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Ownership
PUBLIC
Defence revenue, USD
661.3m (2011)
Defence revenue, %
1.2% (2013)
Country
JAPAN
Internal information
YES
Based on public information, there is no readily available evidence that the President demonstrates a personal external-facing commitment to the ethics and anti-corruption agenda of the company, for example through public speeches or interviews or involvement with anti-corruption initiatives. Fujitsu’s letter of commitment to the UN Global Compact is from 2009, and is the only example found of the President committing to anti-corruption; there appears to be nothing from the last two years. However, there is evidence that this commitment has been delegated to the Compliance team. The company therefore scores 1.
Based on public information, there is no readily available evidence that the President demonstrates a personal internal-facing commitment to the ethics and anti-corruption agenda of the company, for example through direct engagement with staff, speaking at training events, etc.
Based on public information, there is evidence that the company publishes its set of business values as the The ‘Fujitsu Way’. This covers the principles of integrity, trust and transparency sought by the question and based on public information it is clear how these values are translated into company policies and codes.
Based on public information, there is evidence that Fujitsu is a member of the UN Global Compact.
Based on public information, there is evidence that in 2012 the company established an integrated Risk Management and Compliance Committee which oversees corporate governance, risk assessment and compliance in conjunction with the Board of Directors and the Management Council. Terms of reference are clear, with specific responsibilities defined.
Based on public information, there is evidence that the Code of Conduct, which is part of the ‘Fujitsu Way’, is overseen by a Promotion Council, and a Risk Management and Compliance Committee oversees corporate governance, risk assessment and compliance in conjunction with the Board of Directors and the Management Council. However, there is no readily available evidence of a person at a senior level with responsibility for implementing the company’s ethics and anti-corruption policy.
Based on public information, there is evidence that the Risk Management and Compliance Committee is in charge of the company’s compliance programme. Based on public information, there is readily available evidence that the Committee conducts review and reporting on major risks, including compliance; however, the scope of the review process and how often this occurs remain unclear. The company therefore scores 1.
Based on public information, there is no readily available evidence of a a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, or evidence of improvement plans being implemented when issues are identified.
Based on public information, there is evidence of a risk management and compliance system that conducts periodic reviews and impovements as a response to potential compliance issues.
Based on public information, there is evidence of a well-documented risk management process that covers various business risk areas, of which compliance is understood to form a part. The ownership of risk management procedures and mitigation processes is also documented.
Based on public information, there is evidence of risk management processes that take into account factors likely to be highly important to proposed business decisions. However, it is not clear how the company addresses important business decisions within the wider risk management process.
Based on public information, there is evidence that due diligence is undertaken before a third party (including agents) is appointed, and of ongoing monitoring and of red flags that may give rise to checks. However, it is not stated that this due diligence is refreshed every three years or when there is a significant change in the business relationship. The company therefore scores 1.
Based on public information, there is evidence that the company has contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption.
Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption. The Supplier Code of Conduct contains information explaining why Fujitsu is opposed to corruption and that the company expects the same level of compliance from suppliers as from all other employees. Further, the Global Business Standards contain regulations of the relations with third parties. However, it is not explicitly clear that the company has contractual rights to apply sanctions in the event of breach of contract. The company therefore scores 1.
Based on public information, there is evidence in the Code of Conduct of a detailed description of the nature of bribery that is forbidden, which includes both giving and accepting bribes. The Code of Conduct further explains other forms of unethical behaviour that are unacceptable and may lead to other forms of corrupt practice. This includes uncompetitive practice, not ensuring dealings with government officials are honest, and not materially deviating from contractual requirements without government permission.
Based on public information, there is no readily available evidence evidence that the company’s anti-corruption policy is explicitly one of zero tolerance.
Based on public information, there is evidence that the Code of Conduct is publicly available on Fujitsu’s website, and available in numerous different languages.
Based on public information, there is evidence that both the Code of Conduct, and the portion of the website that summarises the themes of the code, is written in clear and comprehensible language.
Based on public information, there is evidence that the Code of Conduct explicitly applies to all employees, directors, and officers.
Based on public information, there is evidence that the Code of Conduct contains a clear policy on potential conflicts of interests that applies to all employees (which is defined to include directors and officers), and features examples of potential conflicts.
