Fujitsu General Air Conditioning
UK Limited
Modern Slavery Transparency
Statement
Publication Date: September 12th, 2023
Executive Owner: Hirofumi Fuji

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement September 2023

Page 0 of 8Contents
1.

Introduction .............................................................................................................................................22.

Business, Structure and Supply Chains of FGACUK....................................................................................2

3.

FGG Policies .............................................................................................................................................3

4.

Risks of Modern Slavery Practices ............................................................................................................45.

Due Diligence Processes ..........................................................................................................................66.

Training ...................................................................................................................................................7

7.

Effectiveness............................................................................................................................................78.

Approval ..................................................................................................................................................7

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement September 2023

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1. Introduction
Fujitsu General Air Conditioning UK (FGACUK) acknowledges that acting in line with the UK Modern Slavery
Act (MSA) is of paramount importance to FGACUK and takes its commitment to preventing modern slavery
very seriously.
Section 54 of the UK MSA 2015 requires businesses to disclose information relating to their efforts to assess
and address the risks of modern slavery and human trafficking in their operations and supply chains. The
following Statement responds to these requirements and outlines FGACUK’s efforts to combat modern slavery
during the financial year ended 31 March 2023.
The modern slavery reporting entity is FGACUK with its UK Head Office at Unit 150, Centennial Park, Centennial
Avenue, Elstree, Hertfordshire, WD6 3SG, U.K.

In this Statement, the following notation shall be used.
FGACUK… FUJITSU GENERAL AIR CONDITIONING (UK) LIMITED

FGG…

Fujitsu General Group（Collective name of Fujitsu General Limited and its subsidiaries）

FGL …

Fujitsu General Limited（HQ of Fujitsu General Group）

2. Business, Structure and Supply Chains of FGACUKBusiness
FGACUK purchases air conditioners produced by FGG’s air conditioner manufacturing subsidiaries and sells
them in the UK. FGG’s air conditioners are the result of more than 60 years of advanced design anddevelopment.
FGACUK employs 33 people in the UK. FGACUK procures and imports finished goods and spare parts into theUK and provides post-sales support. FGACUK uses a 3rd party warehouse company for product storage anddelivery, along with its own warehouse for spare part storage. FGACUK sells its products to wholesalers, airconditioner specialists and installers.

Structure
FGACUK is a majority owned subsidiary of Fujitsu General (Euro) GmbH and a minority owned subsidiary ofEurofred S.A (Spain). Fujitsu General (Euro) GmbH is wholly owned by FGL. FGL’s shares are traded on thePrime Market of the Tokyo Stock Exchange (Stock Code: 6755).
FGL is engaged in product and component development, manufacture, sales, and services for air conditioners
and information and communication systems and electronic devices fields. FGL performs product research anddevelopment primarily in Japan. FGL has R&D centres and production plants as its wholly owned subsidiaries
in Thailand and China, where conducting significant product development and most manufacturing activities.
FGL, together with its subsidiary undertakings (including FGACUK) is comprised within the FGG.
In 2021, FGG became a signatory of the United Nations Global Compact (UNGC). The UNGC is an initiative forcompanies that are committed to integrating ten corporate responsibility principles in their business
operations. The ten principles cover the areas of human rights, labour, environment and anti-corruption.
FGG designs, manufactures, distributes, and sells its products primarily using its own personnel and facilities.

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Modern Slavery Statement September 2023

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Supply Chains
Most relevant to the supply chain of FGACUK are the following FGG entities:
••
•
•••

Fujitsu General (Thailand) Co., Limited was established in 1991 and manufactures air conditioners.
Fujitsu General (Thailand) Co., Limited opened its second manufacturing plant in 2019.
Fujitsu General (Shanghai) Co., Ltd was established in 1994 and manufactures air conditioners. It
established an air conditioning technology centre in 2005.
FGA (Thailand) Co., Ltd was established in 1998 to manufacture motors for air conditioners inThailand and commenced manufacturing compressors in 2009.
Fujitsu General Air Conditioning R&D (Thailand) Co., Ltd was established to conduct product andtechnology development in Thailand in 1999 and became a centre for research and development in2016.
Fujitsu General Central Air-Conditioner (Wuxi) Co. Ltd. was established in 2006 as a subsidiary tomanufacture, market, and service VRF air conditioners in China.
Fujitsu General Laboratories Limited was established in 2016 in Japan to replace Fujitsu General
Institute of Air-Conditioning Technology Limited and step up the research and development ofadvanced technologies for FGG.

