Furukawa Electric GroupCSR Procurement Guideline 3rd edition

February 2021
FURUKAWA ELECTRIC CO., Ltd.

Introduction
Based on the basic philosophy of "Drawing on more than a century of expertise in thedevelopment and fabrication of advanced materials, we will contribute to the realization of asustainable society through continuous technological innovation.", the Furukawa Electric Groupis promoting ESG management with the aim of improving corporate value (Financial and social
values) over the medium to long term based on ESG (Environment, Society and Governance ).
In addition to being responsible for legal compliance, it is also necessary for a company to fulfill
its social responsibility through its corporate activities as a member of society, not to mention its
responsibility to comply with laws and regulations. In other words, it is necessary to actively
engage in "Corporate Social Responsibility (CSR)". Our Group has established the "Furukawa
Electric Group Basic Policy on CSR " as well as "Furukawa Electric Group CSR Code of Conduct"and engages in CSR activities based on this policy and the Code of Conduct.
In order to promote CSR activities with the aim of achieving ESG management, it is necessary
to work not only within the group but also throughout the entire supply chain, including our
suppliers. Our group has formulated the "Furukawa Electric Group Procurement Policy" andthe "Furukawa Electric CSR Deployment Guidelines for Business Partners " to encourage our
suppliers to promote CSR activities.
In recent years, there has been an increasing demand for companies to take measures to createa sustainable society, including the diversification of the business environment, such as theglobalization of corporate activities and the development of an information society, and the harshevaluation of corporate activities by society. In addition, there are major changes in theinternational environment, such as decarbonization of global warming, efforts to protect thehuman rights of workers, and pandemics caused by infectious diseases.
In response to the changing and growing social demands for CSR, we have revised the"Furukawa Electric CSR Deployment Guidelines for Business Partners " and renamed it the"Furukawa Electric Group CSR Procurement Guideline" in order to further promote CSR
activities together with our suppliers.
Furukawa Electric Group calls its suppliers as “Business Partners”, because they are not only
"Suppliers" who supply products and services, but also "Partners" who create value together.
However, in this guideline, please note that the term “Suppliers” is used to make it easier tounderstand.
We would like to ask our suppliers for their understanding and support of this guideline, as
well as for their suppliers to be informed and promote CSR activities.
About Furukawa Electric Group CSR Procurement Guideline:
Based on "Furukawa Electric Group Basic Policy on CSR ", "Furukawa Electric Group CSR Codeof Conduct", and "Furukawa Electric Group Procurement Policy", this guideline summarizes theapproaches and details which the Furukawa Electric Group expects its suppliers to comply withand work on referring to the Code of Conduct of RBA (Responsible Business Alliance), which isa corporate organization that promotes CSR in the supply chain, "Responsible Business Conduct
Guidelines " of the Japan Electronics and Information Technology Industries Association

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(JEITA) and other publications.
・“Furukawa Electric Group Basic Policy on CSR”, "Furukawa Electric Group CSR Code of
Conduct", “Furukawa Electric Group Human Rights Policy”
https://furukawaelectric.disclosure.site/en/themes/114
・ “Furukawa Electric Group Procurement Policy”
https://www.furukawa.co.jp/en/procure/standard.html
・ “Responsible Business Alliance (RBA) Code of Conduct”
http://www.responsiblebusiness.org/media/docs/RBACodeofConduct7.0_English.pdf
・Japan Electronics and Information Technology Industries Association（JEITA）"Responsible
corporate behavior guidelines"
https://www.jeita.or.jp/cgi-bin/public/detail.cgi?id=788&cateid=12

