Fujitsu General Group
Guideline for Sustainable Procurement

富士通ゼネラルグループ富士通ゼネラルグルー

March 2024 (Fourth Edition)
Fujitsu General GroupContents
Cover

1.Introduction ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・2
2.Guideline for Sustainable Procurement ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・2
3.Request matter for Suppliers

・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・3

4.Contact ・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・3<Annex>Annex1

Explanation of Sustainable Procurement Guidelines

Annex2

Reference Standard Type1

1. Introduction
We, Fujitsu General Group, have established, in our corporate policy “FUJITSU GENERAL Way(revised in 2018)”, the “Code of Conduct” as a matter to be observed by employees working in ourgroup, and is thoroughly disseminating the conduct. We also have established “Human Rights Policy(revised in 2022)” which clarifies our response to human rights issues.
Based on these “Code of Conduct” and “Human Rights Policy”, we have established “Fujitsu General
Group CSR Procurement Guideline” in 2020 which covers our procurement activities and asked our
suppliers to agree with the guideline. With the recent upgrade of the code of conduct issued by RBA(Responsible Business Alliance) to Ver. 8.0, we have revised the guideline through the review of
initiatives to be taken in order to fulfill “Corporate Social Responsibility” by the close collaboration
between our suppliers and us throughout the supply chain, including consideration for human rights
and strengthening occupational safety and health. (In addition, the name has been changed to“Fujitsu General Group Guideline for Sustainable Procurement” with this revision.)
We consider this guideline to be an important agreement in our business dealings, and would liketo regularly investigate and confirm the status of our suppliers' efforts regarding the contents
described.
We ask our suppliers to understand the purpose of this guideline and to develop the businessactivities within their companies in accordance with this guideline, and also request that our
suppliers regularly investigate and understand the status of their response, discover problems early,
and take necessary corrective actions.
Furthermore, we would like to ask our suppliers’ cooperation in disseminating the purpose of thisguideline to their next-stage suppliers and in promoting sustainability due diligence (hereinafter,
referred as “Sustainability DD”) activities throughout the supply chain, such as conducting necessary
surveys.

2. Guideline for Sustainable Procurement
This guideline outlines actions and activities that we expect our suppliers to specifically practiceand comply with.
[Note]
Please refer to Annex 1 for explanations of terms used in this Guideline.
For the purposes of these Guidelines, “workers” include temporary workers, migrant workers,
student workers, contract workers, and all other types of workers and employees, whether
directly or indirectly employed, and “workplace” includes "factory, production facility, warehouse,
etc."

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1）LABOR（1）Prohibition of Forced Labor （2）Young Workers （3）Working Hours（4）Wages and Benefits （5）Non-Discrimination/Non-Harassment/Humane Treatment(6) Freedom of Association and Collective Bargaining
2) HEALTH AND SAFETY（1）Occupational Health and Safety （2）Emergency Preparedness（3）Occupational Injury and Illness （4）Industrial Hygiene （5）Physically Demanding Work
（6）Machine Safeguarding（7）Sanitation, Food, and Housing（8）Health and Safety Communication
3) ENVIRONMENT（1）Environmental Permits and Reporting（2）Pollution Prevention and Resource Conservation（3）Hazardous Substances （4）Solid Waste（5）Air Emissions（6）Materials Restrictions（7）Water Management（8）Energy Consumption and Greenhouse Gas Emissions（9）Biodiversity Conservation
4) ETHICS（1）Business Integrity（2）No Improper Advantage（3）Disclosure of Information（4）Intellectual Property（5）Fair Business, Advertising and Competition（6）Protection of Identity and Non-Retaliation （7）Responsible Sourcing of Minerals（8）Privacy
5) MANAGEMENT SYSTEMS（1）Company Commitment（2）Management Accountability and Responsibility（3）Legal and Customer Requirements（4）Risk Assessment and Risk Management（5）Improvement Objectives（6）Training（7）Communication（8）Worker/Stakeholder Engagement and Access To Remedy（9）Audits and Assessments（10）Corrective Action Process （11）Documentation and Records（12）Supplier Responsibility

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3. Request matter for Suppliers
1) Self-Check of Sustainability DD Initiatives
Based on the contents of this guideline, please conduct internal investigations ("on-site
observation", "review of relevant documents", "interviews with relevant personnel", etc.) in yourcompany.
If there happen to be any problems in your company, please report them to us promptly, andwe would like to ask you to make efforts to identify and response to compliance problems andprevent reoccurrence.
In particular, please ensure that your company and your business partners are disseminated to
avoid retaliation against those who report violations of laws and regulations.
2) Deployment to your supply chain
We would like to ask you to promote Sustainability DD Initiatives throughout the entire supply
chain, including to your suppliers.
3) On-site Survey of Sustainability DD Initiatives
In case that we need to conduct on-site survey of Sustainability DD Initiatives for your company,
we would like to ask your cooperative acceptance.
4)

Request for signature and submission of "Agreement Confirmation Form”
After reading this guideline and agreeing to the contents, please sign the "Agreement
Confirmation Form" on the next page and submit it electronically to the Fujitsu General Group
Purchasing Department.
Please note that we ask all new suppliers to submit this form in principle.