As at March of 2023 FGL had 1,729 employees and FGG had 8,335 employees.
FGACUK also uses a third party warehouse company for product storage and delivery.

Red Flags and Potential Risk Areas
Modern slavery can take many forms; of most relevance to FGACUK is the risk that manufacturers in the FGG’s
supply chain might use forced labour, debt bondage or child labour. FGACUK recognises the possibility thatmodern slavery practices such as forced labour, debt bondage and child labour may exist in the operations ofservice and parts suppliers in the manufacturing sector that support FGG’s operations in Thailand and China.
The International Labour Organisation (ILO) has estimated that more than 40 million people are in some formof slavery today and that approximately 24.9 million of those are in forced labour. The International
Organisation for Migration estimates that 62% of people living in modern slavery are in the Asia-Pacific region
and that more than US $51.8 billion each year is made in illegal profits in Asia from trafficking in forced labour.
FGACUK recognises that it has independent responsibility to combat modern slavery and has taken steps toimplement the recommendations of the UN Guiding Principles on Business and Human Rights.

3. FGG Policies
FGG’s response to modern slavery is led by FGL’s Corporate Vice President, Toshio Kano, General Manager of
the Sustainability Promotion Division at the Head Office. Day-to-day responsibility for modern slavery withineach subsidiary of FGG sits with the Chief Executive Officer of each subsidiary.
The policies of CSR are created by the Sustainability Promotion Division.
The Sustainability Promotion Division, in cooperation with the Global Procurement Management Division,develops and reviews the CSR Procurement Guidelines and conducts Sustainability Due Diligence by asking toanswer SAQ (Self Assessment Questionnaire) to ensure their effectiveness. The both Divisions will scrutinize
the answers of SAQ from FGG’s factories and their suppliers, and conduct on-site audits as necessary, and thenwill promote corrective actions and improvements through close communication.
The both Divisions are also responsible for the process of monitoring the FGG's CSR activities throughout thesupply chain.
The Sustainability Promotion Division reviewed the CSR Procurement Guidelines for effectiveness andproduced an updated version in August 2020.
As a subsidiary of FGL, FGACUK takes its corporate social responsibilities seriously. FGACUK is required tocomply with FGL policies and regulations, including the Corporate Social Responsibility (CSR) Guidelines (CSR
Procurement Guidelines).

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Fujitsu General Way – Code of Conduct
Ethical behaviour is of the utmost importance to FGACUK and its commitment to instilling this within its
operations begins with the Fujitsu General Way Code of Conduct (hereinafter, “The Code of Conduct”). The
Code of Conduct sets out the expected behaviours of FGACUK people, including to act ethically and to respecthuman rights.

FGG Human Rights Policy
FGG Human Rights Policy defines its commitment to respecting international norms on human rights, such as
The UN Guiding Principles on Business and Human Rights and the ILO Declaration on Fundamental Principles
at Work. This is achieved through exercising due diligence to identify and prevent human rights violations,
implementing redress mechanisms where appropriate, providing education and training to directors andemployees, and being transparent with regard to FGG’s efforts to protect human rights.
In June 2022, FGG revised its human rights policy for the first time in three years, incorporating priority
initiatives such as prohibition of forced labour and child labour, discrimination and harassment, freedom ofassociation and providing a safe, hygienic and healthy working environment. FGG recognizes that respectfor human rights is an important issue, and asks all stakeholders to endorse, understand, and practice FGG's
Human Rights Policy.

