Fujikura GroupCSR Procurement Guidelines

Aug 5, 2021

Version 5.0

Fujikura Ltd.
Corporate Communication Division
Procurement DivisionTable of Contents
Request to Our Suppliers ······························································································· 1
Ⅰ. Fujikura Group Basic Procurement Policies ··································································· 2
Ⅱ. Fujikura Group Policy on Human Rights········································································ 3
Ⅲ. Fujikura Group CSR Procurement Guidelines ································································ 4
A． Labor ················································································································ 41）Freely Chosen Employment
2）Young Workers3）Working Hours
4）Wages and Benefits5）Humane Treatment
6）Non-Discrimination
7）Freedom of Association
B． Health and Safety ·································································································· 51）Occupational Safety
2）Emergency Preparedness3）Occupational Injury and Illness4）Industrial Hygiene5）Physically Demanding Work
6）Machine Safeguarding7）Sanitation, Food, and Housing
8）Health and Safety Communication
C． Environmental ······································································································ 71）Environmental Permits and Reporting2）Pollution Prevention and Resource Reduction3）Hazardous Substances
4）Solid Waste
5）Air Emissions
6）Materials Restrictions7）Water Management
8）Energy Consumption and Greenhouse Gas Emissions
9) Biodiversity Conservation
D． Ethics ················································································································· 81）Business Integrity2）No Improper Advantage
3）Abuse of Superior Bargaining Position
4）Disclosure of Information5）Intellectual Property6）Fair Business, Advertising and Competition7）Protection of Identity and Non-Retaliation
8) Prevention and Early Detection of Fraud
9）Responsible Sourcing of Mineralsi10）Privacy
E． Management Systems ··························································································· 101）Company Commitment2）Management Accountability and Responsibility3）Legal and Customer Requirements
4）Risk Assessment and Risk Management
5）Improvement Objectives6）Training
7）Communication8）Worker Feedback, Participation and Grievance9）Audits and Assessments10）Corrective Action Process11）Documentation and Records12）Supplier Responsibility
F． Additional Provisions ····························································································· 121）Export Control2）Product Safety3）Quality Management System
4）Defense Against Computer Network Threats5）Contributions to the International Community and Local CommunitiesiiRequest to Our Suppliers
In recent years, companies are facing a drastically changing environment caused by the globalizationof corporate activities and the maturation of information society, among other factors. There has been aspate of corporate scandals and strong criticism of dishonest corporate activities. As a result, there is
growing awareness in society toward companies’ efforts for the formation of a sustainable society.
In this environment, as a member of society, companies are expected to actively fulfill not only theirduties toward legal compliance but also their responsibilities to society as a whole through corporate
activities. In other words, companies are expected to fulfill their corporate social responsibilities (CSR).
Fujikura group strictly controls its own actions through the establishment of rules such as the FujikuraGroup Procurement Basic Policy and the Fujikura Group Procurement Purchasing Division Code of
Conduct, in order to establish a solid relationship of trust with its business partners through fair, equitable
and honest procurement activities. Fujikura group is also committed to compliance and each affiliatedcompany participates and regularly conducts training sessions on Japan’s subcontractor act.
Fujikura group has established the Fujikura Group Policy on Human Rights, through which we promoterespect for all forms of human rights acknowledged internationally and respect for all people affected byour business activities globally. The policies presented below cover all of Fujikura group’s suppliers andrequire that suppliers engage in activities that respect human rights.
With corporate activities becoming more global, companies are now under the microscope when it
comes to not only their own social responsibilities, but also those in their entire supply chain. Fujikura
conducts a supply chain management questionnaire and makes information known through the FujikuraGroup Partners Meeting, including asking suppliers to comply with the Responsible Business Alliance®
(RBA®) Code of Conduct. Nevertheless, we would like to further reinforce our system of cooperation,and therefore, we have revised and published the Fujikura Group CSR Procurement Guidelines to be
in conformity with RBA standards.
Conventionally, CSR is addressed independently by each company. Fujikura, however, asks that its
suppliers to actively engage in CSR activities after referencing these guidelines.
These Guidelines conform to the RBA Code of Conduct 7.0.

