Governance

To ensure smooth and sustainable operation of corporate activities

Corporate

Basic approach to corporate governance

The Nichireki Group implements all its management plans based on its corporate philosophy. To that end, we are pursuing sound, transparent and efficient management by establishing a corporate governance structure appropriate for the Nichireki Group’s business and constantly checking the structure for further enhancement.

Responses to the Corporate Governance Code

Recognizing that the Corporate Governance Code established by Tokyo Stock Exchange, Inc. is what our society requests and expects us to be like, we intend to conduct our business by placing the code at the heart of business management in order to achieve sustainable growth of the Nichireki Group and increase its corporate value over the medium to long term.
To disclose information based on the principles of the Corporate Governance Code, we submit a Corporate Governance Report to the Tokyo Stock Exchange. The preparation guidelines for the report were amended following the requests of “Action to Implement Management that is Conscious of Cost of Capital and Stock Price” and “Better Dialogue with Shareholders and Related Disclosure” made and announced by the Listing Department of Tokyo Stock Exchange, Inc. on March 31, 2023. Accordingly, we added the descriptions of “Action to Implement Management that is Conscious of Cost of Capital and Stock Price” and “Dialogue with Shareholders” in the report to update and submitted it again.

Action to Implement Management that is Conscious of Cost of Capital and Stock Price

We set numerical management targets in the Medium-term Management Plan (Shinayaka 2025) to maintain considerably high capital efficiency. Specifically, we set 8.0% or more of ROIC and 6.0% or more of ROA. We set these numerical targets by calculating cost of shareholders’ equity using the capital asset pricing model (CAPM) and other related models and by considering the weighted average cost of capital (WACC) to be cost of capital while referring to the responses of various types of questionnaires of investors. During the period of the plan, the Investment Strategy Office periodically recalculates cost of capital and checks if it needs to change the targets.

Dialogue with Shareholders

Nichireki strives to enhance dialogue with shareholders and investors. Specifically, we answer individual inquiries and requests as appropriate, hold financial results briefing sessions for analysts and institutional investors as an opportunity to provide information, hold online seminars for individual investors, and make videos and documents available on our website and one operated by an IR support company.

Corporate governance system

Nichireki has adopted a structure of a company with a board of auditors. With this structure, four Auditors, including two Outside Auditors, audit business execution by Directors in a fair and objective manner from an independent standpoint, and properly perform their management oversight functions.
As a company with a board of directors, Nichireki has the Board of Directors composed of 10 members: six Executive Directors who are well versed in the Nichireki Group’s business to enable quick and accurate decision-making on business execution, and four independent Outside Directors with high level of expertise to ensure transparent decision-making and proper supervision over management.
Nichireki pursues quick and accurate decision-making by having the Board of Directors have a stronger monitoring function than before, while maintaining the management oversight functions of Auditors as the cornerstone. We consider that such a corporate governance system will increase the soundness and efficiency of Nichireki’s management and it is effective for the Nichireki Group’s sustainable growth and enhancement of corporate value over the medium to long term.
Our corporate governance system is as shown below.

Corporate governance system

Board of Directors

The members of Nichireki’s Board of Directors are six Executive Directors and four Outside Directors who are not involved in business execution. In order to ensure the diversity of perspectives in the Board of Directors’ decision-making and enhance its management oversight function, we appoint Outside Directors with in-depth knowledge and extensive insights in all aspects of corporate management. Further, four Auditors (two of whom are Outside Auditors) are allowed to attend the Board of Directors meetings and express their opinions, when necessary, in order to ensure sound management.
In principle, Nichireki’s Board of Directors meeting is convened once a month. As any material information pertaining to Nichireki’s management strategy must be reported to the Board of Directors adequately and in a timely manner, the Management Strategy Council consisting of six Executive Directors and six Corporate Executive Officers meets, in principle, twice a month in advance of the Board of Directors meetings to make necessary decisions and reports for business execution so that Board’s meetings can be operated efficiently and effectively.