CSR Procurement Guidelines
FGG’s CSR Procurement Guidelines are based on the RBA Code of Conduct (version 6.0) and the Responsible
Business Conduct Guidelines of Japan Electronics and Information Technology Industries Association (JEITA).
The CSR Procurement Guidelines applies the principles expressed in the ILO Declaration of Basic Principles andRights in Labour, The Universal Declaration of Human Rights’, The UN Guiding Principles on Business andHuman Rights and The Sustainable Development Goals (SDGs) and United Nations Global Compact "The Ten
Principles of the United Nations Global Compact in Four Fields", adopted by the United Nations.
The CSR Procurement Guidelines specifically prohibit or exclude products, components and minerals that giverise to conflict, forced, bonded, involuntary or exploitative prison labour, slavery, trafficking of persons andchild labour at any stage of the manufacturing plant. It also includes provisions around harassment,
discrimination, inhumane treatment, respecting trade unions and collective bargaining, health & safety,sanitation and grievance mechanisms.
The CSR Procurement Guidelines have been required to be adhered to by all suppliers as well as FGG
subsidiaries worldwide.

4. Risks of Modern Slavery Practices
FGACUK recognises the possibility that modern slavery practices may exist in the operations of service andparts suppliers that support its operations in Thailand and China.
According to the Global Slavery Index issued by The Walk Free Foundation, in 2017 there were more than 62.1
million migrants in the Asia-Pacific region. Migration within the region is most often from developing
countries in the South to the more developed countries in the North. The migrating workers are often unskilled,uneducated or poorly educated and at a significant economic disadvantage in their new work environment.
FGACUK recognises a risk that migrating workers employed in the Asia-Pacific might be subject to high service
fees from recruitment agencies, labour placement organisations and employers. There is a risk that their travel
identity documents may be taken by the labour service provider or employer so that they cannot find adifferent or better paid position. There is also a risk that underage workers may be engaged. In summary,
FGACUK recognises a need to combat the possibility that organisations within its supply chain are using forced
labour, employees are subject to debt bondage or child labour is being used.
The factors listed in the previous paragraph contribute to a risk that individual workers in the rapidly growing
economies of Thailand and China may suffer exploitation in the form of modern slavery.
In terms of prevalence, the Global Slavery Index 2018 gives China a low prevalence rating and Thailand a highprevalence rating, estimating 2.8 victims per thousand and 8.9 victims per thousand respectively (see page

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Page 4 of 831 table 1 of the Asia and the Pacific Report). Although the Global Slavery Index gave China a low prevalence
rating in 2018, recent news articles about Uyghur forced labour in Xinjiang suggest that the prevalence ofmodern slavery could be higher than the 2018 rating. China has also been found to have the highest absolute
number of people living in modern slavery.
On page 34 (table 2) Thailand and China have similar ratings of 51.1 and 50.6 in terms of vulnerability tomodern slavery by country, ranked 12th and 13th, respectively. However, it should be noted that Thailand’shigh rating is partly a result of the conflict in Thailand’s southern border. FGG does not have any facilities insuch Thailand’s provinces. Thailand and China are ranked 5th and 20th respectively in the region based on eachcountry’s government response to issues associated with modern slavery between 2016 and 2018.
FGACUK notes that laptops, computers and mobile phones manufactured in China are the top-rated categoryof product at risk of modern slavery, according to table 3 of the Global Slavery Index report. Although FGACUK
does not import or sell laptops, computers or mobile phones, the manufacturing processes associated withconsumer electronics is considered analogous to processes used to construct air-conditioners, and therefore
FGACUK recognises a potential risk in the manufacture of such products.

FGG Manufacturing Facilities
The table below summarises the source of components across FGL’s manufacturing facilities:

The table below is a summary of the source of components across all manufacturing facilities:

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Modern Slavery Statement September 2023

Page 5 of 85. Due Diligence Processes
OperationsFGCACUK performs background checks on all employees, including identity verification, to confirm age andplace of residence. The Rules of Employment stipulates the minimum age for employees employed by theCompany.
A corporate ethics helpline has been established and is in operation. The helpline is available to any directors
and employees who work for FGG (including FGACUK), contract employees, loaned employees and temporary
staff who come across unethical business conduct or behaviour, including suspected instances of modernslavery. Reporting through the corporate ethics helpline can be made anonymously. Employees are madeaware of the helpline through the internal portal and via regular emails.
FGG responsibly investigates the risks of modern slavery.
In FY2022, FGG conducted Sustainability Due Diligence (by SAQ), including human rights, for two of its
factories in China. FGG plans to conduct Sustainability Due Diligence at its each site promptly in the future.
In addition, FGG plans to establish a whistle-blowing mechanism at FGL to serve as a contact point for externalparties, including primary suppliers in Japan. The FGG's whistle-blowing mechanism provides a system(Including No Retaliation Clause) for the appropriate handling of reports and consultations regarding
compliance violations.

