In order to embody the MVCV Group management philosophy, we must not only act in accordance with standards of conduct that enhance the corporate value of the Fujikura Group, but also act in a manner that does not damage the corporate value we have built up over the years.
To this end, we have established the principles of conduct that each and every employee should observe as the "Group Code of Conduct" and are promoting group-wide efforts to establish corporate ethics.

Compliance with various laws and regulations by Fujikura employees and other persons engaged in Fujikura operations is overseen by the Risk Management Committee, which is chaired by the President. The Risk Management Committee met 23 times in fiscal 2020, including regular as well as extraordinary meetings. At the three meetings held in the first and second halves of the fiscal year, reports were made on legal compliance education, case studies, and other measures planned by the corporate division to identify issues and share information.

The Fujikura Group operates an Whistleblower system that stipulates protection, confidentiality and prohibition of disadvantageous treatment of whistleblowers. The purpose of this system is to detect and respond quickly to fraud / compliance, harassment, violation of work rules, etc. In Japan, in addition to the internal contact point, an external contact point has been set up by an external lawyer to receive reports from Fujikura Group employees.
In addition to the reporting contact established by each overseas subsidiary, a reporting contact has been established with an external specialized company to establish an internal reporting contact at the Fujikura Group's overseas locations.

At the meeting of the Board of Directors held on September 28, 2009, participants passed a resolution on the Fujikura Anti monopoly Act Compliance Program with a view to ensuring compliance with the law through the announcement by the President of the company's commitment to compliance and also through the provision of relevant instructions to all directors and employees as well as through the enhancement of our in-house compliance system.

The Fujikura Group regularly conducts audits in order to confirm the internal compliance system and compliance status of the Fujikura Anti-Monopoly Compliance Program.
Fujikura established regulations on contact standards with competitors as the lower regulations of the Fujikura Anti-Monopoly Compliance Program and imposes certain limits and standards when employees have contact with competitors. As an ongoing effort every year, we conduct e-learning on Japan’s Antimonopoly Act for those targeted employees in Group. We will continue to hold such e-learning education in the future.
In FY2020, e-learning training (study and test) on antitrust law was provided to Fujikura Group subjects. A total of 3,125 employees participated in the training, for a total of 4,688 hours of training. In addition, education and training on antitrust and competition laws were provided in rank-based training programs.

The Fujikura Group Anti-Corruption Policy was approved by the Board of Directors and the Managing Directors Meeting and was established on April 1, 2014. After that it was revised 2nd edition on June 2020. The Fujikura Group disseminates information on this policy in the group. This policy also regulates compliance in the supply chain.

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 was revised on June 1, 2020 to state that business entertainment and gifts should be properly handled, even when there are no violations of laws and regulations.

Every year we hold at least one session of e-learning comprising learning and comprehension test in order to develop the understanding of the Fujikura Group anti-corruption policy and raise awareness about anti-corruption examples(ex. anti-bribery) among officers and employees. In Fiscal 2020, course participants in this training reached a total of 4,602 and they spent a collective 6,903 hours in training.

Risk assessments will be conducted as appropriate, primarily by the Legal Office. The risk assessment is based on the external environment, including national, regional, and industry conditions; the degree of contact with public officials, etc. (licensing, customs clearance, etc., customers, etc.); the maintenance and penetration of internal rules; and the status of training.

The Fujikura Group includes provisions on anti-corruption and exclusion of anti-social forces in the basic business agreements it concludes with suppliers for the procurement of materials and components.
On April 2, 2010, we established the Fujikura Group Procurement Division Code of Conduct in an effort to prevent fraud and corruption in procurement and we are making efforts under it to prevent a breach of duties. In addition, we have established guidelines on establishing appropriate relationships with business partners, and we promote fair and equal procurement activities through regular training provided to employees. The Fujikura Group CSR Procurement Guidelines include provisions prohibiting corruption and bribery and abuse of an advantageous position to prevent corruption, including among suppliers.

The Fujikura Group has established Rules on Management of Internal Information to clearly delineate the internal structure for compliance with rules of information disclosure designed to ensure fair and impartial markets, and to prevent insider trading by officers and employees.

Fujikura began providing a new e-learning course (study and testing) for officers and employees in fiscal 2020 to ensure knowledge of and strict compliance with laws and regulations on insider trading. The total number of course participants has reached 4,639 and they collectively participated in 2,830 hours of training.

In the international community a new national surveillance capitalism has emerged in China to counter the order of the liberal capitalistic system championed by Europe and the U.S. The new order advocated by China is now affecting existing rules and a battle over the competitive superiority of these systems in terms of economic security has begun.
Economics and security (national defense) are two sides of the same coin. Economic security measures in the U.S. are being drastically revised, starting with the fiscal 2019 National Defense Authorization Act. Revisions are not limited to the U.S. Export Control Reform Act (ECRA). A wide range of existing rules are being revised from the viewpoint of security. It is necessary to have an in-depth understanding of trends in the U.S.
On the other hand, China is looking to the U.S. as a reference in establishing its legal system, and we also need to keep a close eye on the legal system that will be created in China.A movement toward revising the rules of competition from the perspective of economic security has begun in Japan as well.The need for Japanese companies to pay close attention to national government policy on trade control (export control) for security reasons has also emerged in this climate.
Fujikura officially approved the Basic Policy of the Fujikura Group for Export Control at an executive committee meeting in 2015, and clearly declares the commitment of the entire Group to security export control initiatives as a member of the international community.

As a result of efforts in fiscal 2020, there were no cases of serious legal violations.