Ⅰ. Fujikura Group Basic Procurement Policies
Est. December, 2013
1. Fair and Level Trade
Fujikura Group Companies open doors worldwide for suppliers. We will provide equal opportunity withpotential suppliers and encourage free competition. We evaluate them through fair and soundassessment process for price, quality, delivery, stable supply, technological competence and reliability.
2. Collaborative Relationship with Suppliers Based on Mutual Trust
Fujikura Group Companies keep faith and honesty to suppliers. We always endeavor to develop
collaborative, mutually-beneficial relationship with suppliers based on mutual trust. We do not disclose
any information obtained through business with suppliers to third parties without prior consent.
3. Compliance with Laws, Regulations and Social Norms
Fujikura Group Companies comply with not only relevant laws and regulations but also conducttransactions in accordance with business ethics and social norms in the countries and regions where
we are doing business.
4. Environmental Preservation
Fujikura Group companies strive for environmental management program designed to minimize theimpact on the environment together with our suppliers in order to contribute to preservation of global
environment and realization of sustainable society.

2Ⅱ. Fujikura Group Policy on Human Rights
Est. January, 2017
1. Respect for International Standards
The Fujikura Group shall support and respect international standards for human rights that constituteinternationally adopted and agreed upon universal values, including the International Bill of Human
Rights, which sets forth the basic human rights to be enjoyed by all people in the world, and theInternational Labour Organization's Declaration on Fundamental Principles and Rights at Work, whichsets forth fundamental rights at work.
In addition, we shall frame this Policy based on the Guiding Principles on Business and Human Rights,
established by the UN, to develop further initiatives toward respecting human rights.
2. Responsibility for Respecting Human Rights
The Fujikura Group shall meet our responsibility to respect human rights by taking appropriate
measures (remedies, prevention, and mitigation) for rectification if it is evident that our businessactivities cause or promote adverse impacts concerning the human rights of people.
The Fujikura Group shall appoint a person in charge of implementing this Policy, and that person shallassume responsibility for supervising compliance with this Policy.
3. Scope of Application
This Policy applies to all officers and employees (i.e., all staff members including regular employees,
contract workers, and temporary employees). In addition, if adverse impacts on human rights caused abusiness partner or other such related party are shown to be connected directly with our businessactivities, we shall request said party to take measures to respect rather than infringe upon humanrights.
4. Compliance with Applicable Laws and Regulations
The Fujikura Group shall comply with laws, regulations, and restrictions applicable in respective
countries and regions where the Group conducts its business activities. If there is a contradiction
between internationally accepted principles on human rights and the laws and regulations of any
country or region, we shall respect the internationally accepted principles on human rights, while being
as considerate of the laws and regulations of each country and region as possible.
5. Human Rights Due Diligence
Based on the UN Guiding Principles on Business and Human Rights, The Fujikura Group shallcontinuously carry out human rights due diligence in order to identify, prevent, and reduce potential
and actual adverse impacts on human rights that our business activities might have. The process ofhuman rights due diligence shall include assessing actual and potential human rights impacts,
integrating and acting upon the findings, tracking responses, and communicating how such impacts
are being addressed.
The Fujikura Group shall carry out its human rights due diligence constantly, recognizing that humanrights risks may change over time as business operations change.
6. Promotion
The Fujikura Group shall provide appropriate education for all officers and employees and raise theirawareness on a continuous basis, so that this Policy and our human rights due diligence will be fully
understood and effectively implemented in overall business activities.
7. Dialogue and Consultation
In the implementation of this Policy, the Fujikura Group shall utilize external expertise in human rights.
At the same time, the Fujikura Group shall hold dialogues and consultations with stakeholders who
may be directly affected by actual and potential adverse impacts on human rights caused by ourbusiness activities, and seek efforts toward improvement.
8. Disclosure of Information
In order to meet accountability for this Policy, the Fujikura Group shall report the status of all work on
relevant measures in reports on Corporate Social Responsibility (CSR) and on our corporate websites.

