Corporate Governance | Compliance

Nomura Group works to prevent behavior that may give rise to suspicion of violations of legal regulations. Should such issues arise, all related information is promptly transmitted to management without exception, and systems have been put into place to deal with these appropriately. In addition, in accord with the Regulations of Nomura Group Management Structure, all Group companies comply with laws and regulations that have been enacted for the industries where they engage in business activities and supervise compliance based on their internal regulations.

Appointment of a Group Compliance Officer

To create a substantially stronger system for internal supervision activities at all Nomura Group companies in Japan and internationally, a Group Compliance Officer was appointed on April 1, 2007, with overall responsibility for Group compliance.

Compliance Officers

Each domestic Nomura Group company appoints a Compliance Officer who is responsible for confirming that all employees are aware of their obligations to respect the law and that business operations are conducted in a manner that complies with laws and regulations. Due to the differing nature of operations, each Group company may appoint a Compliance Officer for each department or one or more Compliance Officers at each head office or company. Compliance Officers are responsible not only for monitoring adherence to laws and regulations but also for ensuring that activities conform to social standards from the standpoint of corporate ethics.
Group Compliance Officers attend an annual training seminar to reinforce awareness of their responsibilities and raise awareness within Nomura Group of the need to observe a unified compliance policy and set of regulations.

Compliance Hotline

Nomura Group employees in Japan who have become aware of actions that may violate laws and regulations are able to report their concerns directly to NHI management through a Compliance Hotline. This hotline also allows such reports to go directly to an outside director as well as a legal supervisor (an independent legal attorney), in addition to the designated executive offi cer at NHI, information may be given anonymously, and employees have been informed that measures are in place to ensure that individuals who give their name when reporting violations do not suffer any negative consequences from their actions.

Addressing Legal Risk Globally

Because Nomura Group conducts business on a global scale, adequate measures are taken with regard to legal risks associated with overseas compliance and cross-border transactions.
Nomura Group is heightening its professional expertise concerning the regulatory environment for its international activities. We are also refining skills in the development of cross-border products and services that take into account the requirements of laws and regulations of various regulatory regimes.
Overseas legal risk is managed primarily on a regional basis. As part of the management of legal risk associated with global business activities, Nomura Group periodically holds a global legal conference and a global compliance conference. These provide a forum for examining problems involved with crossborder and other business activities.

Nomura Securities Compliance Structure

Nomura Securities has established a Compliance Program, which is a detailed action plan for compliance, and developed its compliance structure based on this program.

Compliance Committee

• The Compliance Committee is made up of 11 executive officers including the CEO, the Internal Administration Supervisor, and two external lawyers who act as legal supervisors. As a rule, the committee meets twice each month to discuss the internal control system, compliance rules and other important matters concerning compliance.

Compliance Management at Departments and Branch Offices

• In accordance with Japan Securities Dealers Association regulations, Internal Controls Officers are assigned within front-office departments and Compliance Officers are assigned at each department and branch office.

Compliance Hotline

• The Nomura Securities Compliance Hotline provides another means, separate from the Nomura Holdings channels, for Nomura Securities employees to submit information directly to the Internal Administration Supervisor and external lawyers.
  These lawyers are the legal supervisors of Nomura Securities' Compliance Committee. Employees who report violations to the Compliance Hotline can choose to remain anonymous. Employees are also informed that measures are in place to ensure they are completely protected from any negative consequences should they use their real names.

Nomura Securities Compliance Hotline

Compliance Training

• Compliance manuals designed to ensure a clear understanding of laws and regulations are made available via Nomura Securities' intranet, providing a compliance education framework for all directors, officers, and employees.
  Training programs are conducted in accordance with the duties of employees, and training materials are used for monthly training sessions at branch offices. Reports on the implementation of these sessions are submitted to administrators.

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