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Governance | Compliance

Nomura Group has established an appropriate compliance framework, and insists on compliance with all applicable laws, rules and regulations in all Group companies and departments.

Fundamental Approach

Compliance is a top management priority for Nomura Group, and the Code of Ethics of Nomura Group defines our fundamental policy on compliance. The management and employees of the Group pledge to abide by the rules stated in this code once each year. Also, we have established Nomura Founding Principles and Corporate Ethics Day, as a day for management and employees to annually reaffirm our corporate culture and corporate ethics, underpinned by Our Founder's Principles.

Our management and employees always set their challenges related to professional ethics and compliance as part of the issues they plan to address determined at the outset of each fiscal year. If problems are found, the assessor provides proper guidance and reflects evaluation results in their pay scale. Also, Nomura Securities conducts an ethics training course once a year for management and employees. This course is intended to give all employees a substantially heightened understanding of workplace ethics through the exchange of views by employees and other means.

You may report to us your concerns regarding our accounting, internal accounting controls or auditing matters via the feedback link below.

Request to Nomura Group Outsourced Service Providers

Nomura Group outsources various operations to outside providers. In order to fulfill our social responsibility, we are requesting our outsourced service providers to understand the purpose of the "Code of Ethics of Nomura Group" and act in accordance with it. As such, we ask that you take the time to read the code by accessing the link below.

If after reading the code you become aware of any issues that you feel we should know about, please contact us via the feedback link below.

Compliance Framework

We have appointed a Group Compliance Head to oversee compliance for the Group as a whole along with a Group Compliance Department that provides support. In addition, Compliance Officers have been assigned to each Group company to strengthen our internal controls in response to global business, and to develop and maintain the respective compliance structures of each Group company, including overseas offices.

Compliance framework
Image: compliance framework

Nomura Securities' Compliance Structure

In addition to Group-wide initiatives, Nomura Securities has established a Compliance Program as a detailed action plan, and put into place a compliance framework based on this program.

A Compliance Committee chaired by the President oversees Company-wide initiatives and is in charge of establishing and deliberating on important issues related to internal controls.
The Company has established the post of Internal Administration Supervisor to monitor compliance issues in line with Japan Securities Dealers Association's rule
The Company has established the posts of Sales Officers, Internal Controls Officers and Compliance Officers
The Compliance Division strengthens and improves legal and regulatory compliance as well as the internal controls system by formulating internal rules and disseminating them throughout the Company.

Legal Compliance Measures

In all Group companies and departments, Nomura Group insists on compliance with laws and regulations and endeavors to prevent the occurrence of activities that may be construed as illegal by structuring the necessary administrative systems. In the event that such issues arise, they are reported in full to management-level officers without delay, and organizations and systems are structured to respond appropriately.

When actions that may impair trust in the capital markets and major violations of legal regulations occur that may have a major impact on the Company's reputation and financial position, after due investigation and confirmation, related information is made available on the Company website.

Compliance Hotline

Employees in Japan who have become aware of potential legal or regulatory violations are able to report their concerns to persons designated by Nomura Holdings, including Outside Directors, through the Compliance Hotline (persons reporting have the option of remaining anonymous). In FY2015/16, there were 19 calls received via the Compliance Hotline, and the status of related matters was confirmed, and appropriate measures were processed.

Compliance Training

We conduct comprehensive compliance training for all Executive Officers and employees on topics such as the prevention of money laundering and insider trading, firewall regulations, and guidelines for managing customer information.

Nomura Securities' Primary Initiatives
Training for sales officers, internal controls officers, and employees of internal controls departments, as well as quality improvement training for securities sales representatives
Training for branch managers, general administration managers, new employees, newly appointed personnel, and others, aimed at increasing knowledge and deepening the understanding of compliance
Supplementary compliance education and drills during various training sessions and meetings
Training for Compliance Officers
Monthly Compliance Hour* at branch offices and departments
  • To ensure that each and every employee throughout the Company understands the need for full compliance, training sessions are held once a month in the branches and offices of Nomura Securities.

Customer Protection and Information Security

Under various applicable laws and regulations, including the Financial Instruments and Exchange Act and the Personal Information Protection Act, Nomura Group works to properly protect customers' assets and information.

Nomura Group Information Security Policy

Appropriate management of client data is essential in order for the Nomura group to keep the trust of our clients and shareholders. This policy sets out basic principles for safeguarding the security of information. Each company in the group maintains its own supplemental rules based on the policy and continually improves the management of information supplied to clients according to business requirements. Executive officers and employees can review our information security regulations on our intranet.

Nomura Securities has prepared internal regulations that include rules regarding insider trading to strictly manage information related to corporate clients.

Information Security Management

Under the Nomura Information Security Management Regulations, Nomura appoints a Chief Information Security Officer from the executive officers. The Chief Information Security Officer takes responsibility as personal data management supervisor defined by the Financial Services Agency and strives to ensure Information Security.

