Ethics and Compliance

Concept of Ethics and Compliance

Complying with the laws and carrying out our business activities in a fair and honest manner is one of the basic values that we hold dear at Fuji Xerox. Amidst an unending stream of corporate scandals, Fuji Xerox and its affiliates have been working on rebuilding its corporate ethics and compliance framework since 2003.
In February 2004, we stipulated action guidelines for ethics and compliance for Fuji Xerox and its domestic affiliates. Backed by the strong determination of the top management, we have been working on enhancing the framework and mechanism so that they are firmly reflected in the actions of each and every one of our officers and employees.

Ethics and Compliance Promotion Structure

The Ethics and Compliance Committee was set up directly under the Risk and Ethics Committee, with the executive vice president in charge of legal affairs as its chairperson. Committee members are comprised of corporate officers for research, technological development, production, sales and customer service; general managers in charge of human resources, general affairs, management audits and CSR; the presidents of three domestic affiliates; and corporate attorneys. Legal acts as the secretariat and the committee meeting is convened once every quarter as a rule. All the planning, implementation and follow-up of important corporate ethics and compliance-related measures are first deliberated at this committee meeting and official decisions are made at higher-level function-based committees as and when needed.

We have also appointed persons in charge of ethics and compliance promotion at all our affiliates both in Japan and overseas as part of our efforts to build a global ethics and compliance management structure. Furthermore, we have prepared checklists based on the local laws at all our overseas sales companies, which we audit once every six months.
In fiscal year 2009, we added anti-trust law-related items in our checklist for overseas companies and we plan to carry out regular audits not only at our overseas sales companies but also at our manufacturing companies abroad.

Ethics Management

We revised the Employee Code of Conduct in FY2007 to respond to the growing societal demand for ethics and compliance from corporations. The revision was also aimed at making full use of the company's participation in the UN Global Compact (respect for human rights, etc.) since 2002. The objective of the Code of Conduct is not limited to ensuring that employees comply with the laws or other established rules. It also stipulates rules necessary to achieve the management principles through the actions of each and every employee. The Code of Conduct has been translated and distributed to all domestic and overseas affiliates and sales companies in the respective local languages.
In May 2008, we started operating ALL-FX Compliance Help Line for employees to report and provide consultations for them on matters regarding corporate ethics and compliance. This combined the functions of the Sexual Harassment Prevention Hotline established in 1997 and the Corporate Ethics Hotline established in 2003. All employees working at Fuji Xerox and its domestic affiliates make use of this help line to report or discuss issues related to laws and corporate ethics. Some 110 inquiries were received in fiscal year 2008 and handled appropriately.

In the employee awareness survey conducted in August 2008 to assess the level of penetration and retention of ethics and compliance, some 19,862 employees of Fuji Xerox and its domestic affiliates responded. The survey results pointed to the high level of awareness regarding ethics and compliance within the company. We intend to continue with regular education and enlightenment activities and information dissemination to maintain and further improve the awareness level.

Compliance Education

In fiscal year 2008, we held an ALL-FX Compliance Training (General Laws) in Fuji Xerox and all its domestic affiliates with the aim of imparting knowledge on basic laws. A total of 20,734 employees took part in the Legal Risk Assessment Test. The training materials were prepared jointly with FUJIFILM Holdings Corporation and FUJIFILM Corporation and will be used for future training to ensure that it takes root among all employees. They will also be used as a base for drawing up the various measures aimed at ensuring legal compliance in the business activities of all companies.
We also take measures every year to enhance the Compliance Guideline^*, which lists the various legal compliance matters, deemed as of high risk, sorted by theme.
In fiscal year 2009, we intend to continue with measures to improve legal awareness to further ensure compliance. Specifically, we will conduct follow-up training sessions targeting departments with strong ties to operations, for items where the percentage of correct answers was low in the general law training held in fiscal year 2008. We will also make available timely legal affairs-related news on the intranet.

• * The guideline themes include sales to government and municipal offices, subcontracted transactions, environmental regulations, outsourcing contracts, Companies Act, exports and imports and anti-trust law.

Human Rights Related Efforts

In April 2007, the Fujifilm Group established the Fujifilm Group Charter for Good Corporate Behavior, the fundamental spirit behind the human rights-related endeavors of the companies in the group. The Charter defines five basic rules for businesses to pursue profits through fair competition and at the same time be of service to the broader society, and respecting all human rights is one of the five rules.
In our new hire training, we every year offer human rights-related sessions. Likewise, training related to sexual and power harassments and mental health is included for new manager training. In addition to soliciting slogans for human rights promotion, we deliver organizational newsletters related to human rights to all the executive general managers twice every year as part of our efforts to promote human rights awareness.
We will continue with our efforts to improve awareness related to human rights through reinforcing the Code of Conduct and related trainings.
Further, we will ensure ethical procurement as part of our efforts to improve the human rights awareness in our supply chain structure.
(Please see Ethics of Purchasing for details)