CSRCompliance

The Code of Conduct of the Fujitsu General Way, which sets forth the specifics to be taken into account as the basis for compliance at the Fujitsu General Group, is posted on the company intranet and also disseminated through training programs for executives and employees.

The Fujitsu General Group Code of Conduct

• We respect human rights.

  We respect each individual’s human rights and will not discriminate on the basis of race, color, religion, creed, sex, age, social status, family origin, physical or mental disability or sexual orientation, nor will we commit other violations of human rights. Such discrimination will not be tolerated.

  We will make every endeavor to be fully aware of human rights issues and foster respect and equality for all.

• We comply with all laws and regulations.

  We respect and comply with all applicable laws, treaties, government regulations and statutes, customs and social norms considered to be fair. Violating laws or regulations.

  We also conform to socially accepted business practices, use common sense in our dealings, and are careful to check whether our commercial terms are in line with local requirements. Customs vary from country to country.

  Therefore, in addition to understanding the laws and customs of our home territory, we also will become familiar with and respect the laws, customs and ethnicities of other territories in which we do business.

• We act with fairness in our business dealings.

  We treat customers, business partners and competitors fairly and with respect.

  We do not engage in practices which treat customers differently without justification.

  We do not use our position to secure an unfair advantage in dealings with business partners.

  We do not take advantage of competitors through unethical behavior or illegal means.

• We protect and respect intellectual property.

  We are contributing to the establishment of a networked society by continuously creating new value and providing products and services on a global basis to meet customer needs.

  We recognize that the knowledge and know-how held by each employee give us a competitive edge in our business activities.

  We respect third-party intellectual property and utilize it only after having properly secured rights to its use.

• We maintain confidentiality.

  We must have a proper understanding of the rules for handling different types of information and thoroughly comply with those rules.

  In addition, we are conscious of the vital importance of data security in our daily work so as not to unintentionally leak confidential information or personal data.

• We do not use our position in our organization for personal gain.

  We do not use our position, role, or corporate information, or act in any way contrary to our corporate obligations, to seek or gain benefits for ourselves, our relatives, our friends or other third parties.

  We do not trade stocks or other securities using undisclosed "insider" information gathered from our organization or third parties.

Compliance training for employees

As part of our employee awareness-raising activities, we conduct risk management training for managers. We also conduct training as necessary on important laws and regulations relevant to each division's operations, such as the Anti-Monopoly Act, Security Export Control, and the Subcontract Act. In FY2022, we conducted training on eight occasions on topics such as information leak prevention. We also regularly send out e-mail newsletters to employees to raise awareness of compliance in general.

Four e-learning training sessions have been conducted for CSR Training (excluding compliance).

Anti-Bribery Policy

All members of the Fujitsu General Group follow the FUJITSU GENERAL Way of Code of Conduct principles of "We act with fairness in our business dealings" and "We do not use our position in our organization for personal gain." In further support of this, we have established the Anti-Bribery, Gift and Entertainment Guidelines to prevent bribery and maintain fair and equitable relationships with our business partners. Specifically, the provision of gifts or entertainment to public officers for the purpose of obtaining business favors is prohibited. In addition to prohibiting the giving of gifts or entertainment to persons other than public officers and other parties with the intention of inducing them to perform improper duties, it is also prohibited in principle to receive gifts or entertainment.

All officers and employees of the Company and its domestic affiliates are informed of the Policy through training each fiscal year and act in accordance with the said guidelines.

Furthermore, each of our overseas bases complies with anti-bribery regulations established based on the content of these guidelines and local laws and customs, and we conduct training to spread awareness and ensure compliance each fiscal year.

Policy on political contributions and donations

When making political contributions or donations to various organizations and other entities, we will follow the laws and regulations established by each country. In addition, we will do so only after obtaining approval in accordance with internal rules and regulations.

Preventing insider trading

Based on the FUJITSU GENERAL Way's Code of Conduct principles of "We comply with all laws and regulations" and "We maintain confidentiality," the Fujitsu General Group has established the Regulations for the Prevention of Insider Trading to ensure the prevention of insider trading to fulfill its corporate social responsibility. As an example, employees are required to make prior notification when buying, selling, or otherwise trading the Company’s specified securities. In addition, we provide internal training to our employees covering the subject of insider trading to ensure compliance with laws and regulations, and acquaint them with our internal rules regarding the proper handling of insider and confidential information.