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 were the word 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 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 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

In fiscal 2016, Fuji Xerox integrated the Ethics and Compliance Committee into the CSR CommitteeNote 1under which the Ethics and Compliance Committee had been established, with a view to enhancing the CSR-related functions and ensuring that the important corporate ethics and compliance measures discussed and decided by the CSR Committee would be implemented promptly and without fail under the leadership of the head of each functional organization.

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 laws and regulations in their respective countries and review them on a regular basis.

In response to the inappropriate accounting practices at overseas sales affiliates, a Fujifilm Group governance enhancement project was established in fiscal 2017. To enhance transparency of the operation, the entire corporate group has worked on the prevention of a recurrence of similar incidents.

In April 2018, Fuji Xerox established the Compliance & Risk Management Department (hereafter “CP&RM”). In July, the CSR Committee was renamed to the “Compliance & Risk Management Committee” to clarify its role to further strengthen compliance at Fuji Xerox.

Corporate Auditors, Meeting of the Board  of Directors. Internal Audit and Analysis, Business Execution (President). CSR Committee. Ethics and Compliance Committee. General Affairs, Human Resources Groups, Legal. All organizations in Fuji Xerox and its affiliates. Ethics and Compliance Management Rules in Committee, Objectives, roles, and responsibilities. Management tools: Operational regulations and Guidelines. Communication and training: Legal training and Prevention of illegal actions. Monitoring: Organization and Specialized departments. Crisis management and internation disclosure, Identifying problems and whistle-blowing. Auditing and correction. These are available on Domestic business sites and Overseas business sites.

Ethics Management

Fuji Xerox places great importance on ethics management. We introduced a groupwide Code of Conduct in fiscal 1997 that sets out the core conduct expectations and priorities for all employees in accordance with our “Mission Statement” and “Shared Values”. The code of conduct was revised into the ALL-FX Code of Conduct in fiscal 2007 to ensure fulfillment of the UN Global Compact, which Fuji Xerox signed in fiscal 2002, and to respond to the changing needs of society.

The ALL-FX Code of Conduct aligns with the Fujifilm Group Charter for Corporate Behavior / Code of Conduct established in April 2007. It has been translated into local languages and distributed to all overseas affiliated companies as values to be shared by all people who work at Fuji Xerox.

At the same time, the ALL-FX Code of Conduct Guidebook was published to explain, using examples, important points that employees should pay attention to when they perform their daily operations to ensure that each employee correctly understands the Code of Conduct.

This Guidebook was revised in fiscal 2016 based on more global perspectives, by modifying explanations and examples to reflect international standards.

In fiscal 2017, the revised Guidebook was translated into local languages. An education program designed for all employees at Fuji Xerox and affiliated companies was implemented to let them know and understand the Guidebook.

In April 2019, Fujifilm Group has revised its Charter for Corporate Behavior and Code of Conduct in order to take a stand for more positive contribution to the solving of social challenges. The revised Fujifilm Group Charter for Corporate Behavior and Code of Conduct are applied to Fuji Xerox and affiliated companies as revised ALL-FX Code of Conduct.

Fujifilm Group Code of Conduct

Whistle blowing system

In fiscal 2008, Fuji Xerox introduced the “ALL FX Compliance Help Line” as a contact point for employees to report and consult about corporate ethics and compliance. This Help Line was formed by integrating the Sexual Harassment Hotline established in fiscal 1997 and the Corporate Ethics Help Line established in fiscal 2003. The ALL-FX Compliance Help Line receives reports and consultations from all employees of Fuji Xerox and affiliated companies in Japan regarding compliance-related laws and corporate ethics.

Complainant or Consulter in All officers and employees of Fuji Xerox and its affiliates, Complaints and consultation (by telephone) via Extemal liaison, It reports to All Fuji Xerox Compliance Help Line Office. It reports to Ethics and Compliance Committee. Complainant or Consulter in Individuals engaged in business activities on behalf of Fuji Xerox and its affiliates, Reports and consultationv (by webmail or letter) to All Fuji Xerox Compliance Help Line Office, It reports to Ethics and Compliance Committee. It will feedback to complainant and consulter.Structure of the All Fuji Xerox Compliance Help Line

Compliance Education

Since fiscal 2008, we have held 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, in fiscal 2011. In fiscal 2017, the Legal Risk Assessment Test was taken by 23,568 employees, a figure that accounts for 99% of all eligible employees of Fuji Xerox and its domestic affiliates.

In addition to these ongoing efforts, we are creating and revising theme-based compliance guidelinesNote 2that summarize compliance matters that are regarded as risky from a legal perspective (such as subcontracts, the Anti-Monopoly Act, and temporary staffing services).

Moreover, general education programs for all employees, we provide compliance training tailored to specific job categories. Since fiscal 2012, we have been providing group training for new managers twice a year (including the presentation of case studies).

In fiscal 2017, we continued programs to disseminate the basic ideas and rules. In response to the inappropriate accounting practices at overseas sales affiliates, we also implemented awareness-reforming programs to prevent a recurrence of similar mistakes.

A groupwide compliance education program and a subsequent questionnaire survey were conducted by Fujifilm Holdings. As a result, more than 90% of attendees of the education program responded that they understood what actions they should take in the future.

In fiscal 2018, we will continue to take measures mainly focusing on corporate culture reform. Heads of every organization will submit a letter of compliance commitment, and conduct educational programs on awareness change for compliance management. And all officers and employees will submit a pledge of compliance with the Code of Conduct.

  • Note 1 Renamed to the Compliance & Risk Management Committee in July 2018.
  • Note 2 Sales activities for public sector; subcontracts; environmental regulations; temporary staffing services; the Companies Act; exports and imports; the Anti-Monopoly Act; and laws governing service businesses.