Ethics and Compliance

Our 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. In the midst of an unending stream of corporate scandals, Fuji Xerox and its affiliates continue to work to maintain a strong corporate ethic and compliance framework and ensure fair operations.
In 2004, we stipulated action guidelines for ethics and compliance for Fuji Xerox and its domestic affiliates. Supported by the top management's strong resolve, we have been working on enhancing this framework and related measures to ensure these guidelines are firmly reflected in the actions of each and every one of our officers and employees.

Ethics and Compliance Promotion Structure

Established under the CSR Committee, the Ethics and Compliance Committee is chaired by the corporate vice president of legal affairs. Members comprise corporate officers responsible for research, technological development, product development, manufacturing, and sales and marketing; general managers in charge of human resources, general affairs, internal audit and analysis, and corporate social responsibility; the vice president of two domestic affiliates; and corporate lawyers. The legal department acts as the secretariat for this committee, and meetings are held periodically. Members of the Ethics and Compliance Committee deliberate the planning and introduction of important measures pertaining to corporate ethics and compliance and follow up on them; however, for particularly important issues, official decisions are made by the higher-level Committee.
Employees in charge of promoting ethics and compliance are appointed in all affiliates including those overseas, and we are endeavoring to build a global ethics and compliance management system. Moreover, our overseas operating companies compile checklists for compliance with the law and regulations in their respective countries and review them on a semiannual basis.
In fiscal 2010 at our overseas production operations, we conducted a survey using a self-evaluation checklist and carried out an internal audit through internal audit and analysis department.

Ethics Management

Fuji Xerox places great importance on ethics management. We implemented a groupwide code of conduct in 1997 that sets out the core conduct expectations and priorities for all employees. The code of conduct was revised in fiscal 2007 to better align with the UN Global Compact, which Fuji Xerox signed in fiscal 2002. This code of conduct was also translated and distribured to all overseas and sales companies.
In fiscal 2008, Fuji Xerox introduced All-FX Compliance Helpline for compliance complaints and consultations. The helpline consolidates the functions of the Sexual Harassment Prevention Hotline and the Corporate Ethics Hotline, established respectively in fiscal 1997 and fiscal 2003. All employees of Fuji Xerox or affiliates in Japan can report to or consult with the helpline on legal or business ethics problems. The helpline handled 77 cases in fiscal 2010, for which appropriate measures were taken.
Through fiscal 2009 and 2010, Fuji Xerox and affiliates in Japan took part in e-learning program called All-FX Risk Management Education. This program aims to increase understanding of the Fuji Xerox Code of Conduct and strengthen awareness of ethics and compliance. Participants were able to reaffirm their basic understanding of what harassment is and the need to eliminate it. We will sustain these education and awareness-raising activities in a close coordination with persons in charge of ethics and compliance promotion at Fuji Xerox and its affiliates.

Compliance Education

We have held Fuji Xerox companywide Compliance Training at Fuji Xerox and its domestic affiliates since 2008 with the aim of imparting knowledge on basic laws. Training materials were formulated jointly with FUJIFILM Holdings Corporation and FUJIFILM Corporation and are implemented in the form of a Legal Risk Assessment Test.
In addition to this compliance education, we also carried out fraud prevention training in fiscal 2010 with the aim of preventing misconduct; the program included providing examples of misconduct and introducing checkpoints for preventing fraud.We also continued semimonthly postings of ‘Easy Legal News’, a newsletter in which legal aspects of current affairs are explained on the company intranet. These efforts proved successful, as the fiscal 2010 test given to 95% of employees showed increased understanding of basic legal knowledge, with less variation in the percentage of correct answers for each section tested.
We are also striving to improve our theme-based compliance guidelines^*1 summarizing compliance rules for legal fields regarded as being of high risk.
In fiscal 2011, we plan to further establish compliance and basic knowledge among employees by introducing some new elements to our compliance education and ‘Easy Legal News’ such as a participatory function for readers to analyse problems.

• *1 The guideline themes include sales to government and municipal offices, subcontracted transactions, environmental regulations, dispatched workers law, corporate law, exports and imports control law, and competition law.

Human Rights Initiatives

The Fujifilm Group established its Charter for Good Corporate Behavior in April 2007, which describes the fundametal spirit behind the group's human rights initiatives. This charter calls for “respect for all human rights.”
Fuji Xerox incorporates sessions on human rights, sexual harassment, power harassment, and mental health as part of its annual training programs for new employees and new managers, as well as for the companywide All-FX Code of Conduct training.
Other efforts to increase awareness of human rights among its employees include asking for submissions for human rights catch-phrases and sending all executive general managers a human rights bulletin twice a year.
To prevent human rights violations in our supply chain, we work with and evaluate suppliers as part of an ethical procurement. (For more information, see Purchasing Ethics.)
Finally, we were not involved in any lawsuits or other serious human rights disputes in fiscal 2010.
In fiscal 2011, we will continue our efforts to prevent human rights violations and raise human rights awareness among employees.