Compliance
Fujikura Group Code of Conduct
The Fujikura Group promotes initiatives for establishing sound corporate ethics across the entire Group based on the Fujikura Group Code of Conduct established in October 2002.
Fujikura Group's Basic Code of Conduct Principles
No matter how great the results a business produces, if the actions of the business as a whole or of its individual employees are against the law or social rules, not only will there be societal repercussions but examples of the business itself being reviled are too numerous to mention.
To be recognized by all of society and to continue to be good members of that society, we strictly enforce laws and rules and act with responsibility born from social common sense. Carrying this out sincerely helps contribute to society and earns us trust from society. We also believe it is important for the development of our business group and for the insurance of the rich and happy lives of the people that work there, and thus define the "Fujikura Group's Code of Conduct" here.
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.
Management Structure
The Risk Management Committee chaired by the company’s president is responsible for ensuring Fujikura employees and other persons engaged in Fujikura’s operations comply with laws and regulations.The Risk Management Committee convenes meetings as needed in addition to regularly scheduled meetings and convened 26 meetings in fiscal 2019. During the two meetings held in the first half and second half of the year, reports were heard on the training, examples, and other measures for legal compliance planned by corporate divisions in order to identify issues and share information.
Compliance Structure Diagram
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Internal Reporting System
The Fujikura Group operates an internal reporting 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.
[Number of Internal Reporting and Counseling]
| FY2016 | FY2017 | FY2018 | FY2019 |
|---|---|---|---|
| 26 | 20 | 37 | 47 |
Readily Available Portable Leaflets
The Fujikura 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.
The content of the leaflet declares that officers and employees will protect the "antitrust law compliance program" and "anti-corruption policy".
Compliance with the Competition Law
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.
Measures Taken
- The Board of Directors resolved never to take part in cartels in the future. (Mar. 2009)
- Established the Fujikura Anti monopoly Act Compliance Program (Sept. 2009)
- Established banning activities that violate relevant departments (Dec. 2009)
- Launched e-learning education, which is provided at least once a year (Feb. 2010)
- Established a whistle blower system
- Regularly provide education and training on anti monopoly- and competition-related laws and regulations
Implementation of Regular Audits and E-Learning
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 fiscal 2019, we conducted e-learning on Japan’s Antimonopoly Act for eligible persons at the Fujikura Group comprising learning and comprehension test. Participants numbered 3,608 and spent 5,412 hours during the training. In addition, we covered the Antimonopoly Act and competition law during rank-based training as well.
Violations in FY2019
- As a result of promoting efforts in fiscal 2019, no applicable violations were confirmed.
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. 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 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 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.
Education on Anti-corruption
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. Course participants in this training reached a total of 4,639 and they spent a collective 6,959 hours in training.
Prevention of Insider Trading
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.
Education on Preventing Insider Trading
Fujikura began providing a new e-learning course (study and testing) for officers and employees in fiscal 2019 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 2,320 hours of training.
Anti-corruption Initiatives in the Supply Chain
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.
Export Control
Since the advent of the Trump administration in the U.S., the international community has been roiled by the demise of globalism and the rise of nationalism. Moreover, the spread of the COVID-19 pandemic, which began in January 2020, halted the flow of people, goods, and money, and the global isolation is having a major impact on the tourism and airline industries. To make matters worse, the confrontational nature of economic relations between the U.S. and China has reached a crucial point and is impacting the global supply chain. This has increased the importance of understanding the trade control (export control) framework established for security reasons.
Fujikura officially approved a basic policy on export control for the Group at a meeting of its executive committee in 2015. This basic policy clearly states efforts will be made across the entire Group for security export control under the guises of the international community.
Basic Policy of the Fujikura Group for Export Control (Established in October 2015)
- 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.
Export Control Management Structure
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The president is the ultimate authority in charge of export control, and the Export Control Office operates under this ultimate authority. An executive officer is also responsible for the Export Control Office. Responsibility for export control for all in-house companies and corporate divisions falls on the supervising executive. |
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Awareness Activities Internally
| Category | Details |
|---|---|
| 1. Internal training | For export control to function properly, it is important for all employees to be knowledgeable about export controls. Fujikura is concentrating on providing e-learning to all employees. A mandatory e-learning course providing basic knowledge of export controls was established for managerial level employees in overseas Group companies in fiscal 2019. A number of voluntary courses on different topics (basic knowledge, determining applicability, transaction screening) were also established for all company employees. A total of 1,675 people have taken these e-learning courses (See 5. Guidance and training for Group companies). A series of intensive lectures was also provided as an open course for all employees in the fall. A total of 378 people took the course, including individual visits and training. Fujikura will continue to provide export control training in the future. |
| 2. Internal audits | We conduct a combination of written and onsite audits of all head office divisions. Individual guidance is provided on audit findings, and this guidance is linked to improvement activities. |
| 3. Streamlining of export control operations | We aim to streamline operations by systemizing export control with the help of IT, including applicability transaction review, determination of regulated goods* and screening of problem customers. * Determining whether goods for export or technologies for provisions (including programs) are found on lists of regulated items. |
| 4. Expansion of export control staff | In fiscal 2019, the Security Export Administrative Division recruited staff from within the company. The division accepted two new staff members and worked to make them productive. |
| 5. Professional certification for export control employees | During fiscal 2019, visits were made to six domestic Group company locations (including branches) to develop a closer relationship with each company and provide guidance and training on export control. An e-learning course was also launched for managerial level employees in overseas Group companies to give them a deeper understanding of export control. A total of 403 people took the course. |
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Serious Legal Violations in FY2019 (boundary: Fujikura Group)
As a result of efforts in fiscal 2019, there were no cases of serious legal violations.