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CSR Integrated Report

Fujikura Group CSR Integrated Report 2015
[ISO 26000 Core Subject] Organizational Governance

Compliance

The Fujikura Group is working to implement the Corporate Philosophy MVCV (Mission, Vision and Core Value) to be a corporate group that is appreciated by customers and highly evaluated by society. To ensure compliance, the Group established the Fujikura Code of Conduct on October 1, 2002. In line with this Code and other in-house rules, as well as with laws, regulations, norms, and rules enforced in Japan and abroad, all directors and employees of the Group are striving to make the Group a corporate entity that is trusted and needed by society, giving first priority to compliance, occupational health and safety, the environment, and ties with local communities.

Fujikura Group Code of Conduct

  • fully understand customers' needs and propose safe, high-quality products and services that meet those needs in a timely and reliable manner;
  • treat customers' inquiries and opinions with integrity;
  • disclose information in a timely and appropriate manner not only to shareholders, investors and other stakeholders, but also to the general public, while endeavoring to establish good communication;
  • recognize that protection of the global environment is a universal concern, and voluntarily and proactively work on such issues as preventing pollution, reducing environmental burdens, and developing environment-friendly technologies;
  • conduct ourselves with dignity and good sense, in compliance with the laws and regulations of Japan and other countries, in addition to international rules, and with respect for the cultures and customs of different communities;
  • strive to maintain, manage and effectively utilize the company's tangible and intangible assets and information, and refrain from using them for our own private purposes;
  • pay careful attention to the management of personal information, trade secrets and other sensitive information to prevent mishaps such as loss, damage or leakage;
  • create fair and highly transparent business relationships with customers and suppliers on the basis of free competition, and refrain from any activities that restrict competition, or any dishonest activities such as giving or accepting money and/or gifts, or granting favors;
  • maintain a resolute attitude against antisocial powers and groups, refuse to associate with them and stand firmly against them;
  • execute our duties in good faith based on the authority invested in us with the aim of contributing to the company's performance, and refrain from any activities or behaviors that go against the interests of the company; and
  • create a safe and efficient working environment, respect individuals' creativity and independence, and eliminate all forms of discrimination and harassment.

Promotion System

Internal Reporting System

Our Group established the “Fujikura Group Code of Conduct” in 2002. Along with the establishment of this Code, we have developed and operated the "Internal Reporting System" which guarantees the protection of whistleblowers. The internal reporting system is a system aimed at consulting on human rights, prevention of compliance violation, monitoring the penetration of corporate ethics, and so on. In our internal reporting system, we have established an external consultation desk with independent third parties as well as an in-house consultation desk, and we widely accept reports from employees and temporary staff. In addition, our Group, which is developing its business globally, is also in the process of developing consultation desks at each site. Upon operation of this system, we are trying to bring awareness of this system through our company intranet and in-house training.

[Internal reporting and counseling in FY2015]

FY2014 FY2015
Internal reporting/Consultation 3 15

The internal reporting system has steadily rolled out among employees, and we will continue with further enhancements to fulfill further functions.

Readily Available Portable Leaflets

The Group created and distributed palm-sized leaflets of the "Fujikura Group Compliance Code of Conduct" as a tool to enhance and maintain awareness for compliance among employees. By integrating this leaflet with a portable brochure "Management Philosophy MVCV", we can use it at any time, check it on our own, or use it for chanting it within the department.

The content of the leaflet declares that officers and employees will protect the "antitrust law compliance program" and "anti-corruption policy".

International trends and our measures

Compliance-related international initiatives include conventions, norms, and various other measures. The Fujikura Group CSR Committee is working to ensure compliance, including preventing corruption, in reference to the following international guidelines.

[Compliance-related international guidelines]

  • United Nations Convention against Corruption (Oct. 2003)
  • OECD Convention on Combating Bribery of Foreign Public Officials (May 1997)
  • United Nations Global Compact (Principle Ten: Anti-Corruption) (Jun. 2004)
  • ISO 26000 international standard on social responsibility (Core Subject: Fair Operating Practices) (Nov. 2010)
  • International Integrated Reporting Council (IIRC) International Integrated Reporting Framework 1.0 (4D Risks and opportunities) (Dec. 2013)
  • G4 Sustainability Reporting Guidelines (Society: SO3 corruption-related risks and others) (May 2013)
  • EICC Code of Conduct Version 5.0 (Section D on business ethics) (Nov. 2014)

etc.

Compliance with the Antimonopoly Act

At the meeting of the Board of Directors held on September 28, 2009, participants passed a resolution on the Fujikura Antimonopoly 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.

[Measures taken]

  • The Board of Directors resolved never to take part in cartels in the future. (Mar. 2009)
  • Established the Fujikura Antimonopoly Act Compliance Program (Sept. 2009)
  • Prohibited related departments from conducting any activities that might violate the law (Dec. 2009)
  • Launched e-learning education, which is provided at least once a year (Feb. 2010)
  • Established a whistleblower system
  • Regularly provide education and training on antimonopoly- and competition-related laws and regulations

Our initiatives

The Group regularly conducts audits at the Audit Division in order to confirm the internal compliance system and compliance status of the Fujikura Anti-Monopoly Compliance Program.

Antitrust law prohibits unreasonable transaction restrictions (cartels etc.). A dishonest practice refers to sharing price and information on shares with competitors which would usually not be done in standard practice. Therefore, whether or not there is an agreement with this competitor is the most important point whether or not it violates the antitrust law. For this reason, the Company has established the "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, the Company conducts e-learning on the Antimonopoly Act for those targeted employees in the company group. Such e-learning education will be continued in the future.