4. Contact
For inquiries regarding this guideline, please contact the following;
Fujitsu General Group

Purchasing departments at each site

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Agreement Confirmation Form
Fujitsu General Group : Guideline for Sustainable Procurement（4th edition）
We request you to sign this form by the responsible person (the person responsible for yourdepartment or business unit in charge) so that we can confirm that you understand the purposeof this guideline and agree to its contents. By signing this form, we regard that you acknowledge
and accept the contents of this guideline regarding all parts, materials, and services to bedelivered to us.
Date：
Company Name：
Address：
Department Name：
Responsible Person's Name（「”Personal Writing” or “Sign＋Seal of Responsibility”）：
TEL：
E-mail Address：
Please submit this form to the contact point of the Company that requested you to agree to theform.
If you do not agree to any terms of this guideline, please enter the reason of disagreement in thefield below.

【Privacy Policy】
With respect to the personal information included in this Confirmation Form, we agree that it may
be used to inquire about matters related to transactions with Fujitsu General Group. (We regard
your consent to the terms of “Privacy Policy” by signing your name to the personal information
section above.）
We promise to handle the personal information we receive with the utmost care and use it only
within the scope of the purpose of use.
- Manager regarding personal information of suppliers：
Manager of Purchasing Department at each site of Fujitsu General Group5

Annex1．Explanation of Sustainable Procurement Guidelines
1．Initiatives in LABOR
1）Prohibition of Forced Labor
Forced labor in any form, including but not limited to, bonded (including debt bondage) or
indentured labor, involuntary or exploitative prison labor, slavery or trafficking of persons is not
permitted. This includes transporting, harboring, recruiting, transferring, or receiving persons bymeans of threat, force, coercion, abduction or fraud for labor or services. There shall be no
unreasonable restrictions on workers’ freedom of movement in the facility in addition to
unreasonable restrictions on entering or exiting company- provided facilities including, if applicable,
workers’ dormitories or living quarters. As part of the hiring process, all workers must be provided
with a written employment agreement in their native language, or in a language the worker canunderstand, that contains a description of terms and conditions of employment. Foreign migrant
workers must receive the employment agreement prior to the worker departing from his or her
country of origin and there shall be no substitution or change(s) allowed in the employment
agreement upon arrival in the receiving country unless these changes are made to meet local law
and provide equal or better terms. All work shall be voluntary, and workers shall be free to leave
work at any time or terminate their employment without penalty if reasonable notice is given, whichshall be clearly stated in workers’ contracts. Participants shall maintain documentation on all leaving
workers. Employers, agents, and sub-agents’ may not hold or otherwise destroy, conceal, or
confiscate identity or immigration documents, such as government-issued identification, passports,
or work permits. Notwithstanding the foregoing, employers can only hold documentation if
necessary to comply with the local law. In this case, at no time shall workers be denied access totheir documents. Workers shall not be required to pay employers’ agents or sub-agents’ recruitment
fees or other related fees for their employment. If any such fees are found to have been paid byworkers, such fees shall be repaid to the worker.
2）Young Workers
Child labor shall not be used in any stage of manufacturing. The term “child” refers to any person
under the age of 15, or under the age for completing compulsory education, or under the minimum
age for employment in the country, whichever is greatest. Workers under the age of 18 (Young
Workers) shall not perform work that is likely to jeopardize their health or safety, including night
Shifts and overtime. Participants shall ensure proper management of student workers throughproper maintenance of student records, rigorous due diligence of educational partners, andprotection of students’ rights in accordance with applicable laws and regulations. Participants shall
implement an appropriate mechanism to verify the age of workers. The use of legitimate workplacelearning programs, which comply with all laws and regulations, is supported. Participants shallprovide appropriate support and training to all student workers. In the absence of local law, thewage rate for student workers, interns, and apprentices shall be at least the same wage rate asother entry-level workers performing equal or similar tasks. If child labor is identified,6