Contents
１ LABOR .............................................................................................................................. 4
１－１ Freely Chosen Employment .................................................................................. 4
１－２ Young Workers ....................................................................................................... 4
１―３ Working Hours ....................................................................................................... 5
１－４ Wages and Benefits ................................................................................................ 5
１－５ Humane Treatment................................................................................................ 5
１－６ Non-Discrimination/Non Harassment .................................................................. 5
１－７ Freedom of Association .......................................................................................... 6
２ HEALTH AND SAFETY .................................................................................................. 6
２－１ Occupational Safety ............................................................................................... 6
２－２ Emergency Preparedness ...................................................................................... 6
２－３ Occupational Injury and Illness ............................................................................ 7
２－４ Industrial Hygiene ................................................................................................. 7
２－５ Physically Demanding Work ................................................................................. 7
２－６ Machine Safeguarding ........................................................................................... 7
２－７ Sanitation, Food, and Housing .............................................................................. 8
２－８ Health and Safety Communication ....................................................................... 8
２－９ Healthcare of Workers ........................................................................................... 8
３ ENVIRONMENT .............................................................................................................. 9
３－１ Environmental Permits and Reporting................................................................. 9
３－２ Pollution Prevention and Resource Reduction ..................................................... 9
３－３ Hazardous Substances ........................................................................................... 9
３－４ Solid Waste ........................................................................................................... 10
３－５ Air Emissions ....................................................................................................... 10
３－６ Materials Restrictions.......................................................................................... 10
３－７ Water Management.............................................................................................. 11
３－８ Energy Consumption and Greenhouse Gas Emissions ...................................... 11
３－９ Conservation of Biodiversity ............................................................................... 11
４ ETHICS ........................................................................................................................... 12
４－１ Business Integrity ................................................................................................ 12
４－２ No Improper Advantage....................................................................................... 12
４－３ Disclosure of Information .................................................................................... 12
４－４ Intellectual Property ............................................................................................ 13
４－５ Fair Business, Advertising and Competition ...................................................... 13
４－６ Protection of Identity and Non-Retaliation ........................................................ 14
４－７ Responsible Sourcing of Minerals ....................................................................... 14
４－８ Privacy .................................................................................................................. 14
４－９ Appropriate Export and Import Controls ........................................................... 143

５ PRODUCT QUALITY AND SAFETY............................................................................ 15
５－１ Ensure Product Safety ......................................................................................... 15
６ INFORMATION SECURITY ......................................................................................... 15
６－１ Secure Computer Networks Against Threats ..................................................... 15
７ BUSINESS CONTINUITY PLANS ............................................................................... 15
７－１ Formulation of Business Continuity Plans ......................................................... 15
８ MANAGEMENT SYSTEMS .......................................................................................... 16
８－１ Company Commitment ........................................................................................ 16
８－２ Management Accountability and Responsibility ................................................ 16
８－３ Legal and Customer Requirements..................................................................... 16
８－４ Risk Assessment and Risk Management ............................................................ 16
８－５ Improvement Objectives ...................................................................................... 17
８－６ Training ................................................................................................................ 17
８－７ Communication .................................................................................................... 17
８－８ Worker Feedback, Participation and Grievance ................................................. 17
８－９ Audits and Assessments ...................................................................................... 17
８－１０ Corrective Action Process ................................................................................. 18
８－１１ Documentation and Records ............................................................................ 18
８－１２ Supplier Responsibility .................................................................................... 18

９ CONTRIBUTION TO SOCIETY ................................................................................... 18
Related Detailed Guidelines ................................................................................................... 19

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１

LABOR

In this Guideline, workers include "direct workers, temporary workers, migrant
workers, student workers, contract workers, and indirect workers and other forms of
employment" and apply to all such workers.

１－１

Freely Chosen Employment

All workers shall be employed at their own free will, and no form of forced labor shall bepermitted. Also, workers shall be guaranteed to freely leave work at any time or
terminate their employment.
【Details】■Forced labor, bonded labor, slave labor, involuntary or exploitative prison labor, andhuman trafficking labor are not permitted.
■Employers shall not impose no undue restrictions on access to workplaces, dormitories
or residential areas and on the freedom of movement of workers in the workplace.
■Employers are required to provide a written employment agreement in the worker's
native language or in a language that the workers can fully understand. For foreign
migrant workers, an employment agreement must be provided prior to the worker
departing from his or her country of origin and there shall be no substitution of orchange(s) in the employment agreement allowed upon arrival in the receiving country(unless these changes are made to meet local law and provide equal or better terms).
■ No penalty shall be imposed if a worker gives advance notice of retirement inaccordance with relevant local laws and regulations.
■Employers, agents, and sub-agent’s may not hold or otherwise destroy, conceal, or
confiscate workers identification cards, passports, work permits, etc.
■Employers shall not require workers to pay recruitment fees or other related fees when
the workers are recruited or hired.

