NTT Communications Procurement
APAC Supplier Code of Conduct
Senior Vice President,
President and APAC CEO,
Tricia Lim Wan Ling
Executive Vice President,
At NTT Communications, we are dedicated to help customers to accelerate development, strengthen their competitiveness, enter new markets and develop new businesses through a wide range of innovative global information and communications technology (ICT) solutions including cloud, network and security services. This is made possible through our suppliers and partners who share our commitment to quality, cost and delivery, who operate under the highest standards of integrity, compliance and corporate ethics.
It is with great pleasure that we share to you our inaugural APAC Supplier Code of Conduct for NTT Communications affiliates. This Code of Conduct applies to businesses that provide products or services to NTT Communications’ APAC affiliates and its subsidiaries and/or joint ventures. We do recognize that legal and cultural requirements vary in a global business environment, and expect that all our suppliers follow the applicable laws of their country or territory. At the same time, the APAC Supplier Code of Conduct sets forth certain universal requirements that suppliers must follow.
Our objective in this APAC Supplier Code of Conduct is to provide you with the information you need to be successful when dealing with us or with your own subcontractors or suppliers. This document provides the foundation for our ongoing evaluation of a supplier and constitutes additional terms of your contract with NTT Communications.
If you have questions or feedback about this Code, or need any additional information or assistance, please contact your relevant NTT Communications Procurement Representative.
APAC Supplier Code of Conduct
NTT Communications is committed to responsible business practices and to high standards of ethical behavior. We hold our suppliers to high standards of excellence defined in governing laws, recognized international standards and conventions, and global best practices.
The APAC Supplier Code of Conduct reflects the standards and business practices we expect from all our suppliers. Our suppliers’ responsibility is to ensure all related staff and subcontractors is familiar and comply with the spirit and letter of the supplier code of conduct.
We reserve the right to terminate any agreement or business relationship in which a supplier does not comply with this supplier code of conduct.
The APAC Supplier Code of Conduct is applicable to the following NTT Communications’ subsidiaries:
NTT Singapore Pte Ltd
PT. NTT Indonesia
NTT Communications (Thailand) Co., Ltd.
NTT MSC Sdn. Bhd.
NTT Communications (Vietnam) Ltd.
1.0 Business Ethics
1.1 Legal and Ethical Matters
Our approved suppliers are expected to conduct business fairly and transparently. You are expected to maintain the highest level of integrity and professionalism, deal fairly and transparently in all your business dealings. You should not make false claims or sales, misrepresent or withhold facts in order to take advantage of NTT Communications. You should also not engage in price fixing, overcharging, carving out of business client and territories, or collusion against other parties. In the course of business, you should not share NTT Communications’ confidential information such as business and marketing strategies, pricing and costs to other parties unless authorized by NTT Communications. You are required to comply with applicable local and international laws, regulations, ethical trade requirements; applicable NTT Communications and our end client’s Business Ethics standards/Code of Conduct, policies & procedures.
Bribery and kickbacks is strictly prohibited. You are required to comply with all applicable local and international anti-bribery laws including but not limited to Singapore’s Prevention of Corruption Act, the U.S. Foreign Corrupt Practices and UK Bribery Acts. No bribes, kickbacks, ‘facilitation’ payments, loans, fees, favors, gifts of significant value or other similar remuneration or consideration should be offered or promised by your staff and your company directly or through intermediaries, to any person or organization in order to attract or maintain business, influence or secure preferential action and outcomes. Similarly, you should not, directly or through intermediaries, request for, extort or accept any bribes, kickbacks, gifts or benefits that would violate any applicable anti-bribery laws and regulations.
NTT Communications’ practice on receiving corporate gifts: all gifts, prizes and similar items of significant monetary value received by NTT Communications will be declared and shared/redistributed with the employees. Please contact our procurement team if you have any clarifications regarding this policy. If a supplier is found to have given or received any form of bribery or kickback involving NTT Communications personnel or third party, we would take action on the supplier and NTT Communications personnel involved, including but not limited to reporting of criminal act to the relevant authorities.
NTT Communications treats our relationship with our suppliers seriously. If there is an unlawful or unethical issue arising from our employees during the course of business, kindly flag this out via the contact provided at the end of this letter. Similarly, if there is any form of unethical activity by our suppliers, we reserve the rights to suspend or delist the company from our Approved Supplier List, and further sanctions to be made accordingly.
