Compliance

The Fujitsu Group has a compliance division under the General Counsel and carry out measures based on the Global Compliance Program in cooperation with compliance offices in each region. In addition to fostering a corporate culture that each employee does not tolerate any wrongdoing, the Group is also implementing activities to promote a high level of compliance among all stakeholders in Fujitsu’s business, including business partners. The results of these activities are reported to the Risk Management & Compliance Committee, which was established based on “Policy on the Internal Control System” (*1). Activities to raise awareness and ensure of the Fujitsu Way Code of Conduct in Fujitsu Group are implemented in cooperation with the Board of Directors, Audit & Supervisory Board Members, and the Regional Risk Management & Compliance Committees in each region established as a subcommittee to the Risk Compliance Committee.

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 with 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 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.

2. Top-Level Commitment and Securing of Resources

Top management expresses its intentions to strive for compliance proactively and continuously through measures such as sending messages to employees. In doing so, Fujitsu puts the Code of Conduct and the GBS into practice and spread them throughout the entire Fujitsu Group.
The President himself has repeatedly sent out messages to all employees, both in Japan and overseas, declaring that Fujitsu will put an end to compliance violations such as collusion and the formation of cartels. Even overseas, regional heads and Group company top managers continuously send out messages emphasizing the importance of compliance and a corporate culture that has zero tolerance for wrongdoing.
Furthermore, we hold Fujitsu Compliance Week every year to increase awareness of compliance companywide. During the week, compliance messages are simultaneously sent to employees by top management (including the CEO) at Fujitsu headquarters and the Heads of each business region, and Presidents of group companies in each country. We also release annually updated Compliance e-Learning to employees of all Group companies, and provide compliance-related activities planned for each region.
Additionally, we have assigned staff in charge of compliance operations in each region, and have formed a global network composed of staff in charge of risk compliance at each Fujitsu Group company. Based on these steps, we have established a system for operation of our Global Compliance Program. In FY2024, officers responsible for compliance in each region visited Japan for a discussion on a future global compliance policy.

3. Training and Communication

The Fujitsu Group continuously conducts various training and communication opportunities for executives and employees in order to embed and implement the Fujitsu Way Code of Conduct, the Global Business Standards, and other internal rules.
Standard Policy for Compliance, one of the common standards, stipulates that compliance training be conducted for all Fujitsu Group executives and employees, and compliance e-learning is conducted every year. The contents of this e-learning include risk areas such as bribery, collusion, and security export control, along with how to use our whistleblowing system. Moreover, in order to reflect the results of risk assessment and social conditions, the Compliance Division at Fujitsu headquarters and compliance staff from each region conduct an annual review of the e-learning. In FY2024, compliance e-learning was conducted in 14 languages for all Fujitsu Group executives and employees (approximately 120,000 people). As of April 2025, 97% of all executives and employees have already taken the course.
In addition to the measures listed above, we conduct timely online training and e-learning in accordance with the risk level of each organizational level, region, and division. The training and e-learning is based on laws, customs, and actual business conditions in each country. Every year, Fujitsu and domestic Group companies hold compliance training sessions targeted at newly appointed executives. This training is conducted by lawyers from outside Fujitsu, and the company's legal and compliance divisions. For managers, we periodically conduct internal training where in-house instructors explain the importance of the Code of Conduct and compliance, in addition to discussing typical scenarios and difficult situations. Compliance education is also incorporated into new employee training to help them understand the Code of Conduct and the importance of GBS in addition to training focused on specific risks such as sales and legal
We also provide compliance training to partner companies to ensure fair trade. When entering into new business dealings in Japan, we require all project workers to undergo mandatory training to prevent the establishment of inappropriate relationships, based on examples of compliance issues that may arise in transactions, such as violations of the Subcontract Act, fraud, and fictitious transactions. We also provide partner training overseas, providing learning sessions to suppliers in the Asia-Pacific region, mainly on fictitious transactions and bribery, and in Europe, to channel partners, marketing agencies, and sales intermediaries, based on examples of all compliance issues that may arise in transactions, such as bribery, conflicts of interest, competition law, and money laundering.
As mentioned above, Fujitsu has designated an annual Fujitsu Compliance Week, during which the CEO and regional heads send out a message to employees and distribute compliance-related news.
In addition to these top-down activities, we collect ideas and strategies from employees on how to avoid compliance violations through surveys. The valuable insights gathered from these surveys are then published on the company intranet, providing an opportunity for employees to learn from each other. We are taking measures to further improve understanding of compliance among frontline workers in each region and enable compliance departments to listen to the voices of those working on the frontline. This includes setting scenarios of actual compliance issues that could occur and providing opportunities for employees in frontline departments to think about and discuss how to deal with them through role-playing in a variety of positions.