All Nomura Holdings, Inc., Nomura Securities Co., Ltd., Nomura Asset Management Co., Ltd., and The Nomura Trust and Banking Co., Ltd. department and branch office heads serve as Information Security Managers and are responsible as personal data controllers. These Information Security Managers are responsible for the security and proper management of information assets handled by their work area and for properly providing their staff with advice and guidance in this regard.

Personal Information Protection

The Nomura group handles personal information about its many customers with care, and efforts regarding personal information are very important. We handle customers' personal information with extreme care, complying with personal information protection-related laws and regulations as well as the Nomura Group Privacy Policy and the aforementioned information security-related rules.

Nomura Securities Co., Ltd. appointed an Information Security Manager and a checker for each department to thoroughly safeguard personal information, including the Individual Number, by overseeing the management or handling of the following items.

  • The status of personal information management before leaving the office
  • Electronic files containing personal information
  • Personal information ledgers
  • Contractor pledge forms, statements, etc.
  • Procedures controlling the removal of client information outside the company
  • Responses to disclosure requests
  • Training and other activities related to information management
  • IDs/passwords
  • E-mail correspondence with parties outside the company and information terminals
  • Corporate information
  • External recording media
  • Information the company delivers by fax
  • Access logs during late night hours and holidays

Security Measures for Online Services

In order to accommodate the diverse needs of its clients, the Nomura Group provides a wide range of its services over the Internet. These services use the latest, most advanced encryption technologies to ensure that important client information is always safeguarded. Furthermore, we have strengthened surveillance of our in-house systems and implemented new security systems in order to prevent illegal access from external parties or information leakages caused by cyberattacks, which have become increasingly threatening in recent years.

Protection of Customer Assets

In accord with various applicable laws and regulations, including the Financial Instruments and Exchange Act, Nomura Securities properly segregates the assets of its customers from the assets of Nomura Securities itself.

Note that Nomura Securities requests Ernst & Young ShinNihon LLC to examine the status of its separate administration of customer assets in accord with criteria in effect under relevant laws in the United States. As of March 31, 2016, Nomura Securities was in compliance with all material aspects of these criteria as regards the separate administration of customer assets and received a report certifying its compliance.

Offering High-Quality Financial Services

Nomura Securities seeks to enhance the quality of financial products and services offered to customers under the Guidelines for Financial Instruments Business Supervision. Some of its initiatives include rigorous screening of account openings and securities underwriting practices as well as the provision of accurate and easy-to-understand information.

Nomura Securities' Primary Initiatives
Appointing officers to oversee internal controls, compliance, etc., and developing systems to ensure compliance and the appropriateness of operations
Thoroughly screening account openings and conducting proper examinations when underwriting securities
Carefully reviewing product details and taking action to provide accurate and comprehensive information
Conducting sales and solicitation activities in compliance with the Financial Instruments and Exchange Act and laws and regulations governing each operation with an overall understanding of the customer's knowledge of financial instruments and financial status
Structuring systems that establish guidelines for sales to senior customers and requiring compliance with these guidelines
Ensuring thorough compliance with laws, regulations, and internal rules through compliance training

Fair Financial Business Practices

Nomura Group works to prohibit transactions with anti-social forces and to prevent money laundering.

Nomura Group has established guidelines related to gifts and entertainment of public officials and private-sector groups, and by disseminating them throughout the Company, works to ensure fair business practices to prevent the acceptance or giving of bribes.

We manage conflicts of interest and insider information from a global perspective by concentrating information in the Group Compliance Department.

Nomura Securities' Primary Initiatives
Protocols for preventing money laundering, including the identification and reporting of suspicious transactions
Protocols for eliminating all transactions associated with anti-social forces or activities in violation of applicable laws, such as not allowing anti-social forces to participate in trading with Nomura Securities
Managing conflicts of interest and insider information from a global perspective by concentrating information in the Group Compliance Department of Nomura Holdings
Prevention of acceptance or provision of bribes through regular monitoring of social expenditures.

Nomura Founding Principles and Corporate Ethics Day

Following the series of insider trading incidents related to public offerings in 2012, Nomura Securities announced business improvement measures on June 29 in 2012, and these have been fully implemented. Going forward, to ensure that our efforts are maintained and sustained, Nomura Securities will take the necessary measures to prevent this incident from having an effect on its reputation and, by implementing fully adequate improvement measures with the cooperation of all management and staff, will work to prevent a recurrence and recover public trust. Nomura is also working to substantially reinforce and improve its internal controls systems.

Nomura Group, which celebrated its 90th anniversary in 2015, has established Nomura Founding Principles and Corporate Ethics Day. This provides an opportunity each year for all of us to reflect on our corporate culture and corporate ethics based on Our Founder's Principles and remind ourselves of the actions that have brought scrutiny upon the firm. Every year on Nomura Founding Principles and Corporate Ethics Day, we take measures for everyone in each Group company, including overseas offices, to think about Nomura's founding principles and corporate ethics to ensure we never repeat the mistakes of the past.

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