Embedding the Code of Conduct
The Nomura Group Code of Conduct serves as a guide for all employees to translate into actions the core values of entrepreneurial leadership, teamwork and integrity outlined in our Group Corporate Philosophy.
The Code represents our commitment to our clients and all stakeholders to adhere to the highest standards of ethics and integrity in our business activities.
Promoting Proper Conduct - Conduct Program
The firm conducts business in accordance with the Conduct Program, a group-wide framework aimed at embedding the Code of Conduct across the firm and reducing risks arising from inappropriate conduct.
Matters related to the establishment, amendment and abolition of the Code of Conduct are referred to the Board of Directors, and initiatives to promote proper conduct and the annual conduct plan are also reported to the Board. We disseminate information and encourage desired conduct through our executive level committees, our subcommittees at the department and branch management level, as well as working groups. We also manage risks by limiting inappropriate conduct through regulations and monitoring. Under the supervision of each divisional head, Senior Conduct Officers and their respective support teams draft an annual plan and implement specific activities to carry out the plan. To ensure effectiveness, we use the PDCA cycle to identify conduct that could adversely impact clients and/or the market, formulate preventive measures, conduct monitoring, identify problems, and plan subsequent actions.
Employees’ contributions to these efforts are reflected in their performance reviews, thereby providing additional motivation for them to be proactively involved.
Nomura Group Code of Conduct
Our business is built on the trust of our clients and all stakeholders. We regularly review our Code of Conduct to ensure it aligns with the expectations of society.
Initiatives to Promote Dissemination of the Code of Conduct
We are implementing various initiatives to ensure that our people clearly understand and abide by the Code of Conduct, and to foster the correct culture in the firm.
Raising Awareness
- Training for new hires, trainings by title and by themes
- Promotion of Nomura 5 YES and Code of Conduct apps on corporate mobile devices
- Intranet site to promote good conduct
- Entries and listing of outstanding conduct slogans
Generally provided in Japanese and English
Motivate Our Employees
- Include in performance reviews
- Commend good conduct
- Implementation of divisional activities and reports
Learn from Mistakes
- Group executives and employees pledge to comply with the Nomura Group Code of Conduct every August 3 on Nomura Founding Principles and Corporate Ethics Day, and engage in discussions to clearly understand and abide by the Code of Conduct
- Regularly share examples of what requires attention
Responsibility to Speak Up - Compliance Hotline
All employees are responsible for reporting any suspected violations of laws and regulations, violations of the Nomura Group Code of Conduct, or suspicious accounting or auditing activities. Nomura Group companies in Japan and overseas have internal reporting systems (hotlines). We ensure our Group compliance system is effective by regularly reporting the status of its operations to the person responsible designated by the Board of Directors of Nomura Holdings. We are also working to raise awareness and promote the use of hotlines internally, and foster an organizational culture in which anyone can raise their voice when they feel something is wrong.