3III. Fujikura Group CSR Procurement Guidelines
A. Labor
In 2017, the Fujikura Group established the Fujikura Group Policy on Human Rights, which requiresthat we all respect human rights across our entire supply chain, including by suppliers. The following
CSR Procurement Guidelines on human rights and labor were established based on this policy.
Suppliers must be committed to uphold the human rights of workers, and to treat them with dignity andrespect as understood by the international community. This applies to all workers including dispatch,migrant, student, contract, direct employees, and any other type of worker.

1）Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labor, involuntary or exploitative prison
labor, slavery or trafficking of persons shall not be used. This includes transporting, harboring,
recruiting, transferring or receiving persons by means 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 companyprovided facilities.
As part of the hiring process, all workers must be provided with a written employment agreementin their native language that contains a description of terms and conditions of employment.
Foreign migrant workers must receive the employment agreement prior to the worker departingfrom his or her country of origin and there shall be no substitution or change(s) allowed in theemployment agreement upon arrival in the receiving country unless these changes are made tomeet local law and provide equal or better terms.
All work must be voluntary, and workers shall be free to leave work at any time or terminate theiremployment without penalty if reasonable notice is given as per worker’s contract. Employers andagents may not hold or otherwise destroy, conceal, confiscate or deny access by employees totheir identity or immigration documents, such as government-issued identification, passports orwork permits, unless such holdings are required by law. Workers shall not be required to pay
employers’ or agents’ recruitment fees or other related fees for their employment. If any such fees
are found to have been paid by workers, such fees shall be repaid to the worker.

2）Young Workers
Child labor is not to 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 theminimum age for employment in the country, whichever is greatest. Suppliers shall implement anappropriate mechanism to verify the age of workers. The use of legitimate workplace learning
programs, which comply with all laws and regulations, is supported. Workers under the age of 18(Young Workers) shall not perform work that is likely to jeopardize their health or safety, includingnight shifts and overtime. When employing student workers, proper management of student
workers shall be ensured through proper maintenance of student records, rigorous due diligenceof educational partners, and protection of students’ rights in accordance with applicable law andregulations. Appropriate support and training shall be provided to all student workers.
In the absence of local law, the wage rate for student workers, interns and apprentices shall be atleast the same wage rate as other entry-level workers performing equal or similar tasks. If childlabor is identified, assistance/remediation is provided.

3）Working Hours
Studies of business practices clearly link worker strain to reduced productivity, increased turnoverand increased injury and illness. Working hours are not to exceed the maximum set by local law.
Further, a workweek should not be more than 60 hours per week, including overtime, except inemergency or unusual situations. Workers shall be allowed at least one day off every seven days.

4Overtime work must be performed voluntarily by workers and workers shall be compensated forovertime at pay rates greater than regular hourly rates.

4）Wages and Benefits
Compensation paid to workers shall comply with all applicable industry standards and wage laws,
including those relating to minimum wages, overtime hours and legally mandated benefits.
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 statement that includes
sufficient information to verify accurate compensation for work performed. All use of temporary,dispatch and outsourced labor will be within the limits of the local law.
Suppliers must pay a living wage that supports the basic needs of employees and theirdependents, which must be in an amount where employees have disposable income.

5）Humane Treatment
There is to 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.
Disciplinary policies and procedures in support of these requirements shall be clearly definedand communicated to workers.

6）Non-Discrimination
Suppliers should be committed to a workforce free of harassment and unlawful discrimination.
Companies shall not engage in discrimination based on race, color, age, gender, sexual
orientation, gender identity and 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. Workers shall be provided with reasonable accommodation for
religious practices. In addition, workers or potential workers should not be subjected to medical
tests or physical exams that could be used in a discriminatory way. This was drafted inconsideration of ILO Discrimination (Employment and Occupation) Convention (No.111).

7）Freedom of Association
In conformance with local law, suppliers shall respect the right of all workers to form and jointrade unions of their own choosing, to bargain collectively and to engage in peaceful assembly aswell as respect the right of workers to refrain from such activities. Workers and/or theirrepresentatives 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.

