Compliance

The Fujitsu Group aims to be a trusted corporate group, one chosen by stakeholders for investments, deals, and employment, with each executive and employee carrying out their business duties with a high awareness of compliance, as we fulfill our role as a model company. To achieve this, Fujitsu has established and globally implemented the Global Compliance Program to promote understanding and implementation of the Fujitsu Way Code of Conduct and its explanatory guide, the Global Business Standards (GBS). Through these efforts, we are fostering a high level of compliance awareness and, with senior management leading from the front, cultivating a corporate culture in which no employee tolerates wrongdoing. We also extend these initiatives to all parties involved in Fujitsu’s business and seek their understanding and support.
To promote these initiatives, we have established a compliance division under the General Counsel and are carrying out various measures in cooperation with compliance offices in each region.
The results of these activities are reported to the Risk Management & Compliance Committee, which was established based on the “Policy on the Internal Control System” (*1). We also work in cooperation with the Board of Directors and Audit & Supervisory Board Members. In addition, each region collaborates with its Regional Risk Management & Compliance Committee, established as a subcommittee of the Risk Management & Compliance Committee, to promote awareness of and compliance with the Fujitsu Way Code of Conduct throughout the Group.

The operational status of the Global Compliance Program is regularly reported to the Risk Management & Compliance Committee, the Regional Risk Management & Compliance Committee, and the Board of Directors. The development and operation of internal rules, education, and monitoring systems to comply with various laws and regulations related to Fujitsu Group’s business are promoted under the practice and supervision of management.

Our employee evaluation criteria include assessing the level of an employee’s embodiment of “Our Values” under the Fujitsu Way. One of the values is for employees to act with ethics, transparency and integrity. As such, employee personnel assessment and compensation reflect their level of compliance with the Code of Conduct.

Fujitsu has developed the Fujitsu Global Compliance Program to disseminate the Fujitsu Way Code of Conduct and the GBS, and is working to maintain and improve the Fujitsu Group’s global legal compliance structure. The Global Compliance Program organizes our various compliance-related activities into five pillars in a systematic manner. The Global Compliance Program promotes external understanding of Fujitsu’s compliance structure and its compliance activities, in addition to clarifying what items Fujitsu needs to address on a continual basis. Based on this Global Compliance Program, we implement various policies and initiatives in each region, taking into account factors such as each country/region’s legal systems and government institutions guidelines.
When implementing the Global Compliance Program, we establish internal Group rules and assign a compliance officer in each region to be responsible for compliance activities and ensure the structure’s implementation. We also continuously provide employees with various forms of training, with the goal of embedding the Fujitsu Way Code of Conduct and the GBS. In addition, we have established an internal whistleblower system in the event of compliance issues, and employees are required to immediately report compliance violations to the Risk Management & Compliance Division if they are discovered. We periodically verify the effectiveness of the Global Compliance Program through measures such as risk assessment, audit, and reviews by external specialists, and continuously work towards improving the Global Compliance Program.

Fujitsu Alert is publicized to employees via periodic messages, compliance training sessions and the website. In addition, Fujitsu periodically confirms trends in the usage of Fujitsu Alert in order to ensure increased recognition for and confidence in the system among employees.

In the “Policy on the Internal Control System,” which was resolved by the Board of Directors, Fujitsu stipulates the following points.

We comply with the principle of arm's length pricing and distribute profits appropriately when conducting transactions between affiliated companies. We do not transfer business profits generated in countries/regions to countries/regions with low tax rates where we do not conduct business transactions.

We do not engage in tax planning that is solely for the purpose of avoiding taxes without business purpose or business substance. Similarly, we will not use tax havens to transfer profits with the intention of avoiding taxes.