NOMURA

February 2003

The Nomura Group, a leading Japanese financial services group, runs a whistle-blowing programme that gives employees who suspect wrongdoing access to a telephone and e-mail service linked directly to a chief compliance officer.

In a case study submitted to the ICC Corporate Governance website, Nomura said the programme was created in October 1997 in response to scandals related to "fixers" at general shareholders' meetings involving several industries in Japan.

At first, the service was confined to Nomura Securities, a core subsidiary of the Nomura Group, but a new system was introduced last October for the entire group. All group employees are allowed to contact the chief compliance officer or a non-executive director.

Nomura defines whistle-blowing issues as actions s uspected to be in violation of the law and those that breach the company's internal rules. Employees may use the hot line if they believe discussions within their department are unlikely to resolve the problem. They are also free to contact Nomura's legal supervisors.

Nomura Group, which has worldwide operations, provides a wide range of financial services.
These include brokerage, trading, underwriting, M&A financial advisory services, merchant banking, and development and management of investment trusts and investment advisory services. Nomura Group is headquartered in Tokyo and has offices in 28 countries outside Japan. Nomura Securities has 128 branch offices including a head office in Japan. .

Nomura describes three specific measures in took in October 2001 to strengthen the Group's corporate governance.:

- Non-executive directors were appointed, although this is not required under Japan's commercial law. Two of Nomura Holding's 11 directors are non-executive directors.

- An Audit Committee was established, which also includes a non-executive director, The committee's task is to promote corporate propriety across the entire Nomura Group.

- An Executive Compensation Committee has been set up to discuss modalities for Nomura Group compensation. Non-executive directors are in the majority on this committee.

In addition to these moves, an Advisory Board was established in 2001. Consisting of top managers of prestigious Japanese companies.