Board of Auditors

Nichireki’s Board of Auditors is composed of two Auditors who are well versed in the Nichireki Group’s operations and two Outside Auditors who have abundant experience and in-depth insights in their areas of expertise. Each Auditor strictly audits the status of business execution by Directors, Executive Officers and other officers as well as matters such as the status of the Company’s assets, in cooperation with the Accounting Auditor (an auditing firm) and the Audit Department, a department in charge of internal audits.

Nomination and Remuneration Committee

Nichireki has established the Nomination and Remuneration Committee, a majority of the members (four out of six) of which are independent Outside Directors, as a voluntary advisory committee. The committee deliberates material matters regarding the nomination and remuneration of officers in advance of resolution of the Board of Directors in order to ensure the independence and objectivity of its authority over such matters.

Outside Officers (independent officers)

A total of six independent outside officers, including four Outside Directors and two Outside Auditors, are appointed to enhance the transparency of Nichireki’s management. Nichireki assesses the independence of its outside officers based on the independence standards prescribed by Tokyo Stock Exchange, Inc., taking into account their personal, capital, and business relationships and other interests with Nichireki.

Outside officers (independent officers)

Title and name Reasons for appointment Attendance at meetings
(FY2022)		 Significant concurrent positions

Director
Osamu Kobayashi

 As a certified public accountant and a certified tax accountant, he has abundant experience, an extensive track record, and insight in corporate accounting and tax affairs. 13/13 Board
of Directors meetings
(100%) 		Outside Corporate Auditor
of NOK CORPORATION

Director
Haruko Shibumura

 As an attorney-at-law, she has expertise, abundant experience, an extensive track record, and insight in corporate legal affairs including corporate compliance. 13/13 Board
of Directors meetings
(100%) 		Outside Director of
TAMURA CORPORATION

Director
Takuya Kidokoro

 As an attorney-at-law, he has abundant experience and track records in corporate restructuring and corporate legal affairs, as well as considerable knowledge about corporate management. 13/13 Board
of Directors meetings
(100%) 		Executive Director and Lawyer of RISA Loan Servicing, Inc.
Adviser (Administrative Law Judge) to Financial Services Agency

Director
Mieko Fukuda

 She has abundant experience and specialist knowledge gained through her engagement in corporate management and marketing-related divisions. In particular, as a management consultant, she possesses a high level of expertise in market research, analysis, and strategy development. 13/13 Board
of Directors meetings
(100%)

Auditor
Tsutomu Kanitani

 As a certified tax accountant, he has expertise and abundant experience in corporate management including tax affairs. 13/13 Board
of Directors meetings
(100%)
19/19 Board
of Auditors meetings
(100%)

Auditor
Noriko Kawate

 As a certified public accountant and a certified tax accountant, she has abundant experience, track records, and insight in corporate finance and accounting and is well versed in such services as consulting on business succession and advisory on corporate rehabilitation mainly in M&A and organizational restructuring. 13/13 Board
of Directors meetings
(100%)
19/19 Board
of Auditors meetings
(100%) 		Outside Director of Ichigo Inc.
Outside Corporate Auditor of
Sumitomo Bakelite Co., Ltd.

Compliance

Internal control

To ensure efficient execution of duties by directors, Nichireki has set the Board of Directors Rules to clarify the authority, responsibilities and operations of the Board of Directors. Minutes of the Board of Directors will be prepared to record information on matters to be resolved by and reported to the Board of Directors and kept in accordance with the Information Management Regulations and the Group’s other internal rules. Meanwhile, the Company has built a system to ensure the swift and precise execution of matters decided by the Board of Directors in accordance with the Administrative Authority Regulations and the Group’s other internal rules.
To ensure the appropriateness of each Group company’s operations, the Nichireki Group has established the Group Business Management Regulations and built a business management system based on its management philosophy. Under this business management system, Nichireki performs audits of Group companies and provides them with guidance on their business. At the same time, we have a policy to give approval for any material matter regarding Group companies after receiving and carefully examining the results of discussions and reports from them. While Nichireki has established the Group’s internal rules as internal rules applicable to the entire Nichireki Group, Group companies have established their own internal rules following suit of Nichireki’s internal rules to promote unity within the Group.
Nichireki has established the Basic Policy for Establishing Internal Control System (system necessary to ensure the appropriateness of operations prescribed by the Companies Act) based on a resolution of the Board of Directors and reviews the policy as needed according to systemic revision or the status of operations.

