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.
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 convened meetings on three occasions in fiscal 2017. 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
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]
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".
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.
- 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 2018, we conducted e-learning on Japan’s Antimonopoly Act for eligible persons at the Fujikura Group comprising learning and comprehension test. Participants numbered 3,357 and spent 5,035 hours during the training. In addition, we covered the Antimonopoly Act and competition law during rank-based training as well.
Violations in FY2018
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. This policy also regulates compliance in the supply chain.
The Fujikura Group Anti-Corruption Policy (Established in April 2014)
The directors, officers and employees of Fujikura Ltd. and its global subsidiary companies comply with applicable laws and regulations related to the prevention of bribery in all countries and areas where Fujikura Group conducts business activities . In addition, Fujikura Group Members comply with the Fujikura Group Anti-Corruption Policy.
This Policy 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.
In addition, this policy is defined as "1．Prohibition of Corrupt Practices", "2．Accurate Records", "3．Reporting", "4．Role of managers", "5．Monitoring" and "6．Penalties and Philosophy of Fujikura Ltd".
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. In fiscal 2018, this training reached a total of 4,302 participants who spent 6,453 hours taking part.
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.
With of globalization of business, the destabilization of international affairs from regional conflicts, and the increasing complexity of free trade agreements, the importance of trade control (export management) is rising. 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
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.
Awareness Activities Internally
|1. Internal training||Export control operations require that all employees have a commanding knowledge of export control processes. At Fujikura, we focus efforts on e-learning. In fiscal 2018, we held mandatory courses for all employees at the headquarters, with voluntary courses for mid-career employees and employees of group companies, and a transaction review (introductory edition) in March as part of class-based education. In addition, the company held four open lectures by all members of the Export Control Office within the company.
As a result, the total number of employees taking part in e-learning in fiscal 2018 reached 2,582, while the total number of employees participating in individual training (including presentations open to all) amounted to 418.
|2. Internal audits||Document audits and field audits are carried out on all departments at the headquarters, with individual instructions given to address issues and encourage improvement.|
|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. Guidance and training for Group companies||Every year, we visit 21 Group companies inside or outside of Japan to foster closer relations as well as provide instruction and training with regard to export control. In fiscal 2018, we visited 4 Group companies in Japan. As for overseas Group companies, in fiscal 2018 we visited sales companies in United States, Europe, Southeast Asia and China, where we conducted hearings on important issues, conducted onsite audits and offered training, providing guidance and training on export controls.|
|5. Professional certification for export control employees||Fujikura’s export control employees aim for professional certification in their work. Employees with CISTEC certification as security trade control workers or employees with national certification in customs clearance by the Ministry of Finance respond to many inquiries from throughout the company.|
Serious Legal Violations in FY2018 (boundary: Fujikura Group)
As a result of efforts in fiscal 2018, there were no cases of serious legal violations.