NTT DATA : Corporate Governance Report Updated

NTT DATA promotes constructive communication with shareholders and investors. To contribute to continuous growth and improvement in the Medium-to Long-term enterprise value of NTT DATA, our policy takes the following measures:

(1) Appointment of a director in charge of communication with shareholders

To achieve constructive communication with shareholders and investors, a director responsible for Investor Relations (IR) is appointed.

(2) Policy for systematic cooperation among internal offices

NTT DATA has opened an office specializing in IR (the Investor Relations Office). It has also set up the Disclosure Committee, which is made up of the President and CEO, the Head of Finance Department and also the heads of all significant organizations which are required to join by the Head of Finance etc. The said Committee is operated by the Investor Relations Office and has regular discussion on the formation of the disclosure policy relating to, and disclosure of, the following management information:

1) Quantitative information, such as the Medium-term Management Plan, the background to the formation of the Management Plan, the trend of clients and solutions by area, and the business scale of individual businesses;

2) Qualitative information, such as the Medium-term Management Policy, the policy for returning profit to shareholders (including dividend policy), and the trend in each industry; and

3) Any information considered important for investors etc. other than 1) and 2).

(3) Efforts for the sufficiency of conversational procedure except for individual interviews

NTT DATA has established and disclosed 'Disclosure Policy' and holds the briefing sessions on company overview and strength, growth strategy, and shareholders return etc.

(4) Policy for effective feedback on shareholders' opinions and concerns

NTT DATA has established an office specializing in IR under the direct control of the President and CEO, and properly reports on feedback such as the opinions or concerns of shareholders and investors to the Board of Directors, a regular meeting participated in by the President and CEO etc., and the Disclosure Committee. NTT DATA also creates opportunities for NTT DATA's directors and Senior Vice Presidents to directly communicate with shareholders and investors to understand their opinions and concerns.

(5) Policy for the management of inside information in communication

NTT DATA has established the provisions for handling the matters of the company's significant information before disclosed in such as 'Rules for Prevention of Insider Trading' and 'Policy (Rules) for Information Security,' and strictly control the information, and also provides the periodical training to the all employees based on our same rules, and strive to prevent the occurrence of insider trading.

Also NTT DATA has established the 'Disclosure Guidelines' striving to provide timely and fair disclosure of information with the purpose of contribution for the shareholders and investors' fair and appropriate investment decision, and disclose the information with the purpose of clarifying our position toward the information disclosure to the outside by establishing and disclosing 'Disclosure Policy.'