Basic Policy for Establishing Internal Control System

  1. System for ensuring compliance with laws, regulations and Nichireki’s Articles of Incorporation in the execution of duties by directors and employees

    Nichireki shall appoint a director in charge of compliance and set up the Legal Affairs and Compliance Department as the controlling department for the Nichireki Group’s compliance. The Company shall also set the Group’s internal rules and prepare the Compliance Manual, thereby making sure everyone in all of our Group companies is aware of the compliance rules. Nichireki shall open a hotline on the Nichireki Group network as a point of contact for reporting and consultation, which receives reports and provides consultation on compliance directly from and with the Group’s employees. The hotline shall also accept their opinions and proposals on compliance.
    If a director finds any violation of laws and regulations or other important facts regarding compliance at the Nichireki Group, the director shall report to auditors immediately.
    If an auditor recognizes there is a problem with the Nichireki Group’s compliance system, the auditor may give his or her opinions and request improvement measurers to be formulated.
    For internal audits, Nichireki shall set up the Audit Department to assess the achievement of major objectives of the Nichireki Group’s internal management, including the effectiveness and efficiency of operations, the reliability of financial reporting, compliance with laws and regulations and other rules, and asset protection, in an objective and comprehensive manner, as well as to give advice, instructions, or corrective guidance to resolve issues. The Audit Department shall also exchange opinions and information with auditors and the accounting auditor when necessary.
    Nichireki shall establish a system to receive professional advice on management-related legal issues from its corporate lawyer.

  2. System for the storage and management of information related to the execution of duties by directors

    Information related to the execution of duties by directors shall be appropriately stored and managed in accordance with the Information Management Regulations and the Group’s other internal rules or the Company’s internal rules.

  3. Rules and other systems for the management of risk of loss of Nichireki

    For the Nichireki Group’s risk of loss, we shall develop various regulations on risk management as part of the Group’s business management. We shall also establish a system where its responsible departments set rules and guidelines, provide training, and prepare and hand out manuals as needed. In cases where it is necessary to address a new risk, the President shall immediately appoint a director to be responsible for addressing the risk and notify all Group companies of the matter. If the risk is likely to materialize and cause serious damage, the responsible director shall immediately report to the Board of Directors.

  4. System for ensuring the efficient execution of duties by directors

    Nichireki shall formulate a Group management plan and set and determine Group-wide management goals and targets and budget allocation for each fiscal year to promote the Group’s cooperative framework and efficiently execute and manage business operations.
    As the basis of the system for ensuring the efficient execution of duties by directors, Nichireki shall, in principle, hold the Board of Directors meeting once a month and an extraordinary meeting when necessary. Material matters related to the Company’s management policies and management strategy shall be discussed to determine their execution by the Management Strategy Council in advance of the Board of Directors meetings.
    Nichireki shall precisely execute operations based on decisions made by the Board of Directors in a timely manner in accordance with the Administrative Authority Regulations and other internal rules.

