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Ethics and Compliance

Everlasting Spirit of Foundation

"Xerox is made up of a group of enthusiastic, revolutionary people. They believe not only in profit or success in business, but also in the responsibility to provide services that have value for the customers. They want to serve society, and that service will become a source of self-respect." These are the words of Joseph C. Wilson, Chief Executive Officer, when the company started business as Xerox.
In the current trend where corporate social responsibilities are more spreading over enterprise, we are required to conduct moderate business activities from perspective of society and stakeholders.
Upon establishment, Fuji Xerox management was full of spirit to build up a company here in Japan like Xerox with passion, stimulated by innovation of Xerox which played a social role with the supreme idea. Since then, Fuji Xerox has created its corporate culture to discuss and pursue candidly what the right action is and what responsibilities of a corporation to society are.
Taking an opportunity as we come to work together with people in the United States, Southeast Asia and Oceania through expansion of our business areas, we established our "Mission Statement" and "Shared Values" in 1998. "Shared Values" naturally include "High Ethical Standards" as its composition"
"High Ethical Standards" are the most fundamental values for Fuji Xerox and its affiliates.

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 started in fiscal 2003 to reinforce the strong corporate ethics and compliance framework and ensure fair operations, and in 2004, we stipulated action guidelines for ethics and compliance for Fuji Xerox and its domestic affiliates. Since then, supported by the top management's strong resolve, we have been working on enhancing this framework and related measures to ensure that this course of action is firmly reflected in the actions of each and every one of our officers and employees.

Ethics and Compliance Action Guidelines

  1. Do not get involved in any action that is questionable from the ethics and compliance perspectives
  2. Admit candidly any violations, deviation from norms or errors and promptly take corrective and preventive actions
  3. Clearly define the roles, responsibilities, authorities, and the information route within the organization
  4. Impart adequate and continuous training to all the officers and employees and carry out fair evaluation on a regular basis
  5. Carry out appropriate self-audits of all the organizations every year based on the company's management policy and guidelines
  6. Allocate adequate staff and budget to ensure that ethics and compliance-related activities are being carried out as a priority management issue

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.
At overseas sales subsidiaries and overseas production subsidiaries, we are performing periodic self-assessments and preparing checklists in accordance with the laws and ordinances in place in each country.
In fiscal 2013, in response to recent movements around the world to strengthen laws aimed at preventing corruption, Fuji Xerox and all of its domestic affiliates have established corruption prevention regulations. In fiscal 2014, overseas affiliates also adopted corruption prevention regulations. Fuji Xerox and all of its affiliates have now completed the implementation of such regulations.

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 distributed 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 or consult on legal or business ethics problems. Furthermore, all employees of Fuji Xerox and its domestic affiliates can contact the Helpline to report suspected cases of legal non-compliance or suspected violations of corporate ethics.
In fiscal 2014, the Helpline responded in a meaningful way to all complaints and requests for consultations.
Since 2009, Fuji Xerox and its affiliates in Japan have provided an e-learning program on the code of conduct, including for the prevention of harassment. This program aims to increase understanding of the Fuji Xerox Code of Conduct and strengthen employees' awareness of issues surrounding ethics and compliance. We will continue to inform employees about the system and purposes of the All Fuji Xerox Compliance Helpline and provide ongoing ethics/compliance education and activities throughout Fuji Xerox and its affiliates, focusing especially on providing easy-to-understand education on the prevention of harassment.

Fuji Xerox Code of Conduct and Fuji Xerox Code of Conduct Guidebook

Structure of the Compliance Help Line

Compliance Education (Legal Department)

