Furukawa Electric Group regards compliance as "not only observing laws and regulations, but also as acting in accordance with the values and ethics required of the company and its employees as responsible members of society". Each and every employee is encouraged to perform day-to-day compliance activities in line with our three musts for compliance activities: to "be aware", "speak" and "rectify".
1. Be aware
- Is this in line with the philosophy and CSR Code of Conduct?
- Is this an improper practice?
- Does this run counter to society's requirements and expectations?
- Do not neglect it.
- Talk about it openly.
- If still not sure, take it to your boss.
- As soon as you become aware of it, fix it.
- Always improve.
Training and Raising Awareness among Employees
We conduct a host of training and awareness activities in the aim of instilling compliance awareness among all employees. Our primary shared educational materials are the Furukawa Electric Group CSR Code of Conduct and its corresponding Furukawa Electric Group CSR Compliance Handbook. We distribute this handbook to all Furukawa Electric Group employees and take many opportunities to make use of it. We conduct compliance education for employees at every level of the Company, from new recruits to directors. At the same time, we hold theme-based group training and e-learning courses, and conduct groupwide compliance education.
Initiatives in Compliance Months
Furukawa Electric Group has designated October and November as Compliance Months, during which we implement measures aimed at tackling the variety of compliance issues faced by companies across our Group.
Compliance Awareness Surveys
Furukawa Electric Group continues to conduct a compliance awareness survey every other year. The purpose of the survey is to ascertain the current status of the organization by investigating how individual executives and employees feel about compliance and organizational culture and to utilize the results for compliance promotion measures within the group. The results of the survey are fed back to participating group companies for use in the formulation of compliance measures at each company. In FY2021, we reviewed the questions from the perspective of "Business and Human Rights" and conducted the awareness survey.
Furukawa Electric Group has introduced a whistleblowing system for early detection and correction of misconduct. Furukawa Electric has established not only the whistleblowing desk but an external whistleblowing desk (Furukawa Electric Group Hotline) using a third-party organization outside the company, both of which allow employees to make reports anonymously. While giving full consideration to ensure that the informant does not suffer any disadvantages, the whistleblowing office strictly manages the content of reports, investigates them promptly, and takes appropriate measures. Furthermore, depending on the content of the reports, we have an established system to ensure fairness by seeking opinions from outside experts. We also have introduced a whistleblowing desk for overseas group companies, and as of the end of FY2022, 45 companies in 17 countries had introduced it. The number of whistleblowing in the Group was 103 in FY2022, of which approximately half were related to human resources and labor relations. Only a limited number of them turned out to be true as pointed out. However, all of them, including parts of them turned out to be true, have been corrected through the implementation of preventive measures. The Group recognizes the whistleblowing system functions well based on the fact that there was a certain number of whistleblowing.
Security Trade Control
Furukawa Electric Group considers security trade control to be one of its most important responsibilities as a company with global business operations. In accordance with the laws and regulations that make up the international framework on security trade control (the export control regime), we have improved and strengthened our management systems for cargoes and technologies that can be converted to weapons or military uses. In exporting products and providing technology, we conduct transaction screenings based on our Security Trade Control Regulations to ensure compliance with relevant legislation and are careful to prevent circumvent to countries of concern.
Furukawa Electric Group formulated the Furukawa Electric Group Anti-Bribery Statement in April 2012. In December, we published the Furukawa Electric Group Anti-Bribery Guide (revised to the second edition in May 2018), and we are promoting activities toward creating a groupwide bribery risk management system.
Requirements of Furukawa Electric Group Anti-Bribery Statement
- Do not give, offer, promise, accept or demand, directly or indirectly, anyone a bribe.
- Ensure that payments to Government Officials are made according to adequate approval procedures and are reviewed appropriately.
- Are fully aware of, and comply with the applicable anti-bribery laws and the Furukawa policy through training programs and communication of the policy. Employees, agents and Business Partners are furthermore required to declare compliance to applicable anti-bribery laws and the Furukawa Electric Group policy.
- Engage only with legitimate and transparent Agents and Business Partners, after performing adequate due diligence procedures on the Agent or the Business Partner.
- Regularly assess Bribery Risks concerning the business of the company.
- Maintain record keepings and financial controls to enable demonstration of compliance with anti-bribery laws and the Furukawa Electric Group policy.
- Regularly review and update its policy and controls where necessary to prevent bribery.
- Promptly report any suspected violations of the applicable anti-bribery laws or the Furukawa Electric Group policy by any of the Group’s Employees, Agents or Business Partners, so that any violations or suspected violations are dealt with timely.
Tax Compliance Policy
We, Furukawa Electric Group, acknowledge that “tax compliance” is of utmost importance for our group and shareholders. In addition, we understand that the taxes we pay play an important role in the economic and societal development of the receiving countries and tax jurisdictions.
Therefore, Furukawa Electric Group recognizes that the payment of taxes in compliance to the laws and regulations of each country and jurisdiction is a natural obligation and a method for contributing to society.
“Tax compliance” is also in accordance with Furukawa Electric Group’s CSR Code of Conduct which states that we regard compliance as "not only observing laws and regulations, but also as acting in accordance with the values and ethics required of the company and its employees as responsible members of society."
Thus, we are committed to abide by local and international tax laws, build a trusting relationship with the local tax authorities, and undertake in creating an international tax framework centering on transfer pricing in addition to giving careful attention to the following:
- We don’t address tax avoidance through adopting organizational structures that do not coincide with actual business purposes and operations.
- We need to recognize all the transactions are made based on a business purposes and operations, make decisions in consideration of social demands behind even in the case that there are tax benefits, and decide such transactions will not be made if there are no coinciding business purposes and operations.
With the premise that the above tax compliance rules are being observed, Furukawa Electric Group will endeavor to minimize tax risks, apply tax benefits such as tax deductions performing regular checks of tax positions in relevant countries and tax jurisdictions, and reduce unnecessary tax costs in order to maximize shareholder value.
Challenges and Future Policy
Regarding the various legal compliance measures wehave taken to date, we recognize as a Group that ourtask is to expand the scope of participation of Groupcompanies. Going forward, we will try to raise complianceawareness by focusing on more effective educationcontent with a Group perspective and enhancing its globalimplementation system. We will also hold more compliance seminars taking account of local laws, languagesand customs, encouraging individual initiative under theslogan “Think and conduct compliance together”.