1.2 Conflict of interests
NTT Communications does not tolerate suppliers who poach or deal with our customers directly without our consent. If a supplier is found to have unethically worked with our customer, we reserve the rights to suspend or delist the company from our Approved Supplier List, and further sanctions to be made accordingly. Suppliers are expected to declare to NTT Communications in event their company or any staff of their company has a conflict of interest against NTT Communications or end-customers of NTT Communications. Suppliers are expected to report to NTT Communications any situation where they are aware that a NTT Communications employee or professional under contract with NTT Communications might have a conflict of interest with them.
1.3 Handling of Confidential Data, Personal Information
Any information shared by NTT Communications with you is confidential and should not be shared with third parties. If you are subcontracting your work to a third party, please ensure that back-to-back non-disclosure agreement is enforced on your subcontractor, that only the relevant scope of work is shared to the third party, and that the third party understands and complies with NTT Communications policies and procedures.
All confidential information related to NTT Communications and its end clients must be managed, retained and disposed in accordance to the NTT Communications Information Security policy, as well as any applicable regulations.
As part of your work, you may have access to personal information, such as information about NTT Communications employees, business partners and/or customers. NTT Communications respects the privacy of all its employees, business partners and customers. You may only use such personal information responsibly and in compliance with all applicable personal data laws. You are also responsible for protecting both NTT Communications and our client’s intellectual property rights.
In performing your obligations as a supplier to NTTS, you must ensure that you:
- Comply with all applicable laws and regulations in relation to confidentiality and data privacy in the relevant jurisdiction(s)(in particular at all times with the PDPA and GDPR);
- Comply with all contractual obligations in respect of confidentiality and data privacy;
- Collect, use and process such information only for legitimate business purposes;
- Limit access to the information to those who have a legitimate business purpose for seeing the information; and
- Put in place security measures no less stringent than that of commercially accepted levels to prevent unauthorized disclosure of confidential information and personal data.
1.4 Protecting NTT Communications company assets
NTT Communications assets are a critical part of our operations and value. Examples are, but not limited to:
Physical assets - such as office equipment, servers, network equipment
Resources - such as confidential intellectual property and data
You are responsible for:
Safeguarding NTT Communications company assets that you might be in custody of;
Ensuring NTT Communications assets are used only for authorized business activities;
Ensuring NTT Communications assets are not used for any private, illegal or prohibited activities by law or against NTT Communications policies; and
Ensuring no information leakage by observing good security practices such as confidential information protection, password policies.
1.5 Financial integrity, Record Maintenance & Audit
You must not convey false or inaccurate financial information to NTT Communications or our clients. All submissions you make to NTT Communications must be complete and accurate. You must maintain documentation accurately and completely, and reasonably necessary to comply with this APAC Supplier Code of Conduct, governmental and industry regulations. You must provide NTT Communications or its independent auditor with access to relevant documentation upon reasonable request, and not withhold information or provide any misleading statements.
2.0 Environment, Health and Safety Requirements
NTT Communications Commitment
NTT Communications is committed to:
Environmental sustainability and preservation as per our Corporate Social Responsibility charter; and
Health and safety as a non-negotiable priority for our employees, contractors and other people impacted by our business activities.
You have a role to ensure that you do not engage in any activities or services that
Violate environmental, health or safety laws of any country; and/or
Conceals in any form such illegal activities.
All NTT Communications suppliers’ business activities must comply with our environmental, health and safety policies, and NTT Communications suppliers are to adopt measures to prevent pollution, minimize waste generation, and ensure the safety and well-being of our employees and other people impacted by our business activities. If you become aware of any such illegal activities, report this via the contact provided at the end of this letter.
2.1 Environmental Code of Conduct
NTT Communications is committed to protecting the environment. Supplier shall develop, implement and maintain environmentally responsible business practices:
Environmental Permits: Supplier shall obtain, keep current & comply with all required environmental permits, and comply with applicable environmental permits and regulations.
Waste Management: Supplier shall implement a systematic approach to identify, manage, reduce and responsibly dispose or recycle non-hazardous waste.
Hazardous Waste Management: Supplier shall implement a systematic approach to identify, manage, reduce and responsibly dispose or recycle hazardous waste. Supplier shall comply with all applicable regulations with regards to Hazardous Waste Management.
Pollution Management: Supplier shall identify, manage, control and reduce water, air and noise pollution produced by its operations. Supplier shall conduct routine monitoring of their control systems.
Conservation & Resource Reduction: Supplier shall reduce energy, water and natural resource consumption by implementing conservation measures. Supplier shall minimize resource consumption by implementing reduction measures.