Based on public information, there is evidence that the company has a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery. TI notes that managerial approval is required for gifts whose value exceeds a range contained within Regional policy.
Based on public information, there is evidence that the company has a policy for the giving and receipt of hospitality (entertainment) to ensure that such transactions are bona fide and not a subterfuge for bribery. TI notes that managerial approval is required for hospitality whose value exceeds a range contained within Regional policy.
Based on public information, there is evidence of a clear policy that forbids bribery in its many forms – and the examples given encompass facilitation payments. The Annex in the Code of Conduct provides considerable additional information and guidance on the company’s approach to anti-corruption.
Based on public information, there is evidence that the company prohibits political contributions unless authorised by senior management. However, TI notes that there is no readily available evidence that any recipients are required to be publicly disclosed and the guidelines remain limited. The company therefore scores 1.
Based on public information, there is no readily available evidence that the company has a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies. TI notes that Fujitsu UK & Ireland has a policy on corporate lobbying, but has not seen evidence that there is such policy applicable to the global company.
Based on public information, there is evidence that the company regulates charitable contributions in order to prevent undue influence or other corrupt intent. TI notes that company donations are handled centrally, though company donation procedures; however, there is no readily available evidence that recipients are declared. The company therefore scores 1.
Based on public information, there is evidence that the company’s Code of Conduct is detailed and includes additional guidance for employees, such as the Integrity Test, a way to help employees make the right decisions. The Annex to the Code of Conduct also contains a Global Policy on Anti-Bribery and Anti-Corruption that includes advice on what could be construed as a bribe or improper payment, and ‘warning signs that a payment is improper’ illustrated by brief but clear scenarios. The Code of Conduct applies to Board members and employees.
Based on public information, there is evidence that the company has a training programme that makes explicit reference to anti-corruption.
Based on public information, there is evidence that anti-corruption training is provided to employees in all sites of operation.
Based on public information, there is evidence that company executives receive training but it is not evident from readily available information that this training occurs at least every 3 years. The company therefore scores 1.
Based on public information, there is evidence that targeted compliance training is conducted for employees in sensitive positions.
Based on public information, there is evidence that the Code of Conduct makes the case for avoiding conflicts of interest, and identifies areas to watch to help avoid them. Employees are advised to disclose potential conflicts to managers, and reference is made to subsequent documentation and management of such conflicts. However, it is not stated that such disclosure should be in writing from the outset, and there is no evidence the declaration could also be made to an independent department.
Based on public information, there is evidence that the Code of Conduct explicitly states that violation of the Global Business Standards—of which anti-corruption standards are a part—may result in disciplinary action. However, given the language used, it is not clear that disciplinary action would be taken in each case. The company therefore scores 1.
Based on public information, there is evidence that the company has multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee, to report concerns or instances of suspected corrupt activity. Specifically, TI notes that the company has both internal and external channels for employees to report concerns or instances of suspected corrupt activity.
Based on public information, there is evidence that whistleblowing channels are available to all employees in all geographies.
Based on public information, there is evidence that the company conducts an employee survey, but no explicit evidence that this covers concerns surrounding whistleblowing activity. However, the Code of Conduct reports that external whistleblowing mechanisms are examined to monitor compliance with the Global Business Standards and to ensure that the company remains a place ‘where each employee can raise his or her own worth’. The company therefore scores 1. To score higher TI would need to see additional evidence of such mechanisms, for example formal follow-up activity undertaken with whistleblowers.
Based on public information, there is evidence of a helpline to provide guidance on the Code of Conduct. The helpline is well-publicised online. Employees also have access to different resources and departments where they can report breaches of the policies.
Based on public information, there is evidence of a clear commitment to non-retaliation, and that retaliation will be treated as a serious offence. However, it is not clear that employees breaching this commitment will be disciplined. The company therefore scores 1.
Based on public information, there is no readily available evidence that the company publishes a statement from the President of the company supporting the ethics and anti-corruption agenda. TI notes that the company only publishes a brief statement from the President on the company’s strategic direction. There is also evidence of leadership commentary on the Fujitsu ‘DNA’ but this commentary does not go into depth on issues of integrity.