The Fujikura Group Anti-Corruption Policy
April 1, 2014
The directors, officers and employees of Fujikura Ltd. and its global subsidiary companies (hereinafter "Fujikura Group," and when referring to the directors, officers and employees of Fujikura Group, "Fujikura Group Members") comply with applicable laws and regulations related to the prevention of bribery in all countries and areas where Fujikura Group conducts business activities (hereinafter "Anti-Corruption Laws"; the term Anti-Corruption Laws includes, but is not limited to, each country/area's Criminal Law, Unfair Competition Prevention Act, FCPA, Bribery Act 2010, and the like; furthermore, in addition to the relevant country/area's laws and regulations, the term Anti-Corruption Laws also includes the situation where another country/area's laws and regulations, are applied extraterritorially or on some other basis). In addition, Fujikura Group Members comply with the Fujikura Group Anti-Corruption Policy (hereinafter "this Policy").
This Policy, proposed by Yoichi Nagahama, the President and CEO of Fujikura Ltd., has been established with the consent of all directors at the board of directors meeting. The CEO and the board of directors require that Fujikura Group and Fujikura Group Members comply with this Policy under all circumstances.
The global subsidiary companies of Fujikura Ltd. shall take measures, such as corporate acts, etc., necessary to apply this Policy within their own companies.
1．Prohibition of Corrupt Practices
Fujikura Group Members shall comply with generally accepted accounting principles in all cases. Accounting books and records shall be recorded accurately, and they shall not, for any reason, be false or cause misunderstanding. Accounting books and records that do not have both necessary and sufficient entries or that do not reflect exact deals shall not be created.
Any person(s) at Fujikura Group who has knowledge of violations of this Policy and managers who have received reports from those who have such knowledge, have an obligation to report the same. The reports shall be made to his/her immediate superior and/or to the Legal Section of Fujikura Ltd. Reports may also be made anonymously through the whistle-blowing system.
Those who have made the reports shall not be treated unfavorably by the Fujikura Group for making such reports.
4．Role of managers
This Policy requires all managers at Fujikura Group to play specially important roles. They shall recognize their roles and supervise and manage his/her organization and its members accordlingly.
Fujikura Group monitors whether this Policy is followed through internal audits, etc. of Money etc. expenditures and through internal audits, etc. on the supervising and managing referred to in 4 above.
6．Penalties and Philosophy of Fujikura Ltd.
Fujikura Group Members that are confirmed to have violated Anti-Corruption Laws and/or this Policy may be given unfavorable treatment such as disciplinary action by Fujikura Group. When Fujikura Group is aggrieved by a Fujikura Group Members’ violation of Anti-Corruption Laws and/or this Policy, Fujikura Group can make a claim for damages against the violating member.