  5. System for ensuring the appropriate operations of the Corporate Group comprised of Nichireki and its subsidiaries

    To ensure the appropriateness of the Nichireki Group’s operations, Nichireki shall establish the Group’s management philosophy common to all Group companies and develop the Group’s operation system, such as establishing the Group’s internal rules, based on the philosophy. In addition, the Group companies shall set their own internal rules on matters not stipulated in the Group’s internal rules in compliance with internal rules set out by Nichireki.
    Group companies shall discuss with and report to Nichireki on material matters related to business execution. Nichireki shall build a Group business management system to perform audits of Group companies and provide them with guidance on their business.
    If a Group company recognizes that Nichireki’s business management or guidance on its business may be in violation of laws or regulations, or otherwise, there is a compliance issue, the Group company shall report to the Audit Department or the Legal Affairs and Compliance Department. The Audit Department or the Legal Affairs and Compliance Department shall then immediately report to auditors. Auditors may give their opinions to and request directors (Board of Directors) to formulate improvement measures.

  6. Matters related to employees assigned to assist auditors in their duties, the independence of such employees from directors, and ensuring the effectiveness of directions to such employees

    Auditors may exchange opinions and information with the Audit Department, which is responsible for internal audits, and the accounting auditor when necessary and perform investigations and information gathering necessary to execute their duties based on their own judgment. Therefore, employees who are to assist auditors in their duties shall be assigned at the request of auditors if it becomes necessary.
    Employees who are to assist auditors in their duties shall follow the auditors’ directions and orders exclusively on operations subject to instructions given by the auditors.
    Personnel matters of employees who are to assist auditors in their duties shall be discussed with the auditors in advance.

  7. System for reporting from directors and/or employees of Nichireki and its subsidiaries to auditors and other systems regarding reporting to auditors, system for ensuring that a person who has made a report will not receive unfavorable treatment for reason of having made such report, and other systems for ensuring the effective performance of audits by auditors

    Auditors may attend not only the Board of Directors meetings but also the Management Council meetings and other important meetings, as well as inspect documents on important decisions and conduct investigations on the status of operations and assets. Directors and employees shall report the schedule of important meetings to auditors.
    Directors, employees, and auditors of the Nichireki Group companies (“Officers and Employees”) shall report to Nichireki’s auditors on material matters that may affect operations and financial results of the Nichireki Group and legal violations and other compliance issues indirectly through Nichireki’s responsible department or directly by whistleblowing or other means. Notwithstanding the foregoing, Nichireki’s auditors may request a report from Officers and Employees of the Nichireki Group whenever necessary.
    Nichireki shall prohibit unfavorable treatment of each of Officers and Employees of the Nichireki Group companies who has made a report to Nichireki’s auditors for reason of having made such report and make sure all Officers and Employees of the Nichireki Group companies are aware of the matter.
    When Nichireki’s auditors request the advanced payment of expenses to be incurred in the course of executing their duties, Nichireki’s responsible department shall deliberate on the matter and process the request immediately, unless the expenses or obligations are deemed not necessary for the execution of the auditors’ duties.

  8. System for ensuring the reliability of financial reporting

    To ensure the reliability of financial reporting and file the internal control report effectively and appropriately in accordance with the provisions of the Financial Instruments and Exchange Act, Nichireki shall build an internal control system and develop and operate the system appropriately.

  9. System for eliminating anti-social forces

    Nichireki shall respond to unreasonable demands from anti-social forces with a resolute attitude by the entire organization and develop a system necessary to eradicate all business and other relationships with anti-social forces.

Compliance

Nichireki places emphasis on complying with not only laws and regulations but also things that are not legally binding such as common sense and good sense as a member of economic society. Regarding compliance as a much broader concept than mere legal compliance, we believe that our concept of compliance also includes fully meeting social expectations.

  1. Basic approach

    ①All officers and employees of the Nichireki Group shall act in accordance with the Nichireki Group’s Corporate Philosophy and the Code of Individual Conduct to promote compliance.

    ②The Head of Compliance, who is appointed from among Nichireki’s directors, shall promote compliance throughout the Nichireki Group.

    ③The Head of Compliance shall direct and take overall control of compliance officers assigned at each base of the Nichireki Group through the Legal Affairs and Compliance Department and strive to enhance the Nichireki Group’s compliance system.