B. Health and Safety
Fujikura recognizes that in addition to minimizing the incidence of work-related injury and illness, asafe and healthy work environment enhances the quality of products and services, consistency of
production and worker retention and morale. Fujikura also recognize that ongoing worker input andeducation are essential to identifying and solving health and safety issues in the workplace.
Recognized management systems such as ISO 45001and ILO Guidelines on Occupational Safety and
Health were used as references in preparing these Guidelines and may be a useful source ofadditional information.

1）Occupational Safety
Worker potential for exposure to safety hazards (e.g., chemical, electrical and other energy
sources, fire, vehicles, and fall hazards, etc.) are to be identified and assessed, mitigated using
the Hierarchy of Controls, which includes eliminating the hazard, substituting processes or5materials, controlling through proper design, implementing engineering and administrative
controls, preventative maintenance and safe work procedures (including lockout/tagout), andproviding ongoing occupational health and safety training. Where hazards cannot be adequately
controlled by these means, workers are to be provided with appropriate personal protective
equipment and educational materials about risks to them associated with these hazards.
Reasonable steps must also be taken to remove pregnant women from working condition withhigh hazards, to remove or reduce any workplace health and safety risks, as well as include
reasonable accommodations.

2）Emergency Preparedness
Potential emergency situations and events are to 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 must be executed at least annually or as required by local law, whichever ismore stringent. Emergency plans should 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 are to be in place to prevent, manage, track and report occupational
injury and illness 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 return of workers to work.

4）Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified, evaluated, andcontrolled according to the Hierarchy of Controls. If any potential hazards were identified,participants shall look for opportunities to eliminate and/or reduce the potential hazards. If
elimination or reduction of the hazards is not feasible, potential hazards are to be controlled
through proper design, engineering, and administrative controls. When hazards cannot beadequately controlled by such means, workers are to be provided with and use appropriate, wellmaintained personal protective equipment free of charge. Protective programs shall include
educational materials about the risks associated with these 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 is to be identified, evaluated and controlled.

6）Machine Safeguarding
Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks
and barriers are to be provided and properly maintained where machinery presents an injury
hazard to workers.

7）Sanitation, Food, and Housing
Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary
food preparation, storage, and eating facilities. Worker dormitories provided by suppliers or alabor agent are to be maintained to be clean and safe, and provided with appropriate emergency
egress, hot water for bathing and showering, adequate lighting and heat and ventilation,individually secured accommodations for storing personal and valuable items, and reasonable
personal space.

8）Health and Safety Communication
Suppliers 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

6

in the facility or placed in a location accessible by workers. Training shall be provided to all
workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged toraise any health and safety concerns without retaliation.

7

C. Environmental
Environmental responsibility is important and indispensable to manufacturing. In manufacturing
operations, adverse effects on the community, environment and natural resources are to be minimized
while safeguarding the health and safety of the public. Suppliers are asked to review the website
below to learn more about the Fujikura group’s green procurement practices.
URL : https://www.fujikura.co.jp/eng/esg/environmental/green.html
Recognized management systems such as ISO 14001 and the Eco Management and Audit System(EMAS) were used as references in preparing these Guidelines and may be a useful source ofadditional information.

1）Environmental Permits and Reporting
All required environmental permits, approvals and registrations are to be obtained, maintained
and kept current and their operational and reporting requirements are to be followed.

2）Pollution Prevention and Resource Reduction
Emissions and discharges of pollutants and generation of waste are to be minimized oreliminated 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, is to be conserved or by practices
such as modifying production, maintenance and facility processes, materials substitution, re-use,conservation, recycling or other means, fully considerate of biodiversity.

3）Hazardous Substances
Chemicals and other materials posing a hazard to humans or the environment must be identified,appropriately labelled and managed to ensure their safe handling, movement, storage, use,
recycling and disposal.

4) Solid Waste
Suppliers must implement a systematic approach to identify, manage, reduce, and responsibly
dispose of or recycle solid waste (non-hazardous).