assistance/remediation shall be provided.
3）Working Hours
Working hours shall not exceed the maximum set by local law. Further, a workweek shall not be
more than 60 hours per week, including overtime, except in emergency or unusual situations. All
overtime shall be voluntary. Workers shall be allowed at least one day off every seven days.
4）Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating
to minimum wages, overtime hours and legally mandated benefits. All workers shall receive equalpay for equal work and qualification. Workers shall be compensated for overtime at pay rates greaterthan regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted.
For each pay period, workers shall be provided with a timely and understandable wage statementthat includes sufficient information to verify accurate compensation for work performed. All use of
temporary, dispatch and outsourced labor shall be within the limits of the local law.
5）Non-Discrimination/Non-Harassment/Humane Treatment
Participants shall commit to a workplace free of harassment and unlawful discrimination. There
Shall be no harsh or inhumane treatment including violence, gender-based violence, sexual
harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public
shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment.
Companies shall not engage in discrimination or harassment based on race, color, age, gender,
Sexual orientation, gender identity or expression, ethnicity or national origin, disability, pregnancy,
religion, political affiliation, union membership, covered veteran status, protected genetic
information or marital status in hiring and employment practices such as wages, promotions,rewards, and access to training. Disciplinary policies and procedures in support of theserequirements shall be clearly defined and communicated to workers. Workers shall be provided
with reasonable accommodation for religious practices and disability. In addition, workers or
potential workers should not be subjected to medical tests, including pregnancy or virginity tests,
or physical exams that could be used in a discriminatory way. This was drafted in consideration of
ILO Discrimination (Employment and Occupation) Convention (No.111).
6）Freedom of Association and Collective Bargaining
Open communication and direct engagement between workers and management are the mostEffective ways to resolve workplace and compensation issues. Workers and/or
their representatives shall be able to openly communicate and share ideas and concerns withmanagement regarding working conditions and management practices without fear of
discrimination, reprisal, intimidation, or harassment. In alignment with these principles,participants shall respect the right of all workers to form and join trade unions of their own
choosing, to bargain collectively, and to engage in peaceful assembly as well as respect the right7