The Fujitsu Group has established an internally and externally accessible portal, Fujitsu Alert, operated by an external vendor, to receive internal whistleblower reports and consultation (including anonymous reports) from all Group employees (including board members, retirees, temporary transfers, contracted employees, part-time employees, dispatch workers, and others) and offer consultations. Group companies also maintain and operate separate internal whistleblower systems.
Through a web form or telephone hotline, Fujitsu Alert accepts reports on suspected wrongdoing or concern from all Fujitsu Group employees and external parties relevant to the Fujitsu Group, including customers and suppliers (anonymously, if applicable). Fujitsu Alert is available in 14 languages 24 hours a day, 365 days a year.
Fujitsu Alert also serves as reporting system for business partners from which the Fujitsu Group (companies in which Fujitsu has direct or indirect investment of more than 50%) directly procures goods, software or services.

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

Employees are encouraged to report breaches or potential breaches of compliance of which they become aware. Furthermore, if employees are unsure of the appropriate action to be taken, they can seek advice from a supervisor in their division or a specialized division such as the legal division.
Anonymous reports can be submitted to Fujitsu Alert, and we handle information under strict confidentiality with the utmost care in order to preserve anonymity. Even in cases where the whistleblower is indirectly identified during investigation process, we strictly prohibit the adverse treatment of whistleblowers due to their reports, and any such adverse treatment will be regarded as an extremely serious breach of internal policies.

When a breach of compliance is reported on Fujitsu Alert, we will conduct an internal investigation under the supervision of responsible managers who are licensed attorneys, and will cooperate with external attorneys when necessary. Fujitsu directly reports the results of its internal investigations to the Board of Directors and the Risk Management & Compliance Committee. These reports are made independent of the division and/or affiliated companies which are involved in the subject matter under investigation. Depending on the content of the report, the Compliance Division may delegate an investigation to other authorized divisions if deemed appropriate.
The Compliance Division will conduct an appropriate internal investigation in order to understand the facts and review possible countermeasures in accordance with applicable laws and professional standards. The internal investigation includes, but is not limited to, consideration of applicable laws, consideration of appropriate investigation steps, evaluation of collected evidence, documentation of investigation results, and reporting or escalation. Depending on the results of the investigation, Fujitsu provides feedback to the whistleblower if necessary based on applicable laws such as the data protection laws and business laws.
In the event that the investigation has verified problems according to the Code of Conduct, Global Business Standards, or other internal rules, we take corrective measures such as disciplinary action and reflect the results in personnel evaluations. In order to prevent similar problems from occurring in the future, we remind all parties of rules, revise systems, strengthen monitoring and supervision, and take other necessary measures.
The process for these investigations, etc., is also reviewed and improved at least once a year, including at the time of establishment of the annual plan under the Global Compliance Program and/or at the time of enactment or amendment of relevant laws.
Fujitsu may be either required by law or decide based on business judgement to provide information about compliance violations to certain government and/or judicial agencies (including, but not limited to, government investigative agencies or courts). When making such decisions, Compliance Division staff work together with managers and other relevant divisions as necessary.
Moreover, letters or emails received via platforms other than Fujitsu Alert are also reviewed for investigation of suspected compliance breach and corrective measures and response are taken as needed.

In FY2024, 155 reports were submitted to Fujitsu Alert. Of these, there were no confirmed cases of corruption (bribery included) or legal disputes. The Fujitsu Group takes measures to comply with the laws and regulations of countries where it operates and prevent corruption based on the GBS 5.2 Prevention of Bribery (*3) and the Standard Policy for Compliance.

When executives or employees become aware that compliance violations have occurred, or recognize signs that violations may occur, they are required by the risk management regulations to immediately file a report with the Risk Management & Compliance Committee and in accordance with the reporting system previously established by the head of the division. In addition, we periodically report to the Risk Management & Compliance Committee, the Board of Directors and Audit & Supervisory Board members concerning internal whistleblower reports and consultations, as well as our responses to major compliance issues. Please refer to the Fujitsu Group Integrated Report for the number of meetings of the Risk Management & Compliance Committee and the Board of Directors.

