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

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

In fiscal 2013, in response to recent trends around the world to strengthen anti-corruption legislation, Fuji Xerox and all its domestic affiliates established corruption prevention regulations. In fiscal 2014, the regulations were established in all Fuji Xerox companies, including overseas affiliates.

In fiscal 2016, we are going to dissolve the Ethics and Compliance Committee and delegate the decision-making process related to planning, introduction and review of ethics and compliance measures to CSR Committee, composed of the leaders of all functional areas, thus enabling them to promptly implement these measures in all business functions.

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 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 affiliates.

In fiscal 2008, Fuji Xerox introduced All Fuji Xerox 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.

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.

In fiscal 2015 all employees were reminded of the availability of All Fuji Xerox Compliance Helpline. Fuji Xerox and its affiliates will continue to provide employees with ethics and compliance education to raise their awareness of the issues.

All Fuji Xerox Code of Conduct, All Fuji Xerox Code of Conduct Guidebook

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 2015, the Legal Risk Assessment Test was taken by 23,529 employees, a figure that accounts for 99.6% of all eligible 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 covers selected topical issues and explains their legal aspects in simple language. Since fiscal 2013, we have also been issuing an English version of Easy Legal News for officers and executives of our overseas affiliates. In addition to these ongoing efforts, we are creating and revising theme-based compliance guidelinesNote 1 that summarize compliance matters in legal areas, regarded as risky from legal perspective.

In fiscal 2015, we were posting weekly case studies on the intranet to help employees deepen their understanding of harassment issue (17 times in total). In addition to 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 2015, we provided managers of all levels with web-based educational materials (videos).

Further, we posted the cases of accounting frauds on the intranet (6 times in total) to raise the awareness and knowledge of employees, including those of overseas affiliates, aiming to prevent the occurrence of any accounting frauds, which would lead to the collapse of corporate trust.

In fiscal 2016, we will continue to conduct Legal Risk Assessment Test and publish Easy Legal News, as programs designed to promote employees' understanding of the basic policy and rules of the Company.

To further ensure legal compliance, we will upgrade our legislation training programs to provide 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.

  • Note 1 The guideline themes cover sales to government and municipal offices, subcontracted transactions, environmental regulations, dispatched workers, corporate law, exports and imports, competition law, and law concerning service-related businesses.

Human Rights Initiatives

The Fujifilm Group established its Charter for Good Corporate Behavior in April 2007, which describes the fundamental spirit behind the group's human rights initiatives. This Charter calls for "respect for all human rights."

Fuji Xerox provides human rights training, focusing on the right for harassment-free life and on mental health, as part of its annual training programs tailored to specific job categories, including new employees and managers.

Furthermore, all general employees of Fuji Xerox and its affiliates are provided with the training on the code of conduct. Other efforts to increase awareness of human rights among employees include requests to propose catch-phrases related to human rights, and the distribution of semiannual human rights bulletin to all executive general managers. In fiscal 2015, group trainings designed for individual job categories were continued along with the e-learning programs for general employees to promote understanding of the Company's code of conduct and prevent harassment.

To prevent human rights violations in our supply chain, particularly child labor and forced labor at our overseas suppliers, we evaluate their performance and work with them to improve it as part of our CSR procurement. (For more information, see Purchasing Ethics.) We plan to continue our existing efforts to prevent human right violations and raise awareness of human rights issues. As in the previous fiscal year, in fiscal 2015 we were not involved in any lawsuits or other serious disputes concerning human rights.

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.