Ethics Policy

Fujitsu UK & Ireland Ethics Policy

Policy statement

It is Fujitsu UK & Ireland’s policy to conduct its business fairly with regard to employees, customers, suppliers and the communities within which it operates. This means complying with local laws and regulations in each country where we operate, as well as following our own Global ethics policy. Some aspects of this are covered below. Fujitsu is committed to conducting business openly, honestly and in accordance with the highest moral and ethical standards.  If you have any concerns regarding the conduct of a Fujitsu employee in this respect, please contact Fujitsu’s Chief Compliance Officer via email to askfujitsu@uk.fujitsu.com marking it for the attention of The Chief Compliance Officer.

Political parties

Fujitsu UK & Ireland does not give any money or other material donation to any political party, political candidate or other holders of political office without prior written authorisation from senior management.
In Financial Year 2011/12, we did not make any political donations.

Corporate lobbying

As a leading company in the UK, Fujitsu UK & Ireland does comment on current and planned legislation – that might affect its own business (for example the plans by the Government on smart metering) or its role as a leading employer (for example the extensive work by the Government on social mobility and apprentices).

Like many similar companies, Fujitsu UK & Ireland works closely with Public Relations and Public Affairs agencies.  When it does, it insists that they comply with the respective codes of practice – for example from the Association of Professional Political Consultants (APPC) and the Public Relations Consultants Association (PRCA).  The APPC governs the way in which Public Affairs agencies do business and which has at its heart the principle of transparency.  Fujitsu UK & Ireland is included on their register, which is updated quarterly, and is publicly available through the APPC’s website.

Taxation

‘Fujitsu’s activities in the UK generate considerable tax revenue for the Exchequer. In 2011/12 Fujitsu directly contributed a total of £397m, more than 21% of revenue. Of this, £68m were receipts it paid itself through corporation taxes, business rates, employers NI contributions, etc. It also collected a total of £329m in taxes on behalf of HM Treasury through VAT payments and employment taxes. The company’s corporation tax payments in recent years continue to be impacted by the significant cash contributions that it has continued to make to reduce the funding deficits in a number of its defined-benefit pension plans.

The total contribution to the Exchequer over the past three years is in excess of £1.1bn.

Fujitsu’s UK business does not engage in the aggressive tax planning or offshore tax structures which have been the recent focus of attention in the media and by the Public Accounts Committee. HMRC has recently renewed Fujitsu’s ‘low-risk’ tax status in the UK.’

Dealing with Governments

When doing business with national governments and government-owned enterprises, Fujitsu will:

• Be truthful and accurate at all times, and ensure that all documents are current, accurate and complete
• Comply with any special legal requirements associated with government transactions
• Ensure that contracts are clear and unambiguous, and that changes are not made without appropriate government authorisation
• Avoid incorrect or unauthorised charges

Bribery

Fujitsu competes based on the quality and price of its IT services, products and solutions. No Fujitsu employees (or anyone operating on behalf of the company such as consultants or partners) may accept or give any form of bribe. Examples include:

• Giving or promising money to government officials or employees of customers
• Paying to obtain preferential treatment
• Payment of commission disproportionate to the service provided

Conflict of Interest

Fujitsu UK & Ireland employees must avoid all situations in which personal or financial interests with those of the company. There are internal processes which cover the reporting of such conflicts. In addition, strict policies prohibit employees from gaining any benefit from their position as employees, including receiving gifts or passing on benefits to friends or family.

Insider Trading

As well as an obligation to comply with laws prohibiting insider trading in securities, Fujitsu employees have an obligation to ensure that such trading does not involve any sharp practices or lack of fair dealing.

Financial and asset protection

All payments made by Fujitsu follow strict accounting procedures.  All Employees must ensure that all payments to third parties are “transparent” and duly authorised in accordance with the established authorisation and accounting procedures, and that no tax planning arrangements are entered into that rely for their success on non-disclosure or mis-disclosure of the facts to tax authorities. Employees are also expected to manage company assets responsibly.

Confidentiality

Fujitsu will comply with all laws and regulations relating to the handling of personal information, and with its own strict policies on data protection. These include:

• Protecting confidential information with non-disclosure agreements
• Maintaining confidentiality agreements with employees after their employment at Fujitsu has ended
• Ensuring that information from customers and partners is handled with the same care, and in accordance with any relevant contracts or terms and conditions.

In addition, all Fujitsu UK & Ireland employees receive training in protecting sensitive information.  Work-related information is protected using secure encryption software.

For more information about any aspect of Fujitsu’s ethical or privacy policies, please contact:
HRDirect
Fujitsu
Lovelace Road
Bracknell
Berkshire
RG12 8SN
An anonymous hotline is also available for reporting concerns: +44 (0)808 234 5279

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