We are ensuring thorough compliance in line with the Code of Conduct of the Fujitsu Way.
Under our top management's commitment, the Fujitsu Group engages in various activities to ensure widespread awareness of the need for compliance.
In FY 2012, as a set of standards for Fujitsu Group global compliance, we fleshed out the Code of Conduct in the Fujitsu Way then put together the GBS (Global Business Standards), a set of guidelines that even incorporates a guide for individual employee behavior. These guidelines were uniformly put into practice throughout the Group in January 2013.
In Japan, we have put in place a range of internal company rules that include Fujitsu Group rules deemed necessary for building a governance structure throughout the Group. We are also disseminating information to Fujitsu and Group company employees about major legislation closely connected to our business (the Antimonopoly Act, the Unfair Competition Prevention Act, Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors, etc.) through easy-to-follow compliance manuals posted on the intranet. Furthermore, we have established a special internal hotline for consultation on and reporting of matters related to the Antimonopoly Act.
Besides Japanese laws, we have also prepared a compliance manual on the U.S. Export Administration Regulations (EAR), which are closely connected to our global business development activities. Efforts are focused on ensuring familiarity with this manual among employees. Overseas, the GBS has been codified into rules at each Group company. At the same time, we use e-mail and the Internet to ensure that employees understand these rules.
The Fujitsu Group provides a range of compliance training to all employees to ensure legal compliance.
In FY 2012, we began offering the "Carrying Out the Code of Conduct" e-Learning course at Group companies in Japan. This is an expansion of the initiatives conducted for all Fujitsu employees in FY 2011, and focuses on issues like harassment and problems like bribery, which can greatly harm the company. The course provides an opportunity for each employee to review and correct their actions. At overseas Group companies, we also implemented e-Learning courses covering areas such as the GBS and corruption prevention in FY2012.
In addition to compliance training for executives, which is provided by outside lawyers, we also conduct in-house training for heads of sales divisions and branches covering bidding-related laws and the Antimonopoly Act. For new managers, we also regularly hold in-house training where a Fujitsu instructor explains the importance of the Code of Conduct and compliance, while also providing case studies of typical scenarios and situations whose optimal handling may not be clear.
Along with continuing the activities above, in 2013 we will be further enhancing our group training efforts focused on areas such as cartels and bribery for high-risk departments in Japan and abroad.
Furthermore, we have been printing the Code of Conduct of the Fujitsu Way on wallet-size cards and have been distributing them to all Group employees. These cards are designed to serve as a quick reference of the Code of Conduct for employees when they are dealing with customers or business partners, or when they are uncertain about a decision in the course of daily operations. The foreign-language card, which includes three languages, is distributed to non-Japanese employees.
Since September 2004, we have been operating an internal helpline system to handle reports and provide consultations for all Group employees (including seconded, contracted, part-time or other short-term employees as well as temporary staff).
This helpline is intended for use by employees who are uncertain about a decision or suspect a violation in the course of executing daily business operations, based on the Code of Conduct set forth by the Fujitsu Way.
Each of the Group companies in Japan and overseas has also established and operates its own internal reporting system.
In August 2009 the existing helpline system was extended by a compliance line for suppliers to handle reports and inquiries directly from the employees of companies that supply Fujitsu with products, services or software, etc.
With our helpline and compliance line for suppliers, the system forbids any and all sanctions against employees and suppliers for making such reports, and meticulous care is taken in handling the information so as to preserve their anonymity.
If problems are found in investigating these reports, the relevant practice is terminated and measures are taken to prevent recurrence.
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