■Major Initiatives for the 2015 Fiscal Year

  • We conducted e-learning training (learning and testing) on subcontract laws and antitrust laws for all our employees. A total of 4,967 students participated for a total attendance of 5,993 hours.
  • We conducted education and training on antitrust law and competition law for different job classes

■Main Initiatives of Group Companies

  • We read the Code of Conduct policies at regular meetings, so everyone it is aware.
  • We created a leaflet on the Code of Conduct policy and distributed it to everyone.
  • We conducted a periodic audit.

■Presence or Absence of Violations in FY2015

As a result of promoting efforts in FY2015, we could not confirm any applicable violation.

Export control

Basic Policy of the Fujikura Group for Export Control

Basic Policy of the Fujikura Group for Export Control

  • We make it the basic policy of the Fujikura Group companies not to participate in transactions with a possibility of undermining maintenance of international peace and safety.
  • We comply with the laws relating to the export control which are applicable in the country or area where the group companies each does business activities.
  • In order to comply with the above-mentioned basic policy and laws, the group companies each will establish its system and rule for export control.

Our iinitiatives

On the international front, security problems such as nuclear and missile issues in Iran and North Korea, and the terrorist activity in the Middle East, Africa, etc. are emerging as serious international concerns. Japan is a major exporter of high-tech products and technologies on a par with the United States. When Japanese companies export their products for consumer use overseas, they need to ensure that none of these products will be used to create nuclear, chemical or biological weapons, missiles to transport these weapons, or other weapons of mass destruction, in order to preserve international peace and safety.
The Foreign Exchange and Foreign Trade Act of Japan regulates the export of not only weapons but also consumer products and technologies that could be used for military purposes, with a view to maintaining international peace and security. The Act also requires exporters to meet the export criteria set by the Japanese government.
In order to maintain peace, order and security of the international community in the progress of globalization, companies are thus strongly required to strictly control the export and provision of their products and technologies that could be used for military purposes.

Fujikura has set the in-house export control rules, based on which it makes necessary judgment on products to be exported and technologies to be provided*, checks its dealings with customers, notifies employees of any revisions to the related laws and regulations, provides them with training on export control, and also carries out internal audits for export control. Under this system, we promote voluntary export control and ensure legal compliance.
For export control, we make necessary judgments about our products and confirm their intended usage with the users. We also pay due attention to the shipment of equipment to the plants of overseas Group companies to ensure that no export-regulated items are included in the shipment. We obtain export permits for the equipment as necessary.
Security Export Administrative Division conducted workshops and e-learning training for employees. We also dispatched personnel to Group companies in Japan and abroad to raise their employees' awareness of export control and give relevant instructions, thereby promoting compliance awareness across the Group.

*Specifically, judgments are made on whether the goods to be exported and technologies (including programs) to be provided are subject to export regulation or not.

■Major Activity in FY2015

  • 2170 people attended e-learning (1085 hours in total)
  • 336 people attended an export control seminar (336 hours in total)

■Presence or Absence of Violations in FY2015

As a result of promoting efforts in the 2015 FY, we could not confirm any applicable violation.

Anti-Corruption

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. The Fujikura Group disseminates information on this policy in the group.

The Fujikura Group Anti-Corruption Policy

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.

This policy include 1~6.

Promotion System

Our Activities

The Audit Department regularly conducts audits to confirm compliance frameworks and compliance status for our company policy. In addition, our Group conducts study sessions and e-learning related to the Anti-Corruption Law targeted to those concerned within the company.

■Major Initiatives for the 2015 Fiscal Year

In the 2015 fiscal year, we implemented educational training and e-learning based on anti-corruption policy. A total of 336 employees attended education and training on our "corruption prevention", for a total attendance of 336 hours. Also, 3,331 students attend e-learning, for a total attendance of 1,666 hours.

In addition, the total number of employees who attended e-learning, the total attendance time, and the amount of educational investment related to compliance training centered on "corruption prevention" in the Fujikura Group as a whole, are as follows.

No. of participants (people) 20,238
Training hours (hour) 38,877
Educational Cost (thousand yen) 155,507

■Presence or Absence of Violations in FY2015

As a result of promoting efforts in FY2015, we could not confirm any applicable violation.

Measures for the United Nations Global Compact

Following a decision made by its CSR Committee (Management Committee) in July 2013, Fujikura Ltd. announced its support for the United Nations Global Compact (UNGC), which outlines the universal and international principles on human rights, labor, the environment and anti-corruption. Subsequently, on September 3, 2013, the company became a signatory to the Global Compact and also joined the Global Compact Network Japan (GC-NJ). The UNGC, which is based on 10 principles, provides a global framework for companies and other organizations to act as good corporate citizens for the creation of a sustainable society by displaying leadership in a responsible manner. Under this framework, Fujikura carried out associated activities in FY2015.

Awareness-raising activities conducted by the Fujikura Group

(1) Activity by the CSR Committee

The CSR Committee is also working to raise employees' awareness of the United Nations Global Compact.

[Examples]

  • Educational seminars for new employees
  • Briefings on the initiative for employees of Fujikura and other Group companies
  • Biannual awareness-raising campaigns (in September)
  • Biannual dispatch of information to employees through the intranet
  • Participation in the Public Forum of the Third UN World Conference on Disaster Risk Reduction held in Sendai City from March 14 to 18, 2015, which fostered cooperation with the United Nations toward the establishment of an international framework beyond national and regional boundaries.

(2) Activity by the procurement department

In the partners' meetings held by the procurement department with suppliers, participants were briefed on the UNGC and Fujikura's support to the initiative.