of workers to refrain from such activities. Where the right of freedom of association and collective
bargaining is restricted by applicable laws and regulations, workers shall be allowed to elect andjoin alternate lawful forms of worker representations.
2. Initiatives in HEALTH AND SAFETY
1）Occupational Health and Safety
Worker potential for exposure to health and safety hazards (chemical, electrical and other energy
Sources, fire, vehicles, and fall hazards, etc.) shall be identified and assessed, mitigated using the
Hierarchy of Controls. Where hazards cannot be adequately controlled by these means, workers
Shall be provided with appropriate, well-maintained, personal protective equipment, andeducational materials about risks to them associated with these hazards. Gender-responsive
measures shall be taken, such as not having pregnant women and nursing mothers in working
conditions, which could be hazardous to them or their child and to provide reasonableaccommodations for nursing mothers.
2）Emergency Preparedness
Potential emergency situations and events shall be identified and assessed, and their impact
minimized by implementing emergency plans and response procedures including emergency
reporting, employee notification and evacuation procedures, worker training, and drills. Emergency
drills shall be executed at least annually or as required by local law, whichever is more stringent.
Emergency plans shall also include appropriate fire detection and suppression
Equipment, clear and unobstructed egress, adequate exit facilities, contact information for
emergency responders, and recovery plans. Such plans and procedures shall focus on minimizing
harm to life, the environment, and property.
3）Occupational Injury and Illness
Procedures and systems shall be in place to prevent, manage, track and report occupational
Injuries and illnesses, including provisions to encourage worker reporting, classify and record
injury and illness cases, provide necessary medical treatment, investigate cases and implement
corrective actions to eliminate their causes, and facilitate the return of workers to work.
Participants shall allow workers to remove themselves from imminent harm, and not return until
the situation is mitigated, without fear of retaliation.
4）Industrial Hygiene
Worker exposure to chemical, biological, and physical agents shall be identified, evaluated, andcontrolled according to the Hierarchy of Controls. When hazards cannot be adequately controlled,workers shall be provided with and use appropriate, well-maintained, personal protective equipment
free of charge. Participants shall provide workers with safe and healthy working environments, whichshall be maintained through ongoing, systematic monitoring of workers’ health and working
environments. Participants shall provide occupational health monitoring to routinely evaluate if
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workers’ health is being harmed from occupational exposures. Protective occupational healthprograms shall be ongoing and include educational materials about the risks associated with
exposure to workplace hazards.
5）Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material
Handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or forcefulassembly tasks shall be identified, evaluated, and controlled.
6）Machine Safeguarding
Production and other machinery shall be evaluated for safety hazards. Physical guards,
Interlocks, and barriers shall be provided and properly maintained where machinery presents aninjury hazard to workers.
7）Sanitation, Food, and Housing
Workers shall be provided with ready access to clean toilet facilities, potable water and sanitary foodPreparation, storage, and eating facilities. Worker dormitories provided by the Participant or a labor
agent shall be maintained to be clean and safe, and provided with appropriate emergency egress,
hot water for bathing and showering, adequate lighting, and adequate conditioned ventilation,individually secured accommodations for storing personal and valuable items, and reasonable
personal space along with reasonable entry and exit privileges.
8）Health and Safety Communication
Participants shall provide workers with appropriate workplace health and safety information andTraining in the language of the worker or in a language the worker can understand for all identified
workplace hazards that workers are exposed to, including but not limited to mechanical, electrical,
chemical, fire, and physical hazards. Health and safety related information shall be clearly posted in
the facility or placed in a location identifiable and accessible by workers. Health information andtraining shall include content on specific risks to relevant demographics, such as gender and age, if
applicable. Training shall be provided to all workers prior to the beginning of work and regularly
thereafter. Workers shall be encouraged to raise any health and safety concerns without retaliation.
3. Initiatives in EVIRONMENT
1）Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals, and registrations shall
Be obtained, maintained, and kept current and their operational and reporting requirements shallbe followed.
2）Pollution Prevention and Resource Conservation
Emissions and discharges of pollutants and generation of waste shall be minimized or eliminated9at the source or by practices such as adding pollution control equipment; modifying production,
maintenance, and facility processes; or by other means. The use of natural resources, including
water, fossil fuels, minerals, and virgin forest products, shall be conserved by practices such as
modifying production, maintenance and facility processes, materials substitution, re-use,conservation, recycling, or other means.
3）Hazardous Substances
Chemicals, waste, and other materials posing a hazard to humans or the environment shall beidentified, labeled, and managed to ensure their safe handling, movement, storage, use, recycling
or reuse, and disposal. Hazardous waste data shall be tracked and documented.
4）Solid Waste
Participants shall implement a systematic approach to identify, manage, reduce, and responsibly
dispose of or recycle solid waste (non-hazardous). Waste data shall be tracked and documented.
5）Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting
substances, and combustion byproducts generated from operations shall be characterized,
routinely monitored, controlled, and treated as required prior to discharge. Ozone- depleting
substances shall be effectively managed in accordance with the Montreal Protocol and applicableregulations. Participants shall conduct routine monitoring of the performance of its air emission
control systems.
6）Materials Restrictions
Participants shall adhere to all applicable laws, regulations, and customer requirements regarding
the prohibition or restriction of specific substances in products and manufacturing, including labelingfor recycling and disposal.
7）Water Management
Participants shall implement a water management program that documents, characterizes, andmonitors water sources, use and discharge; seeks opportunities to conserve water; and controls
channels of contamination. All wastewater shall be characterized, monitored, controlled, and treatedas required prior to discharge or disposal. Participants shall conduct routine monitoring of theperformance of its wastewater treatment and containment systems to ensure optimal performanceand regulatory compliance.
8）Energy Consumption and Greenhouse Gas Emissions