5）Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depletingchemicals and combustion by-products generated from operations must be characterized,
routinely monitored, controlled and treated as required prior to discharge. Ozone-depleting
substances are to be effectively managed in accordance with the Montreal Protocol andapplicable regulations. Suppliers shall conduct routine monitoring of the performance of their own
air emission control systems.

6）Materials Restrictions
Suppliers must adhere to all applicable laws, regulations and customer requirements regarding
prohibition or restriction of specific substances in products and manufacturing, including labelingfor recycling and disposal.

7）Water Management
Suppliers 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 is to be characterized, monitored, controlled, andtreated as required prior to discharge or disposal. Suppliers must conduct routine monitoring of
the performance of their own wastewater treatment and containment systems to ensure optimal
performance and regulatory compliance.

8）Energy Consumption and Greenhouse Gas Emissions
Suppliers are to establish a corporate-wide greenhouse gas reduction goal. Energy consumption
and all relevant Scopes 1 and 2 greenhouse gas emissions are to be tracked, documented, and8

publicly reported against the greenhouse gas reduction goal. Suppliers are to look for methods toimprove energy efficiency and to minimize their energy consumption and greenhouse gas
emissions.

9）Biodiversity Conservation
Suppliers must be aware of the fauna and flora and habitats in the vicinity of their businessactivities, establish plans to give utmost consideration to survival of these lifeforms, and engage
in activities to curtail any impacts on biodiversity.
Impacts on biodiversity include the following examples:・ Air pollution: Impacts on ecosystems in the vicinity caused by air pollution from exhaust gas
or chemical substances.
・ Water pollution: Impacts on ecosystems of downstream regions caused by the discharge of
effluent.
・ Climate change: Impacts on ecosystems associated with climate change and acceleration inloss of species.
・ Loss of habitat: Use of land for plant construction.
・ Loss and transfer of species: Impacts of climate change or transfer of species associatedwith transport of raw materials or products.

Suppliers are asked to review the following website on the Fujikura group’s efforts to prevent
impacts on biodiversity.
URL:https://www.fujikura.co.jp/eng/esg/environmental/biodiversity.html

D. Ethics
To meet social responsibilities and to achieve success in the marketplace, suppliers are to uphold thehighest standards of ethics including:1）Business Integrity
The highest standards of integrity are to be upheld in all business interactions. Suppliers shallhave 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 are not to 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）Abuse of Superior Bargaining Position
Abuse of a superior bargaining position refers to using a position as purchaser or outsourcer tounilaterally decide or change transactional conditions with suppliers or levy unreasonable
demands or obligations on suppliers.
Procurement transactions must be carried out honestly and fairly based on contracts, and actions
such as those that abuse a superior bargaining position are forbidden. In countries with laws or
regulations on abuse of a superior bargaining position, suppliers must follow these laws andregulations (e.g. the subcontractor act in Japan, etc.)

94）Disclosure of Information
All business dealings should be transparently performed and accurately reflected on the
suppliers’ business books and records. Information regarding supplier labor, health and safety,
environmental practices, business activities, structure, financial situation and performance is to bedisclosed in accordance with applicable regulations and prevailing industry practices. Falsificationof records or misrepresentation of conditions or practices in the supply chain are unacceptable.

5）Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know- how is to bedone in a manner that protects intellectual property rights; and, customer and supplier information
is to be safeguarded.
An intellectual property refers to patent rights, utility model rights, design rights, trademarks,
copyrights, and trade secrets, etc.
Suppliers must fully investigate in advance the intellectual properties of third parties in case ofdeveloping, producing, selling, or providing a product or service.
The following actions shall be considered an infringement of intellectual property rights.
・ Unauthorized use of a third-party’s intellectual property, except with reasonable grounds.
・ Illegal reproduction of computer software or other copyrighted works, etc.
・ Obtaining and using the trade secrets of a third-party obtained illegally.

6) Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld.
Actions that inhibit competition include agreeing to set the price, quantity, or sales region of
products or services with other companies in the same industry (cartel) and when bidders
determine the successful bidder or successful bid price (bid rigging), etc.
Obtaining and using the trade secrets of another company illegally, falsifying representations
concerning other companies’ products, and using representations that cause customer
misunderstanding, etc., are examples of unfair competition.
In representations or advertisements for products or services such as catalogues, suppliers must
not use expressions differing from the facts or expressions that cause customers to
misunderstand the content. Such representations or advertisements must not contain slander ofanother company or person or infringe upon the rights of others.