１－２

Young Workers

Children under the minimum working age shall not be hired. Workers under the age of
18 shall not perform work that is likely to jeopardize their health or safety. Pleasemanage student workers appropriately based on local laws. Employers shall ensure
proper management of student workers in accordance with applicable laws andregulations.
【Details】■Child labor is not permitted. 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.

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■Employers shall implement an appropriate age verification process of workers using
official documents issued by the government, such as identification.
■Workers under the age of 18 shall not perform work that is likely to jeopardize

their health or safety, night shifts and overtime, or other hazardous work as
required by local law.
■ If there are student workers, monitor the training content and their workplace
practices and performance according to the learning program.

１－３

Working Hours

Working hours, holidays and vacations of workers shall be appropriately managed inorder not to exceed the legal limit.
【Details】■Working hours, including overtime, must comply with local laws and regulations.
■When workers work overtime, they must comply with the relevant local laws andregulations, and follow the instructions of the superiors.
■Workers shall be allowed at least one day off every seven days.
■Workers shall be granted the right to annual paid leave, maternity leave, childcare
leave and rest periods as stipulated by local laws and regulations.

１－４

Wages and Benefits

Wages of workers must at least exceed the local minimum wage required by local law
and the company shall not make wage deductions that deviate from local laws andregulations.
【Details】■The calculation and payment of all other benefits, including minimum wages, overtime
allowances and statutory benefits, must be in accordance with local wage laws.
■For each pay period, workers shall be provided with understandable wage statementthat includes sufficient information to verify accurate compensation for work
performed.

１－５

Humane Treatment

Respect the human rights of workers and there is to be no harsh or inhumane treatment
including abuse and harassment.
【Details】■There is to be no harsh or inhumane treatment including violence, gender-based

violence, abuse, corporal punishment, sexual harassment, power harassment
bullying, public shaming etc.
■In order to establish a disciplinary systems and response procedures, etc. and to grasp

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the facts of inhumane treatment, a grievance or reporting mechanism should be set up
and communicated to workers.

１－６

Non-Discrimination and Non-Harassment

All forms of discrimination and harassment related to employment and occupation shallbe prohibited, and appropriate preventive measures shall be taken.
【Details】■ Workers should not be discriminated or harassed in employment, promotion,compensation, training or other opportunities or treatment based on race, national
origin, creed, religion, gender, gender identity, sexual orientation, social origin, age,disability, educational background, family status, etc. These are based on factors
other than the reasonable factors such as ability aptitude and performance.
■Workers or potential workers should not be subjected to medical tests that could
be used in a discriminatory way.
■Workers shall be provided with reasonable accommodation for religious practices.

１－７

Freedom of Association

Respect workers’ freedom of association (rights to organize) in accordance with local
laws, and the right to collective bargaining as a means of realizing discussions between
labor and management regarding the working environment and wage levels.
【Details】■ Workers shall be able to openly communicate and share ideas and concerns

regarding working conditions and management practices without fear of
discrimination, reprisal, intimidation, or harassment.
■ Employer should approve workers' representatives for the purpose of collective
bargaining, promote voluntary negotiations between employers and workers, andemployer shall not refuse collective bargaining activities without justifiable reasons.
■Respect the right of workers to participate in peaceful assemblies.

２

HEALTH AND SAFETY

２－１

Occupational Safety

Assess the risks to the health and safety of workers in the workplace and ensure safety
through appropriate design, engineering controls and administrative controls.
【Details】■Identify risks to the health and safety of workers in the workplace and eliminate or
reduce such risks and take safety measures.
■ Where risks in the workplace cannot be adequately controlled by appropriate

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design engineering controls and administrative controls , workers are to be provided
with appropriate, well-maintained, personal protective equipment with free ofcharge.
■Consider occupational health and safety for pregnant and nursing mothers and remove
them from working in conditions with high hazards.
■For female workers who are raising children less than one year after giving birth,
employer should provide them with a clean place for breastfeeding and expressing milkwith adequate breaks, safety and privacy.