2.2 Health and Safety Codes
Worker health, safety, and well-being are important to NTT Communications. Supplier shall provide and maintain a safe work environment and integrate sound health and safety management practices into its business. Their workers shall have the right to refuse unsafe work and to report unhealthy working conditions.
Occupational Health, Safety, and Hazard Prevention: Supplier shall identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, engineering controls, and/or administrative controls. Supplier shall provide workers with job-related, appropriately maintained personal protective equipment and instruction on its proper use.
Emergency Prevention, Preparedness, and Response: Supplier shall identify and assess potential emergency situations. For each situation, Supplier shall develop and implement emergency plans and response procedures that minimize harm to life, environment, and property.
Incident Management: Supplier shall have a system for workers to report health and safety incidents and near-misses, as well as a system to investigate, track, and manage such reports. Supplier shall implement corrective action plans to mitigate risks, provide necessary medical treatment, and facilitate workers’ return to work.
Ergonomics: Supplier shall identify, evaluate, and control worker exposure to tasks that pose ergonomic risk such as excessive force, improper lifting positions, or repetitiveness. Supplier shall integrate this process into the qualification of all new or modified production lines, equipment, tools, and workstations.
Working Conditions: Supplier shall provide workers with reasonably accessible and clean toilet facilities and potable water. Supplier should provide proper work place to all their workers.
Health and Safety Communication: Supplier shall provide workers with appropriate workplace health and safety training in their primary language.
Worker Health and Safety Committees: Supplier is encouraged to initiate and support worker health and safety committees to enhance ongoing health and safety education and to encourage worker input on, and participation in, health and safety issues in the workplace.
Workplace Safety and Health Act: Suppliers are required to comply with the Workplace Safety and Health Act.
2.3 Human Resource Code of Conduct
NTT Communications follows a list of employment practices that is governed by each country’s legislation and is also guided by certain employment best practices from assisting organizations. Below is a list that covers the critical points for NTT Communications employment practices. In addition, NTT Communications expects its suppliers to adhere to the lists below. Suppliers must ensure that:
Labor laws are abided
Employment is freely chosen
Recruitment and selection of employment is on the basis of merit (such as skills, experience or ability to perform the job) regardless of age, race, gender, religion, marital status and family responsibilities, or disability
Freedom of association and the right to collective bargaining are respected
Working conditions are safe and hygienic
Child labor shall not be used
Working hours are not excessive
No discrimination is practiced
Regular employment is provided
No harsh or inhumane treatment is allowed
Employees are fairly treated and with respect
Progressive human resource management systems are put into place
Employees have equal opportunities to be considered for training and development based on their strengths and needs, to help them achieve their full potential
Employees are rewarded fairly based on their ability, performance, contribution and experience.
3.0 Violation of Supplier Code of Conduct
If any of our suppliers is found to have violated the code of conduct as stated in above requirements, NTT Communications will take appropriate action, including but not limited to:
Remedial measures with supplier
Reduction of business activities
Suspension of supplier
Delisting of supplier from Approved Supplier List.
Reporting of possible criminal act to relevant authorities.
4.0 Reporting of unethical behavior
Kindly report any unethical behavior that might impact NTT Communications to NTT Communications Procurement or NTT Communications company hotline channels:
NTT Singapore Pte Ltd
Compliance Committee Office
20 West Pasir Panjang Road, #11-28, Mapletree Business City, Singapore 117439
NTT MSC Sdn. Bhd.
CEO & President
PT. NTT Indonesia
Wisma 46 Kota BNI, suite 503
NTT Communications (Vietnam) Ltd.
HCM Office: Room 10-13, Floor 4A, Vincom Center, 72 Le Thanh Ton, Ben Nghe Ward, District 1, Ho Chi Minh City, Vietnam
HN Office: Room 201, 2nd F HITC, 239 Xuan Thuy Street, Dich Vong Hau Ward, Cau Giay District, Hanoi, Vietnam
Thailand, Cambodia, Laos and Myanmar
NTT Communications (Thailand) Co., Ltd.
6th Floor, Column Tower, 199 Ratchadapisek Road, Klongtoey, Bangkok 10110, Thailand.
Singapore Prevention of Corruption Act (Cap 241) - US Foreign Corrupt Practices Act - UK Bribery Act - Europe GDPR - Personal Data Protection Act 2012 - Workplace Safety and Health (WSH) Act, WSH Legislation - Employment Act, Employment Practices - Tripartite Alliance for Fair and Progressive Employment Practices (TAFEP) - Sedex Members Ethical Trade Audit (SMETA)