7）Protection of Identity and Non-Retaliation
Programs that ensure the confidentiality, anonymity and protection of supplier and employee
whistleblowers2 are to be maintained, unless prohibited by law. Suppliers should have acommunicated process for their personnel to be able to raise any concerns without fear of
retaliation.
2

Whistleblower definition: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official
body.

8) Prevention and Early Detection of Fraud
Activities for the prevention and early detection of fraud involve worker training, raisingawareness, and creating an open workplace culture.
Suppliers will set up a whistleblower hotline either inside or outside the company for reporting
fraud and suppliers’ management will strive to detect fraud at an early stage. Suppliers shallsafeguard the confidentiality of whistleblowers and protect them as appropriate. Fraud must be
dealt with promptly and the results reported to the whistleblower as needed.

109）Responsible Sourcing of Minerals
Suppliers must source minerals responsibly across the entire supply chain, especially in conflictzones and high risk countries, knowing the risks including human rights violations or labor issues
locally and recognizing that these risks and issues are considered a major social issue. Suppliers
shall have a policy on the responsible sourcing of minerals and take actions to increase thetransparency of their supply chain.
Suppliers shall exercise due diligence on the source and chain of custody of these minerals andmake their due diligence measures available to customers upon customer request.
Fujikura group’s initiatives for the responsible sourcing of minerals can be found on the following
website.
URL : https://www.fujikura.co.jp/eng/esg/governance/procurement.html10）Privacy
Suppliers are to commit to protecting the reasonable privacy expectations of personal informationof everyone they do business with, including suppliers, customers, consumers and employees.
Suppliers are to comply with privacy and information security laws and regulatory requirements
when personal information is collected, stored, processed, transmitted, and shared.

Personal information refers to the information of a living person that can be used to identify a
specific individual based on name, date of birth or other descriptions in said information.
Appropriate management refers to building and operating a mechanism for overall control of
personal information, preparation of regulations or policies for employees, etc., including
planning, implementation, audits and reviews associated with such.
Appropriate protection refers to not collecting, using, disclosing or divulging personal
information illicitly or unjustly.

E.

Management Systems

Suppliers shall adopt or establish a management system whose scope is related to the content ofthese Guidelines. The management system shall be designed to ensure:(a) Compliance with applicable laws, regulations and customer requirements related to the
supplier’s operations and products;(b) Conformance with these Guidelines; and(c) Identification and mitigation of operational risks related to these Guidelines.
It should also facilitate continual improvement of this management system.

1)

Company Commitment
A corporate social and environmental responsibility policy statements affirming the supplier’s
commitment to compliance and continual improvement, endorsed by executive management andposted in the facility in the local language.

112）Management Accountability and Responsibility
The supplier clearly identifies 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 system on a regular basis.

3）Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations and customer
requirements, including the requirements of these Guidelines.

4）Risk Assessment and Risk Management
A process to identify the legal compliance, environmental, health and safety3 and labor practiceand ethics risks associated with the supplier’s operations. Determination of the relative
significance for each risk and implementation of appropriate procedural and physical controls tocontrol the identified risks and ensure regulatory compliance.
3

To be included in a risk assessment for environmental health and safety are production areas, warehouse and storage facilities, plant/facilities support equipment,laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker housing/dormitories.

5）Improvement Objectives
Written performance objectives, targets and implementation plans to improve the supplier’s socialand environmental performance, including a periodic assessment of the supplier’s performance inachieving those objectives.

6）Training
Programs for training managers and workers to implement the supplier’s policies, procedures andimprovement objectives and to meet applicable legal and regulatory requirements.

7）Communication
Mechanisms must be in place for communicating clear and accurate information about the
supplier’s policies, practices, expectations and performance to workers, suppliers and customers.

