contract with NEC, NAVEX is obligated to maintain the confidentiality of the information handled in "EthicsPoint".