  2. Compliance promotion system

    For the Nichireki Group’s compliance system, the President and Representative Director of Nichireki appoints a responsible director as the Head of Compliance and sets up the Legal Affairs and Compliance Department as a responsible department. The President and Representative Director also appoints General Managers of Nichireki’s departments, offices, and branches as well as presidents of Group companies as compliance officers to put in place a system where the Group as a whole works together to promote compliance.
    Under the direction of the Head of Compliance, the Legal Affairs and Compliance Department is responsible for work to promote compliance across the Nichireki Group. Specifically, the Legal Affairs and Compliance Department is responsible for planning and providing compliance training for the Nichireki Group’s officers and employees, performing compliance audits of sales offices and other bases, and establishing, revising and abolishing the Group’s internal rules and other systems, in addition to responding to compliance incidents that occur in daily operations.
    Each compliance officer is responsible for work to promote compliance at a department, office, or branch he/she heads. Specifically, they monitor and manage the status of compliance within their own organizations and work to keep everyone informed about compliance information provided by the Legal Affairs and Compliance Department.
    The Nichireki Group has also set the Group’s internal rules and prepared the Compliance Manual, thereby making sure everyone in all of our Group companies is aware of the compliance rules.
    These Group’s internal rules include the Compliance Regulations, which stipulate such matters as compliance system, Regulations on Whistleblowing, Harassment Prevention Regulations, and Regulations on Compliance with the Antimonopoly Act. Given the importance of these regulations, they are established, revised, and abolished based on a resolution of the Board of Directors. In the case of any law amendment or incident that has become a social concern, the Legal Affairs and Compliance Department shall immediately examine the draft of regulations and seek a decision of the Board of Directors. For example, in response to the enforcement of the Amendments to the Whistleblower Protection Act in June 2022, the Board of Directors completely revamped the Regulations on Whistleblowing.

    Compliance promotion system diagram
    Compliance promotion system diagram

  3. Whistleblowing system

    In accordance with the Regulations on Whistleblowing, the Nichireki Group has opened a hotline on the Nichireki Group network to receive reports and provide consultation on compliance directly from and with officers and employees of Group companies as well as to accept their opinions and proposals on compliance, in addition to consultation and reports made in writing or orally. The Nichireki Group seeks to early detect and correct any misconduct by establishing a whistleblowing system, placing the hotline at its core, thereby practicing compliance management that responds to stakeholders’ expectations.
    The whistleblowing system, including the hotline, is available for all officers and employees including not only regular employees but also part-time workers and temporary workers. The whistleblowing system is also available for retirees, regardless of the period of time since their retirement. In order to protect whistleblowers, we receive anonymous reports and prohibit the unfavorable treatment of whistleblowers and persons who cooperate in investigations, such as search for and reprisal against them. We also impose confidentiality obligations on officers and employees engaged in the reception of whistleblowing.
    To make the whistleblowing system more accessible to the Nichireki Group’s officers and employees, Nichireki is working to further improve the system by, for example, entrusting an external expert subject to confidentiality obligations to serve as a point of contact from August 2023.

  4. Compliance training

    At the Nichireki Group, the Legal Affairs and Compliance Department plans and provides hands-on compliance training, which also introduces actual cases, for employees on a regular basis. For example, in consideration of the complete revision of the Harassment Prevention Regulations, which had been carried out to enable the Group as a whole to respond to the recently amended and enforced harassment-related acts (the Labor Measures Comprehensive Promotion Act, the Equal Employment Opportunity Act, and the Child Care and Family Care Leave Act), we provided harassment prevention training mainly for employees in managerial positions at the Nichireki’s Head Office and those in each area. Also, in order to develop a sense of fairness, which is important in business transactions, we hold a training workshop on the Antimonopoly Act lectured by lawyers and other external experts and provide training on such themes as intellectual property right and insider trading regulations, thereby striving to raise the awareness of compliance among the Nichireki Group’s employees.