5. Monitoring and Reassessment

The Fujitsu Group conducts annual verification of the effectiveness of the Global Compliance Program through reviews of our risk assessment and internal auditing activities, and through reviews by external experts such as law firms. We are also working to continuously improve our Global Compliance Program based on the results of applicable reviews and audits, as well relevant social conditions. Please refer to the Risk Management page regarding our risk assessment activities.
The Compliance Division of Fujitsu headquarters continually assesses risk that mainly targets Group companies located in overseas countries and regions with a high risk of corruption. Through interviews with executives/employees and verification of internal rules and business processes, the Compliance Division analyzes the compliance risks of local businesses. It then proposes countermeasures in accordance with the actual contents and extent of risks, and supports the implementation of those countermeasures.
The status of risk assessment and implementation of the Global Compliance Program are periodically reported to the Risk Management & Compliance Committee, the Regional Risk Management & Compliance Committees, and the Board of Directors. The discussions and decisions made at these meetings are reflected and implemented in a timely manner to activities in the Global Compliance Program.

From the viewpoint of maintaining global peace and security, the export of goods and the transfer of technology that could be used for the development or production of weapons of mass destruction or conventional weaponry are controlled by an international framework for security export controls. In Japan, by following its framework, the regulations for security export controls are implemented under the Foreign Exchange and Foreign Trade Act (the Foreign Exchange Act).
In line with one of the Fujitsu Way Code of Conduct, “We comply with all laws and regulations,” Fujitsu has enacted “Security Export Control Regulations” internally and thoroughly enforced it as the fundamental policy to promote security export controls in accordance not only with the Foreign Exchange Act, but with the Export Administration Regulations (EAR) of the United States applied extraterritorially.
As Fujitsu's management system, the President serves as the Security Export Control Chief Officer, while the Security Export Control Office in the Corporate Governance and Compliance Unit serves as the organizer of the security export control operations. On the operational process, it is required that, before export of goods and the transfer of technology to overseas, all classification and transaction screening (scrutinizing destination country/region, end-use/end-user) are surely executed and then all necessary licenses are adequately obtained. “Security Export Control Regulations” also sets the rule that legal violations shall be reported immediately. When execution of business, to prevent legal violations by misinterpretation and/or overlook of related regulations, Fujitsu closely aligns with the Ministry of Economy, Trade and Industry which has jurisdiction over export administration regulations. Due to such internal system for security export controls upheld, the regular audit is conducted, as well as the export controls training is provided to all executives and employees.
For domestic and overseas Group companies, the guidance about rules and frameworks for proper security export controls is offered accordingly, and any related activities like educational support, audit support and domestic seminar for information exchange are given as well. Furthermore, since FY2013, e-Learning course about basic security export controls has been developed, which is available in multiple languages for Fujitsu Group companies worldwide.

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

The organization responsible for internal control and internal audits has established the system and assesses internal control over financial reporting throughout the Fujitsu Group, and reports the activity status and assessment results to the Representative Director and CEO, Chief Financial Officer, Audit & Supervisory Board Members and the Board of Directors in accordance with the principles of the “Practice Standards for Management Assessment and Audit concerning Internal Control Over Financial Reporting” published by the Business Accounting Council.

Tax compliance at the Fujitsu Group is carried out according to the Fujitsu Way Code of Conduct.
We understand the purpose and essence of each country’s tax laws and treaties, as well as other guidelines such as those laid out in the Business Erosion and Profit Shifting (BEPS) Project led by the OECD, and abide by them. We strive to file tax returns and pay taxes appropriately. In transactions between related companies, we will comply with the general rule of an arm’s length price and distribute profits appropriately.

The Director who serves as the Chief Financial Officer is responsible for the proper filing and fulfilment of tax returns and obligations, management of tax risks, and optimization of tax expenses. Important matters and risks related to tax are reported to the management meeting and Board of Directors in a timely and appropriate manner for approval.

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.

We strive to build a sound relationship with the tax authority in each country by conducting our business with ethics, transparency, and integrity in accordance with Our Values under the Fujitsu Way.
Based on the above, we aim to achieve proper tax management, in order to continuously improve corporate value.