２－２Emergency Preparedness

In order to protect the life and physical safety of workers, prepare emergency measures
assuming possible accidents and disasters, and should be communicated to workers.
【Details】■Prepare emergency response measures, including emergency reports, notifications toworkers, evacuation methods, response procedures, storage and posting of emergency
response personnel contact points, evacuation drills, installation of appropriate fire
detectionsystems,

installation

of

fire

extinguishers,

securingofexternal

communication means, easy to understand and clear and unobstructed egress,
adequate exit facilities, emergency medical supplies storage and recovery plans.
■Plan and conduct evacuation drills for all workers once a year or as frequently as
required by local laws and regulations, whichever is stricter.

２－３

Occupational Injury and Illness

Understand the situation of industrial accidents and diseases and take appropriate
measures.
【Details】■Encourage reports by workers, classify and record accidents and diseases, provide
treatment as needed, investigate accidents and diseases, and implement corrective
measures to eliminate causes.
■Establish and operate a system for supporting workers' return to work.
■Follow the necessary procedures for the administration (including participation inindustrial accident insurance) in accordance with the local laws and regulations.

２－４

Industrial Hygiene

Understand the situation where workers are exposed to biologically or chemically
harmful substances, noise and odors, and take appropriate measures in the workplace.
【Details】■Identify the risks to workers' health and safety from smoke, steam, dust, toxic and8poisonous substances, radiation, substances that cause chronic diseases (lead,asbestos, etc.), noise, odors, etc., and take measures to eliminate or reduce such risks(by training for workers, and job rotation etc.).
■ Where risks in the workplace cannot be adequately controlled by appropriate

engineering and administrative controls, workers are to be provided withappropriate, well-maintained, personal protective equipment with free of charge.

２－５

Physically Demanding Work

Worker exposure to the hazards of physically demanding tasks is to be identified andcontrolled appropriately so that they do not lead to disaster or illness.
【Details】■Identify heavy lifting work such as manual material handling and transport work,
assembly tasks requiring force, long hours of standing work, long hours of repetitive
work such as data input, etc., and take control measures such as improving the work
environment.

２－６

Machine Safeguarding

Assess the machinery and equipment used by workers for safety risks and takeappropriate safety measures.
【Details】■If the use of machinery devices may cause accidents or health problems to workers
during work, the following measures should be taken. Adoption of a safety mechanism
called fail-safe, installation of safety devices and protective walls, periodic inspection
and maintenance of machinery and equipment.

２－７

Sanitation, Food and Housing

Ensure the health and safety of the facilities provided for workers (such as dormitories,
cafeterias, toilets, etc.).
【Details】■Workers are to be provided with ready access to clean toilet facilities, safe drinking

water, sanitary food preparation, storage, and eating facilities.
■Worker housing such as dormitories must be provided with fire prevention measures,
emergency egress and appropriate living environments.

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２－８

Health and Safety Communication

Provide appropriate health and safety information and conduct safety education(training) in the worker's native language or a language understood by the worker for
all workplace hazards to which the worker may be exposed to.
【Details】■Health and safety information provided for workplace hazards such as mechanical,
electrical, chemical, fire and physical hazards should be clearly posted in the facilities
or placed in a location identifiable or accessible by workers and should be wellcommunicated.
■Health and safety education should be provided to all workers prior to the beginningof work and regularly thereafter.
■Establish a communication process and allows workers to raise any health and safetyconcerns without fear of retaliation.

２－９

Healthcare of Workers

Take appropriate healthcare for all workers.
【Details】■In order to prevent and detect diseases of workers at an early stage, please conduct
medical examinations, etc., as prescribed by relevant laws and regulations in the area.
In addition, sufficient consideration should be given to the prevention of healthproblems due to overwork and mental health care.