Participants shall establish and report against an absolute corporate-wide greenhouse gas reduction
goal. Energy consumption and all Scopes 1, 2, and significant categories of Scope 3 greenhouse gas
emissions shall be tracked, documented, and publicly reported. Participants shall look for methods
10to improve energy efficiency and to minimize their energy consumption and greenhouse gas
emissions.
9）Biodiversity
It is necessary to study the direct and indirect impacts of the company’s business operations on
ecosystems and work to conserve biodiversity.
4. Initiatives in ETHICS
1）Business Integrity
The highest standards of integrity shall be upheld in all business interactions. Participants shall
Have a zero-tolerance policy to prohibit any and all forms of bribery, corruption, extortion andembezzlement.
2）No Improper Advantage
Bribes or other means of obtaining undue or improper advantage shall not be promised, offered,
Authorized, given, or accepted. This prohibition covers promising, offering, authorizing, giving or
accepting anything of value, either directly or indirectly through a third party, in order to obtain or
retain business, direct business to any person, or otherwise gain an improper advantage.
Monitoring, record keeping, and enforcement procedures shall be implemented to ensurecompliance with anti-corruption laws.
3）Disclosure of Information
All business dealings shall be transparently performed and accurately reflected on the Participant’s
Business books and records. Information regarding participant’s labor, health and safety,
environmental practices, business activities, structure, financial situation, and performance shall be
disclosed in accordance with applicable regulations and prevailing industry practices. Falsification ofrecords or misrepresentation of conditions or practices in the supply chain are unacceptable.
4）Intellectual Property
Intellectual property rights shall be respected. Transfer of technology and know-how is to be donein a manner that protects intellectual property rights, and customer and supplier information shallbe safeguarded.
5）Fair Business, Advertising and Competition
Standards of fair business, advertising, and competition shall be upheld.
6）Protection of Identity and Non-Retaliation
Programs that ensure the confidentiality, anonymity, and protection of supplier and employee
whistleblowers2 shall be maintained, unless prohibited by law. Participants shall have acommunicated process for their personnel to be able to raise any concerns without fear of11retaliation.
7）Responsible Sourcing of Mineral
Participants shall adopt a policy and exercise due diligence on the source and chain of custody ofthe tantalum, tin, tungsten, gold, and cobalt in the products they manufacture to reasonably
assure that they are sourced in a way consistent with the Organization for Economic
Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from
Conflict- Affected and High-Risk Areas or an equivalent and recognized due diligence framework.
8）Privacy
Participants shall commit to protecting the reasonable privacy expectations of personal informationof everyone they do business with, including suppliers, customers, consumers, andemployees. Participants shall comply with privacy and information security laws and regulatory
requirements when personal information is collected, stored, processed, transmitted, and shared.
5. MANAGEMENT SYSTEMS
1）Company Commitment
Participants shall establish human rights, health and safety, environmental and ethics policy
statements affirming Participant’s commitment to due diligence and continual improvement,
endorsed by executive management. Policy statements shall be made public and communicated toworkers in a language they understand via accessible channels.
2）Management Accountability and Responsibility
Participants shall clearly identify senior executive and company representative(s) responsible for
ensuring implementation of the management systems and associated programs. Senior
management reviews the status of the management systems on a regular basis.
3）Legal and Customer Requirements
Participants shall adopt or establish a process to identify, monitor and understand applicable laws,
regulations, and customer requirements, including the requirements of this Code.
4）Risk Assessment and Risk Management
Participants shall adopt or establish a process to identify the legal compliance, environmental,
health and safety3, labor practice and ethics risks, including the risks of severe human rights andenvironmental impacts, associated with Participant’s operations. Participants shall determine therelative significance for each risk and implement appropriate procedural and physical controls tocontrol the identified risks and ensure regulatory compliance.
5）Improvement Objectives
Participants shall establish written performance objectives, targets and implementation plans to
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Improve the Participant’s social, environmental, and health and safety performance, including aperiodic assessment of Participant’s performance in achieving those objectives.
6）Training
Participants shall establish programs for training managers and workers to implement Participant’s
policies, procedures, and improvement objectives and to meet applicable legal and regulatory
requirements.
7）Communication
Participants shall establish process for communicating clear and accurate information about
Participant’s policies, practices, expectations, and performance to workers, suppliers, andcustomers.
8）Worker/Stakeholder Engagement and Access To Remedy
Participants shall establish processes for ongoing two-way communication with workers, theirrepresentatives, and other stakeholders where relevant or necessary. The process shall aim to
obtain feedback on operational practices and conditions covered by this Code, and to foster
continuous improvement. Workers shall be given a safe environment to provide grievance andfeedback without fear of reprisal or retaliation.
9）Audits and Assessments
Participants shall conduct periodic self-evaluations to ensure conformity to legal and regulatory
Requirements, the content of the Code, and customer contractual requirements related to socialand environmental responsibility.
10）Corrective Action Process
Participants shall establish a process for timely correction of deficiencies identified by internal orexternal assessments, inspections, investigations, and reviews.
11）Documentation and Records
Participants shall create and maintain documents and records to ensure regulatory complianceand conformity to company requirements along with appropriate confidentiality to protect privacy.
12）Supplier Responsibility
Participants shall establish a process to communicate Code requirements to suppliers and tomonitor supplier compliance to the Code.

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Annex2．Reference Standard Type
1. Responsible Business Alliance（ＲＢＡ）
ＲＢＡ Code of Conduct（RBA Code of Conduct : Version 8.0）
2. Japan Electronics and Information Technology Industries Association(ＪＥＩＴＡ)「Responsible Business Conduct Guidelines」
3. United Nations「United Nations (UN) Guiding Principles on Business and Human Rights」
4. United Nations「Sustainable Development Goals（ＳＤＧｓ）」
5. International Labor Organization (ＩＬＯ)「ILO Declaration on Fundamental Principles and Rights at Work」
6. United Nations「Universal Declaration of Human Rights」
7. United Nations Global Compact「The Ten Principles of the UN Global Compact」

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