Heh cause its Dlsite? And the NTR tag sells like hotcakes in Japan? I mean, afterall anything can be tagged as "netorare" as long as there is another guy in the mix who "doesn't win the girl" in the end. Like I said, heroine has no lover/husband so Netorare shoudn't exactly apply. But she does have a junior officer who is clearly in love with her but NEVER and I really mean NEVER, do they confess to each other and have a relationship.
Now NTR hungry minds will say "Yea, that's NTR definitely." But is it though? For me it is the same as someone saying "Mom and son are not in a relationship, but because Mom is screwing around with the entire city while son "peeps", is NTR!". I mean... sure? If you must? But is it really?
Anyways, play and find out yourself. Different strokes for different NTR folks.