Since 2008, we have held Fuji Xerox companywide Compliance Training (general legal training) sessions at Fuji Xerox and domestic affiliates to improve understanding of basic legal matters, formulating training materials jointly with FUJIFILM Holdings Corporation and FUJIFILM Corporation and implementing them in the form of a Legal Risk Assessment Test.
In addition to anti-corruption training (including examples of misconduct and checkpoints to prevent fraud) introduced in fiscal 2010 to safeguard against misconduct, we implemented new misconduct prevention training, adding questions on sexual and power harassment, with the goal of preventing harassment in fiscal 2011. In fiscal 2014, the Legal Risk Assessment Test was taken by 24,073 employees, a figure that accounts for 99% of all applicable employees of Fuji Xerox and its domestic affiliates.
To promote awareness of legal issues, we have continued to issue the semimonthly newsletter, "Easy Legal News," on the company intranet since fiscal 2009. The newsletter picks up topical issues and explains the legal aspects of them using simple language. Since fiscal 2013, we also have issued an English version of Easy Legal News for officers and executives of our overseas subsidiaries.
In addition to these ongoing efforts, we are also striving to improve theme-based compliance guidelinesNote 1 that summarize compliance matters in legal areas deemed to encompass high levels of legal risk.
In addition to general education programs for all employees, we also provide compliance education tailored to specific job categories. Since fiscal 2012, we have provided group education sessions for new managers twice a year (including the presentation of case studies). In fiscal 2014, we completed the creation of web-based educational materials (videos) for all levels of managers (which will be used for education training from fiscal 2015).
In fiscal 2015, we will continue the Legal Risk Assessment Test and regular issuance of Easy Legal News as programs designed to promote employee understanding of the basic policy and rules of the Company. And to further ensure legal compliance, we will strengthen our education on laws and regulations to provide the legal knowledge needed for new businesses and global compliance in order to enhance the awareness and basic understanding of legal affairs among all employees, including employees of overseas affiliates.

Human Rights Initiatives

The Fujifilm Group established its Charter for Good Corporate Behavior, which describes the fundamental spirit behind the group's human rights initiatives, in April 2007. This charter calls for "respect for all human rights."
Fuji Xerox provides educational sessions on human rights-especially the right to live free of harassment-and on mental health as part of its annual training programs tailored to specific job categories, including those for new employees and new managers, as well as in the code of conduct training programs designed for general employees of Fuji Xerox and its affiliates.
Other efforts to increase awareness of human rights among its employees include human rights slogan contests and human rights bulletins distributed to all executive general managers twice a year. In fiscal 2014, group education sessions designed for individual job categories were provided in addition to the e-learning program for general employees to promote understanding of the Company's code of conduct and prevent harassment. These educational programs will be continued in fiscal 2015. To prevent human rights violations in our supply chain, particularly the use of child labor and forced labor in other countries, we work with and evaluate suppliers as part of our CSR procurement.
(For more information, see Purchasing Ethics.) We plan to continue our existing efforts to prevent human rights violations and raise awareness of human rights issues.
We were not involved in any lawsuits or other serious disputes concerning human rights in fiscal 2014.

Common Code of Conduct for the Fujifilm Group (excerpts)

Respect of basic human rights

The most fundamental aspect of compliance is respect for basic human rights. Individual dignity is at the core of our innate human rights, and there can be no compliance if such rights are not respected and protected.
Observing the following points will make our work environment better and is essential for truly enhancing productivity.

(1) Respect and protection of human rights

We respect and protect basic human rights guaranteed by international declarations as well as national constitutions and judicial precedents, and we do not infringe on such rights.

(2) Prohibition of discrimination

We respect one another as individuals and do not discriminate on the grounds of ethnicity or race; religious or political convictions or other beliefs; gender; regional or family background; disability; or age.

(3) Prohibition of harassment

We do not speak or act in ways that degrade individual dignity based on issues such as gender, authority or position (sexual harassment or power harassment), nor do we engage in any other form of harassment.

(4) Protection of privacy

We do not disclose information relating to individuals' private lives gained in the workplace or in the course of our duties without the clear consent of the individual concerned.

(5) Respect and protection of basic labor rights

We respect and protect basic labor rights, including workers' rights to organize and bargain collectively, and we do not infringe on such basic labor rights.

(6) Prohibition of forced labor / child labor

We do not take part in any form of forced labor or child labor.

(7) Workplace health and safety

We comply with workplace health and safety laws as well as regulations designed to prevent workplace accidents. We ensure safe and healthy working conditions, promote the creation of comfortable work environments, and do not act in ways that conflict with these aims.