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The Fujitsu Group is ensuring strict compliance based on the Code of Conduct in the Fujitsu Way. Top management is committed to engaging the Fujitsu Group in various activities to ensure extensive awareness of the need for compliance.
As a set of standards for Fujitsu Group global compliance, GBS (Global Business Standards), which incorporates the detailed Code of Conduct in the Fujitsu Way and a guide for individual employee behavior, has been uniformly put into practice throughout the Fujitsu Group since January 2013.
In Japan, we have put in place a range of internal company rules that include the rules applied to Fujitsu Group company as its own rules deemed necessary for developing a governance structure throughout the Group. We also disseminate information about major legislation, especially legislation that is closely connected to our business such as the Antimonopoly Act, the Unfair Competition Prevention Act, the Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors, to Fujitsu and Group company employees through easy-to-follow compliance manuals posted on the intranet. Besides compliance manuals for Japanese laws, we have also prepared and disseminated a compliance manual for the U.S. Export Administration Regulations (EAR), which is closely connected to our global business development activities.
Overseas Fujitsu Group companies have set out the GBS and ensure that all employees are aware of it via email or internet.
The Fujitsu Group provides a variety of compliance training to all employees to ensure legal compliance. In FY2013, we started to provide the "Global Compliance for Fujitsu Group" e Learning training course to all employees in Japan for the purpose of reassessing the GBS and deepening the understanding of our employees regarding cartels and bribery prevention. Additionally, we implemented a face-to-face compliance training course "Anti-trust and Anti-bribery" for high-risk Group companies. At overseas Group companies, we also implemented e-Learning compliance training courses and face-to-face compliance training courses covering areas such as the GBS, anti-trust, anti-bribery and anti-corruption, export controls, and conflicts of interest.
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 about bidding-related law sand 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 FY2014 we will be further enhancing our face-to-face training focused on areas such as cartels and bribery prevention for high-risk departments in Japan and overseas.
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. For non-Japanese speakers, we have prepared wallet-size cards in three other languages.
Since September 2004, we have been operating an internal helpline system to handle reports and provide consultations for all Fujitsu Group employees (including seconded, contracted, part-time or other short-term employees as well as temporary staff) in Japan. In February 2014, we changed its name to the Compliance Line/Fujitsu Alert in order to further strengthen our commitment to internal reports and consultations. This system is intended to be used by employees who are uncertain about what is the right decision or suspect a violation of the Code of Conduct in the Fujitsu Way, and prepares to receive a wide range of reports and consultations, from harassment to legal violations which may occur in any country. Each of the Group companies in Japan and overseas has also established and operates its own internal reporting system.
In August 2009, we opened a Compliance Line for Suppliers to handle reports and inquiries from the employees of companies that directly supply Fujitsu with their products, services or software, etc. Since September 2014, this helpline is also fielding calls from suppliers to Fujitsu Group companies.
Our Compliance Line/Fujitsu Alert and Compliance Line for Suppliers 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.
From the perspective of maintaining global peace and security, exported or transported goods and technology that could be reappropriated toward the development or production of weapons of mass destruction, conventional weapons, etc. are managed according to an international framework for secure export controls. Japan is also implementing a system for secure export controls within this international framework.
Following the stipulation to "comply with all laws and regulations" in the Fujitsu Way Code of Conduct, we have formulated and are working to thoroughly implement our Security Export Controls policy in line with Japan's Foreign Exchange and Foreign Trade Act, and the U.S.'s Export Administration Regulations (EAR). The control system established a Security Export Control Office in our Legal, Compliance and Intellectual Property Unit. This Office acts as an organization to carry out classification and inspection of all export goods and technology by verifying consignee countries/regions, end uses, and clients. Exports are carried out only after acquiring the requisite export permission. Additionally, in order to maintain and perpetuate a system inside the Group for secure export controls, we conduct regular audits and training.
Along with Group companies inside and outside Japan in formulating rules and establishing frameworks for secure export controls, Fujitsu is offering training support, audit support, and information exchange meetings between Group companies. In FY 2013, the Security Export Control Office visited five Group companies in East and Southeast Asia to carry out secure export control training. Targeting Group companies across the globe, the Office also developed basic e-Learning training courses covering secure export controls in 20 languages.
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