Compliance and Anti-Corruption
Compliance promotion framework
The Company has established a Risk and Compliance Committee chaired by the representative director, who takes primary responsibility for promoting, monitoring, and addressing compliance with laws and regulations. In addition, an internal reporting (whistleblowing) system has been established and is in operation. Furthermore, the Internal Auditing Department audits the appropriateness of the compliance framework, including that of subsidiaries, and reports the results to the representative director.
Fuji Group Ethics and Compliance Policy
In March 2025, the Fuji Group formulated the "Fuji Group Ethics and Compliance Policy" to ensure fair and honest corporate activities. The Group is committed to compliance with laws and regulations as well as social norms and corporate ethics.
In addition to providing education and training to employees inside and outside the Group, disclosing our policies, and establishing an internal reporting system, we are strengthening our monitoring system through the Risk Compliance Committee.
Furthermore, an audit department independent from the operational management line audits various initiatives based on the Fuji Group Ethics and Compliance Policy to mitigate risks such as bribery and corruption, and reports the results to the Board of Directors and the Audit and Supervisory Board Members.
Revisions to the "Fuji Group Ethics and Compliance Policy" require the approval of the CEO.
Anti-corruption initiatives
Based on the Fuji Group Ethics and Compliance Policy, we are committed to preventing all forms of corruption, including bribery, in order to promote sound and transparent business activities.
Regarding bribery in particular, we have established a system to prevent improper benefit-giving by thoroughly implementing both prior approval for entertainment and gift expenses and subsequent monitoring of expenditure records.
Additionally, we have implemented effective and concrete measures in various risk areas, including anti-money laundering checks on new business partners and centralized information management under internal information management regulations to prevent insider trading.
For fiscal year 2025, fines imposed on administrative authorities for corrupt practices amounted to zero Japanese yen. Furthermore, the amount of political contributions for this fiscal year was zero Japanese yen. We do not make political contributions in any country where we conduct business.
Through the creation of an open workplace and appropriate information disclosure, we will strive to foster a sound and highly transparent corporate culture and focus on establishing a system to prevent fraud and misconduct.
Initiatives
- Compliance with laws and regulations
- Prohibition of corrupt practices
- Prohibition of fraud and misappropriation
- Prohibition of conflicts of interest
- Exclusion of anti-social forces
- Anti-competitive practices
- Prohibition of insider trading
- Prevention of money laundering and terrorism financing
- Appropriate tax compliance
- Protection of personal information and privacy, and management of confidential information
- Protection of intellectual property
- Information security measures
- Appropriate information disclosure
- Proper labeling, explanations, and advertising
- Responsible mineral procurement
- Political involvement
- Whistleblowing system
- Compliance education, training, and awareness
Human rights, ethics, and compliance training
1.Fuji, domestic group companies
- All employees have completed training on the Fuji Group Behavior Charter
In 2010, all Fuji employees completed training and signed the Code of Conduct. Since then, new employees have completed the same training and signed the Code of COnduct upon joining the Company. At Fuji's domestic group companies, employee training and COde of COnduct acknowledgment have been conducted since 2016, with the same process applied to new hires thereafter.
- Training on the policy introduced in March 2025
We have posted the Fuji Group Human Rights Policy and the Fuji Group Ethics and Compliance Policy, translated into Japanese, English, and Chinese, on the Fuji Group portal site. By making these policies accessible to all Fuji Group members, we promote awareness across the Group.
- Provided training for new employees (Every April)
- Provided training for mid-career employees (Every May)
- Provided education for directors of domestic group companies (Every May, October )
- Provided education for key personnel (Every September)
- Provided pre-assignment education for newly appointed key personnel (Every March)
Based on the Fuji Group Human Rights Policy and the Fuji Group Ethics and Compliance Policy, information sharing and training were conducted on human rights, ethics, and compliance (including anti-corruption).
2.Supply chain engagement
In recent years, the scope of CSR activities in procurement, such as human rights, child labor, forced labor, prohibition of discrimination, and responsible mineral procurement, is required to be expanded to cover the entire supply chain. In conjunction with the establishment of the Fuji Group Human Rights Policy and the Fuji Group Ethics and Compliance Policy, we are sharing these principles internally and externally along with the "Supplier code of conduct and agreement" from fiscal year 2026. We are also promoting responsible procurement by encouraging our suppliers to practice respect for human rights.
- *130 major suppliers in Japan have endorsed the project. (as of June 2025)
We will continue to implement initiatives to make our stakeholders aware of the importance of human rights, ethics, and compliance.
Anti-corruption due diligence
The Group is establishing anti-corruption due diligence system to identify and address potential and apparent risks related to anti-corruption.
We identify and evaluate risks related to our business operations and supply chain, take appropriate preventive and mitigating measures, and conduct follow-up on a continuous basis.
We place particular emphasis on anti-corruption measures and are committed to ensuring their effective implementation through internal training and collaboration with our suppliers.
In September 2025, the audit department, operating independently from the business execution line, conducted an internal investigation after identifying as an integrity risk a case at another company where a manager initiated purchase requests and abused processes to circumvent acceptance procedures, enabling a single employee to commit fraud totaling 240 million yen. No suspected misconduct was identified; however, a directive was issued prohibiting single-person end-to-end processing in procurement procedures, whereby a single core employee handles the entire process from purchase request to acceptance. Since then, through monitoring by the audit department, zero cases of single-person end-to-end processing were identified.
Whistleblowing system
In order to prevent violations of laws and regulations and misconduct, as well as to detect and correct such violations at an early stage, internal reporting regulations have been established, and a reporting and consultation service applicable to all directors and employees working for the Group has been put in place. These regulations prevent whistleblowers from being disadvantaged in accordance with the Whistleblower Protection Act, and allows for anonymous reporting. In addition, a dedicated consultation service has been established to appropriately respond to consultations and complaints of power harassment and sexual harassment in the workplace, ensuring that human rights are appropriately addressed.
| FY2022 | FY2023 | FY2024 | FY2025 | FY2026 | |
|---|---|---|---|---|---|
| Number of reports and consultations | 4 | 5 | 9 | 11 | 13 |
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