June 1, 2020
The directors, officers and employees of Fujikura Ltd. and its global subsidiary companies (hereinafter “Fujikura Group,” and when referring to the directors, officers and employees of Fujikura Group, “Fujikura Group Members”) comply with applicable laws and regulations related to the prevention of bribery in all countries and areas where Fujikura Group conducts business activities (hereinafter “Anti-Corruption Laws”; the term Anti-Corruption Laws includes, but is not limited to, each country/area’s Criminal Law, Unfair Competition Prevention Act, FCPA, Bribery Act 2010, and the like; furthermore, in addition to the relevant country/area’s laws and regulations, the term Anti-Corruption Laws also includes the situation where another country/area’s laws and regulations, are applied extraterritorially or on some other basis). In addition, Fujikura Group Members comply with the Fujikura Group Anti-Corruption Policy (hereinafter “this Policy”).
1. Prohibition of Corrupt Practices
2. Business Entertainment and Gifts
Fujikura Group Members must not conduct the following acts unless (i) such acts not only do not constitute a violation of the related laws and regulations but contribute to legitimate business purposes, (ii) the amount and frequency of the relevant business entertainment or gifts are reasonable in light of societal norms, and (iii) such acts are approved under the prescribed approval process.
(A) Providing any business entertainment or gifts to any related parties, including public officials and clients, etc.
(B) Receiving any business entertainment or gifts from any related parties, including public officials and clients, etc.
3. Accurate Records
Fujikura Group Members shall comply with generally accepted accounting principles in all cases. Accounting books and records shall be recorded accurately, and they shall not, for any reason, be false or cause misunderstanding. Accounting books and records that do not have both necessary and sufficient entries or that do not reflect exact deals shall not be created.
Any person(s) at Fujikura Group who has knowledge of violations of this Policy and managers who have received reports from those who have such knowledge, have an obligation to report the same. The reports shall be made to his/her immediate superior and/or to the Legal Section of Fujikura Ltd. Reports may also be made anonymously through the whistle-blowing system. Those who have made the reports shall not be treated unfavorably by the Fujikura Group for making such reports.
5. Role of managers
This Policy requires all managers at Fujikura Group to play specially important roles. They shall recognize their roles and supervise and manage his/her organization and its members accordingly.
Fujikura Group Members that are confirmed to have violated Anti-Corruption Laws and/or this Policy may be given unfavorable treatment such as disciplinary action by Fujikura Group. When Fujikura Group is aggrieved by a Fujikura Group Members’ violation of Anti-Corruption Laws and/or this Policy, Fujikura Group can make a claim for damages against the violating member.
Based on the Policy above, Fujikura Group has established the following guidelines for business entertainment, gifts, etc. in relation to public officials, etc., customers, suppliers and Representatives and all other related parties involved in the Group’s business activities, including:
1. Guidelines for giving business entertainment, gifts, etc.
The Group may give business entertainment, gifts, etc. only if they contribute to legitimate business purposes and the amount, frequency and content thereof are reasonable in light of societal norms so that the Group can secure the fairness and soundness of its business operations.
2. Guidelines for receiving business entertainment, gifts, etc.
The Group ensures that its directors, officers and employees will apply strict self-discipline in receiving business entertainment, gifts, etc. In principle, receiving any business entertainment, gift, etc. that are not only in violation of law, but also objectively considered attributable to wrongful intent (in terms of such matters as amount, frequency, timing, recipient, content and purpose thereof) or any customary gifts or the like is prohibited.
Specifically, it is prohibited to receive an offer of the following business entertainment, gifts, etc.:
(i) Business entertainment such as drinking, dining and golf outing beyond the societal norms;
(ii) Cash, gift vouchers and the like;
(iii) Year-end gifts, mid-year gifts or other gifts (including those brought by a visitor); and
(iv) Entertainment, gifts, etc. that is personally given.