8）Worker Feedback, Participation and Grievance
Mechanisms must be in place to assess employees’ understanding of and obtain feedback on or
violations against practices and conditions covered by these Guidelines and to foster continuous
improvement.

9）Audits and Assessments
Periodic internal audits and self-evaluations to ensure conformity to legal and regulatory
requirements, the content of these Guidelines and customer contractual requirements related tosocial and environmental responsibility.

10）Corrective Action Process
A process for timely correction of deficiencies identified by internal or external assessments,
inspections, investigations and reviews.

11）Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance andconformity to customer requirements along with appropriate confidentiality to protect privacy.

12）Supplier Responsibility
A process must be in place to communicate Guideline requirements to suppliers and to monitor
supplier compliance with the Guidelines.

12F. Additional Provisions1）Export Control
Suppliers must have a clear management system in place for the export of technologies or goods
regulated by law and export these items only after carrying out the appropriate procedures.
Technologies or goods regulated by law refers to components, products, technologies, facilities
and software, etc., for which exports are restricted under international agreements such as the
Wassenaar Arrangement.
The export of these technologies and goods may require approval of supervisory agencies.

2）Product Safety
Suppliers engaging in product design are to ensure that product safety requirements set forth ineach countries’ laws and regulations are met.
When engaging in product design, suppliers must create a design that ensures adequate productsafety and sell such designs full considerate of their responsibility as a manufacturer. For productsafety, normally required safety features as well as compliance with laws are to be considered.
Examples of laws and regulations concerning product safety in Japan include the Electrical
Appliance Safety Act, the Consumer Product Safety Act, and the Household Product Quality
Labeling Act. Safety standards are set forth in the by-laws of these acts or Japan Industrial
Standards (JIS). In addition, international safety standards include UL, BS, and CSA, etc.
The assurance of product safety must include prompt response to problem solving andmanagement, such as traceability (history of materials, components, processes, etc.).

3）Quality Management System
A quality management system refers to a system for the total control of quality assurance activities.
This system must encompass organizational structure, systematic activities, accountability,
practices, procedures, processes and management resources. Quality assurance activities refers
to preparing a policy on quality as well as implementing, achieving, reviewing and maintaining
measures following this policy. The plan-do-check-action (PDCA) cycle must also be implemented
to ensure continuous improvement in quality assurance.
Quality management systems including the ISO 9000 family, IATF 16949, and ISO 13485, etc.

4）Defense Against Computer Network Threats
Suppliers must implement measures to safeguard against computer network threats and implement
controls prevent damages from being incurred by the supplier or others. Computer network threatsrefer to computer viruses, computer worms, and spyware, etc.
If a computer connected to the Internet becomes infected with a computer virus, this could lead tothe loss of customer information or confidential information stored therein, or could result in an
attack on the computers of other companies, resulting in serious damages including lost businessand loss of credibility. As such, it is important for suppliers to implement measures against
computer network threats to prevent impacts both internally and externally.

5）Contributions to the International Community and Local Communities
Activities that contribute to the international community and local communities refer to activities
supporting the community that utilize a company’s management resources and generally indicatesthe following initiatives.
・ Social contributions utilizing conventional operations or technologies
・ Non-monetary social contributions utilizing facilities or people
・ Social contributions by means of monetary donations

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Specifically, examples of these activities include collaboration with the community during adisaster, employee volunteering, support for NPOs/NGOs, donations, and various forms of
information sharing or provision. Each individual supplier is to actively engage in social
contributions after determining the feasible scope of their own activities.

Corporate Communication Division
Procurement Division
Fujikura Ltd.

*These Guidelines are subject to change without notice. Please see Fujikura’s corporate website for thelatest information.

Document Revision History
Version
1.0

Date
June 20, 2016

2.0
3.0
4.0
5.0

June 1, 2017
May 14, 2018
May 28, 2019
Aug 5, 2021

Details of revisions
Establishment of CSR Procurement Guidelines andpreparation of first version
Name of issuing department changed
Revision following the name change of EICC
Revisions for conformity with RBA
Revisions for conformity with RBA Code of Conduct 7.0.

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