Compliance

We seek to thoroughly understand laws and customs both in Japan and overseas, as well as all social norms and worldviews, and to comply with them and always act with a high degree of social conscience. We have established the Fuji Electric Compliance Regulations and the Fuji Electric Compliance Program to be our foundation for such efforts.

Compliance Policies and Structures

The Fuji Electric Code of Conduct, which was revised in October 2010, states that we shall “Respect, value and conform to all applicable laws and regulations.” Based on this code, we have established the Fuji Electric Compliance Regulations and the Fuji Electric Compliance Program, which bring together four aspects of domestic and overseas compliance (internal rules, oversight, monitoring, education) to achieve sustained growth. We promote activities based upon the above regulations and program not only by Fuji Electric Co., Ltd., but also by our consolidated subsidiaries, to ensure thorough compliance.

The Fuji Electric Compliance Committee, which is headed by the president and composed of the managers responsible for compliance, with outside experts (attorneys) as observers, has jurisdiction over compliance. The committee meets twice a year to deliberate compliance planning and execution with the goal of achieving full compliance with laws and social norms.

In addition, we have set up the Business Ethics Helpline system for the prevention and early detection of infractions of laws and company rules. This system allows employees to report to the president of Fuji Electric via the Compliance Division.

Strengthening Compliance at Overseas Subsidiaries

Based upon our policy of “Respect, value and conform with all applicable laws and regulations,” Fuji Electric is promoting localization of management and construction of partnerships with offshore enterprises as we strengthen our overseas compliance program.

Specifically, we classify our offshore bases into three regions and have tailored our compliance programs accordingly by formulating the Fuji Electric European and U.S. Compliance Program, the Fuji Electric China Compliance Program and the Fuji Electric Asian Compliance Program. These programs focus on common social issues to be addressed, such as prohibiting unfair discrimination and human rights violations and stopping illegal practices such as bribery and corruption.

In addition, we have extended our Business Ethics Helpline System to overseas subsidiaries and taken other steps for the early detection and prevention of violations of laws and ordinances.

In FY2010, we held explanatory meetings at each of our bases concerning the Compliance Programs and the Business Ethics Helpline System, aimed at more thorough compliance.

We plan to raise employee awareness of compliance through training on local laws and customs. We will also shore up our compliance systems by appointing a Compliance Manager at each base.

Business Ethics Helpline

Fuji Electric operates a Business Ethics Helpline to promote the prevention and early detection of legal and in-house rule violations. Fuji Electric employees worldwide can make use of the Helpline to report actual or suspected violations of laws, regulations or internal rules. The helpline provides a route of communications, independent from regular business channels. Employees may report items of concern via dedicated phone line, fax or e-mail, or by sealed post.

For informant protection, ease of reporting and timely response, all reports are taken by the Fuji Electric Compliance Unit, with the content forwarded to the president of Fuji Electric. Attorneys may then be called upon to participate in a response, such as an investigation, depending upon the nature of the information provided.

In the event that an investigation confirms that infraction of laws, regulations or in-house rules has occurred, the company responds immediately with corrective and recurrence prevention measures, internal discipline and disclosure.

Furthermore, the system guarantees that through such reporting of information, employees will not suffer any prejudicial treatment, reprisals, internal discrimination or other punishment for their actions. Any words or deeds perceived as reprisals or discrimination shall be treated with the utmost severity by Fuji Electric.

Promoting Compliance Training

Fuji Electric has created a compliance training program for our officers and employees that addresses matters they encounter in the course of their business activities. This program is conducted year-round.

Compliance training comprises level-specific and job-specific courses. Level-specific training is tailored to executives, general managers, managers and new employees of consolidated subsidiaries, and consists of classroom sessions lasting a half to one full day, focused on the Fuji Electric Group compliance framework and the Fuji Electric Compliance Program. In FY2010, training was conducted for around 160 new employees and 20 directors.

Job-specific training is provided to meet the needs of all professionals, such as members of the sales and administration staff, featuring items for consideration in practical business situations in half-day classroom-based group sessions. In FY2010, this training was provided for about 800 members of sales and administration units.

Local training at overseas subsidiaries was conducted for 388 personnel at 39 bases in 12 countries in FY2010.

In the future, we plan to implement real-time compliance training via the Internet and teleconferencing, to increase the number of participants.

Compliance training in China