    Medium- to long-term targets
    Item FY2020 results FY2021 results FY2022 results FY2025 FY2043 SDGs
    mapping
    Number of internal
    compliance training
    workshops held    		 2 2 2 2 2 SDGsmapping

Risk Management

We consider it necessary to be aware that risk management is one of our key managerial challenges; to constantly update material risks; and to review on a daily basis whether our countermeasures and control measures against various types of risks are appropriate. We therefore decide on which department takes charge of each of the risks in the context of their nature, etc., and conduct risk management as part of our daily operations.

  1. Basic policy for risk management

    For the Nichireki Group’s risk of loss, we have developed various regulations on risk management as part of the Group’s business management. We have also established a system where our departments responsible for risk management (e.g., the General Affairs Department, the Legal Affairs and Compliance Department, and the Safety, Quality and Environment Management Department) set rules and guidelines, provide training, and prepare and distribute manuals as needed. In cases where it is necessary to address a new risk, the President and Representative Director shall immediately appoint a director to be responsible for addressing the risk and notify all Group companies of the matter. If the risk is likely to materialize and cause serious damage, the responsible director shall immediately report to the Board of Directors.

  2. Management system

    For financial and legal risks and those of disasters and other events, the status of risk management is reported to the President and Representative Director and the Board of Directors by departments in charge of these issues in accordance with relevant regulations (e.g., the Finance and Accounting Department for financial risks, the Legal Affairs and Compliance Department for legal risks, and the General Affairs Department and the Safety, Quality and Environment Management Department for risks of disasters).
    To strengthen the management system that addresses various types of risks the Nichireki Group may face, we set up a Business Risk Management Committee based on a resolution of the Board of Directors meeting held in March 2023.

  3. Major business risks

    Shown below are major business risks that may affect the Nichireki Group’s operating results and financial position, and responses to the risks. By identifying and analyzing major business risks and having an in-depth review of responses to the risks, the Nichireki Group seeks to minimize the risks and curb the effects of them on its management and finance.

    Major business risks and responses

    1. Raw material prices and supply trends

      The Nichireki Group seeks to minimize the effects of procurement risks of raw materials. Specifically, we have a system in place where the Production Department occasionally monitors such risks and reports each month the procurement trends of raw materials to the Management Strategy Council comprised of Executive Directors, and the council decides on the direction of how to respond to the trends so as to early promote purchase measures and the addition of increased costs to the selling prices of products.

    2. Trends of public works

      To scale back the effects of the financial conditions of the central and local governments on its business performance, the Nichireki Group seeks to perform a detailed analysis of the infrastructure improvement issues faced by the central and local governments, promotes its design and sales activities to receive orders for products and construction methods that contribute to the longer life and higher performance of paved roads and the reduction of environmental load, stimulates demand in the domains of airports, harbors, railways, parks and other facilities in addition to roads as its focus domain, and expands its business markets.

    3. Trends of price competition

      The Nichireki Group works at reducing its manufacturing and construction costs and seeks to minimize the effects of lower prices on its business performance while striving to mitigate the impact of price competition by developing high value-added products and construction methods.

    4. Credit risks

      The Nichireki Group thoroughly manages credit and receivables when entering into transactions and seeks to mitigate credit risks by, for example, using a credit research agency and holding credit monitoring meetings.

    5. Country risks

      In the Nichireki Group, the Overseas Business Department, the Chinese Business Department and the Legal Affairs and Compliance Department have discussions to take appropriate measures to avoid risks for each project. These departments also share information with each other about the progress of overseas business, the existence of any troubles, the social landscapes of the markets that we plan to enter or have recently entered, amendments to laws and regulations, and other matters, and take necessary measures.