Supply Chain
Adherence to CSR Procurement Guidelines
Since November 2019, suppliers of FGG are asked to agree to the CSR Procurement Guidelines prior to onboarding. For suppliers on-boarded prior to November 2019, consent was obtained after on-boarding once
again. As of March 31, 2023, 1,124 out of 1,171 suppliers signed up, using the CSR Procurement Guidelines
consent confirmation form. Of the suppliers that have signed up using the guidelines, 669 are in Japan, 279
are in China and 176 are in Thailand. FGG’s top 10 suppliers by procurement amount have agreed to comply
with the CSR Procurement Guidelines.
Commencing in November of 2019, FGL assessed suppliers for compliance with the CSR Procurement
Guidelines. The CSR Procurement Guidelines set criteria for the evaluation and selection of suppliers.

Supplier audits
FGG selects suppliers for audits by prioritizing them based on the transaction amount, importance to thebusiness, country risk, and relationship with the supplier.
The Sustainability Promotion Division and Global Procurement Management Division prepare and implement
the rules for audits:

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Modern Slavery Statement September 2023

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Before suppliers are audited, they are requested to answer SAQ.

•Then, under the direction of the both Divisions, the department in charge of each plant conducts onsite audits and compares the answers of SAQ with the results of the on-site audits.

•Based on the results, the department in charge of each factory will provide improvement andcorrective guidance to each supplier.

The aim of SAQ, CSR Procurement Guidelines and on-site audits is to work with suppliers to improve theircompliance and performance over time by creating an opportunity for improvement and providing support tosuppliers that are willing to invest and improve.
FGG planned to conduct 12 times on-side audits in the fiscal year 2022, and conducted on-site audits for 14
suppliers in China actually. FGG plans to conduct more extensive on-site audits in FY2023, as monitoring theimpact of Covid-19.
FGG has not identified any cases of modern slavery in its operations or supply chain through its reviews andaudits to-date.

6. Training
All directors and employees receive training on human rights via e-learning as part of the Fujitsu General Way
Code of Conduct training (“The Code of Conduct”). The Code of Conduct is communicated to all directors andemployees at least once a year. FGG use internal controls to monitor the compliance of its employees, and in
the case of non-compliance FGG act in accordance with the Employment Regulations.
Commencing in November of 2019, FGG started to provide CSR Procurement Guidelines training for suppliers,
to introduce and explain the CSR initiatives and guidelines. Briefing sessions have been held for suppliers
across Japan, China and Thailand.
In FY2022, FGL also conducted an e-learning course on human rights by expert video delivery to provide all
directors and employees with basic knowledge and awareness of "business and human rights" from a global
perspective, and to encourage them to think about human rights issues as "their own issue" and act.

7. Effectiveness
FGACUK recognises that the review and assessment of its actions to identify and address modern slavery risks
across its operations and supply chain will be an ongoing and evolving process. FGG uses the following Key
Performance Indicators (KPI’s) to better understand the effectiveness of its approach to managing modernslavery risks:
1) Ensuring all suppliers have signed up to the CSR Procurement Guidelines – 95% have signed up so far2) Conducting Sustainability Due Diligence (by SAQ) – FGL conducted Sustainability Due Diligence to two
factories in China.
3) Conducting on-site audits in China – Target number of suppliers per year: 12 companies, Actual FY2022: 14companies
In 2023, FGG plans to work with the relevant departments towards meeting its KPIs and implement a new
Policy clarifying that FGG does not tolerate child labour or forced labour in its supply chains.
Over subsequent reporting periods, FGG will continue to review and evaluate these KPIs and develop future
metrics to assess the effectiveness of its actions, and enhance its monitoring over time, in line with continuous
improvement.

8. Approval
This Modern Slavery Transparency Statement for the year ended March 31, 2023 has been approved by theBoard of Directors of FGACUK, on September 12th, 2023.
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