    6. Information security

      As measures to prevent information leaks, the Nichireki Group limits access to confidential data, limits the use of media that employees can take out of their workplaces, and provides employees with information security education. To brace ourselves for information security incidents, we have also set up a system centered around the System Engineering Department to immediately restore our data and systems, and take out a cyber insurance that covers all of our Group companies.

    7. Risks of natural disasters, infectious diseases, etc.

      To brace itself for natural disasters, such as earthquakes and typhoons, and infectious disease outbreaks, the Nichireki Group has its internal regulations in place set mainly by the General Affairs Department, which include the BCP Management Regulations (regulations for the management of business continuity plan) and the Disaster Prevention Regulations, and has introduced a safety confirmation system to confirm the safety of employees in times of natural disasters.
      In case of a disaster, the Head of the Business Risk Management Committee compiles information, and depending on the situation, we set up a disaster response office led by the President and Representative Director to take action.

    8. Risks associated with legal regulations, etc.

      In the Nichireki Group, the Legal Affairs and Compliance Department and the Safety, Quality and Environment Management Department create opportunities to provide education about compliance as well as health and safety, and make sure that all officers and employees of the Group are aware of such important matters, thereby mitigating the risks of receiving administrative sanctions and penalties by legal regulations.

Information security

The Practical Guidelines for Corporate Governance Systems (CGS Guidelines) revised by the Ministry of Economy, Trade and Industry on July 19, 2022 state that “business becomes integrated with and indivisible from IT in many areas, and more business owners and shareholders use digital solutions and tools to make their investment decisions; under such situation, it is pointed out that having discussions about corporate governance based on the use of digital solutions and tools is becoming important.” As described, using information and communications technology helps improve convenience and streamline operations, and ICT is essential for improving corporate governance and gaining a stronger competitive advantage. The Nichireki Group seeks to streamline its operations by expanding and improving its information systems. We also expand our services that use ICT to serve our customers. For example, we manage construction in a new way with ICT-embedded road stabilizers using cloud computing, and use GLOCAL-EYEZ, a road inspection system using a smartphone. The more we depend on ICT, the more we have ICT-specific risks. We consider that information security management in particular is one of key managerial challenges for many companies. Given this situation, the Nichireki Group has established a Basic Policy for Information Security, and strives to advance its information security management. Based on the Basic Policy for Information Security, the Nichireki Group has improved its system for the centralized management of information security by appointing a Director as Information Management Supervising Manager and appointing General Managers of departments, offices and branches and presidents of Group companies as information management officers. Another Director is appointed as Information Handling Manager to mainly work on information disclosure, especially timely disclosure. The Nichireki Group has its internal regulations and rules in place, such as the Information Management Regulations, and makes sure that all of its officers and employees are aware of information security by providing an employee training session, an explanatory session, and other learning opportunities.

Information management system diagram
Information management system diagram
Basic Policy for Information Security

  1. Subject

    Information assets subject to this policy shall be all the information obtained in the course of business activities and held by the Nichireki Group.

  2. Scope

    This policy shall be applicable to all officers and employees of the Nichireki Group, and they shall strive to conduct safe operations and to protect information assets.

  3. Information management system

    A director shall be appointed as Information Management Supervising Manager under the Board of Directors, and an information management system shall be established covering all departments, offices and branches.

  4. Group’s internal regulations and rules in place

    The Nichireki Group shall have its internal regulations and rules in place that stipulate information handling, information system operations standards, standards for developing and introducing information systems, physical security measures, and outsourcing standards among others to implement and manage information security practices.

  5. Internal audit

    Internal audit shall be regularly performed to verify if the Group’s internal regulations and rules successfully work and are appropriately adhered to by its officers and employees.

  6. Improving security literacy

    The Nichireki Group shall provide its officers and employees with education and training on an ongoing basis to maintain and improve their security literacy.

  7. Adapting to changes in the business climate

    The Nichireki Group shall flexibly adapt to changes in its business domains, information assets being handled and the ICT (information and communications technology) landscape, and review its information security management rules and systems.