３

ENVIRONMENT

３－１

Environmental Permits and ReportingIn accordance with relevant local laws and regulations, obtain approvals from thegovernment if necessary, and comply with required operational and reporting
requirements.
【Details】■ In Japan, managers who have acquired certain qualifications are required to beappointed under the Waste Management and Public Cleansing Law (Managers for
specially controlled industrial waste), the Act on the Rational Use of Energy (Energy
managers in factories that use energy above a certain level), the Air Pollution Control
Law (Pollution control managers in factories that emit chemical substances, dust andsmoke) etc., and must comply with the requirements of related laws and regulations.
■Strictly comply with local laws and regulations regarding the obligation to appoint a
person in charge of managing poisonous and deleterious substances, specific chemical

10substances, hazardous substances, etc., according to the chemical substances used in
the business.
■Depending on the business content and the location of the company site, please comply
with and respond to relevant laws and regulations, such as environmental impact
assessments and government approvals of hazardous material handling facilities.

３－２

Pollution Prevention and Resource Reduction

Set voluntary goals for resource and energy conservation, and make continuous effective
use of resources and energy, as well as implement activities to reduce environmental
impact, such as reducing pollutants and waste.
【Details】■Reduce the use of natural resources (water, fossil fuels, minerals, etc.) by substituting
materials, recycling and reusing, improving the operation methods and processes ofmanufacturing, maintenance, equipment, and carry out resource conservation
activities.
■As for pollutants and waste, please carry out activities to reduce pollutants and waste
by controlling the source of pollution, installing equipment to prevent pollution, andimproving the operation methods and processes of manufacturing, maintenance, andequipment.
■Reduce the amount of materials used in products and waste, promote the use ofrecycled resources and parts, and make effective use of resources. The 3Rs (Reduce,
Reuse, Recycle) are effective in reducing waste.

３－３

Hazardous Substances

In compliance with relevant laws and regulations, identify chemical substances, waste
and other substances that are harmful to human bodies and the environment, andmanage them appropriately.
【Details】■In Japan, follow the Act on the Evaluation of Chemical Substances and Regulation of
Their Manufacture, the Poisonous and Deleterious Substances Control Law, theIndustrial Safety and Health Act, the Fire Service Act and the Act on Confirmation, etc.
of Release Amounts of Specific Chemical Substances in the Environment and Promotionof Improvements to the Management Thereof.
■Establish rules regarding identification (including labeling) of chemical substances,safe handling, movement, storage, use, recycling or reuse, and disposal.

３－４

Solid Waste

Comply with relevant laws and regulations, manage waste appropriately, set voluntary
goals for waste reduction, and continuously reduce waste.

11

【Details】■ Regardless of whether it is harmful or not, establish regulations regarding theidentification, classification, storage, transportation, and disposal of waste, andmanage their operation.
■Set voluntary reduction goals for waste, plans, and implement a systematic approach.
■Continue to implement the 3Rs (Reduce, Reuse, Recycle) to reduce waste.
■Periodically evaluate whether the contractor for disposal and transporter of hazardous
waste are processing according to the contract terms.

３－５

Air Emissions

Comply with all applicable laws and regulations and take appropriate measures toreduce emissions of hazardous substances into the atmosphere. If necessary, makefurther improvements based on voluntary standards.
【Details】■ Before discharging hazardous substances (volatile organic compounds, aerosols,
corrosive substances, fine particles, ozone-depleting substances, combustion byproducts, etc.) into the atmosphere, analyze them and discharge them as necessary
based on the results.
■Manage ozone-depleting substances in accordance with the Montreal Protocol andapplicable laws and regulations.

３－６

Materials Restrictions

For the management of chemical substances in parts and materials used in products andmanufacturing processes, comply with applicable laws, regulations and customer
requirements concerning the prohibition or restriction of the use of specific substances.
【Details】■In addition to prohibiting the inclusion of chemical substances specified in applicablelaws and regulations in products, ensure compliance with required labelingrequirements, conduct tests and evaluations, and manage chemical substances
contained in products.
■In addition to controlling chemical substances that should not be contained in products,
suppliers shall also monitor the release of chemical substances released into theexternal environment and report them to the government. In order to reduce therelease of such substances, suppliers shall manage chemical substances in its
manufacturing processes.
■Chemical substances used in products and manufacturing processes must comply withapplicable laws and regulations as well as customer requirements.

12

３－７

Water Management

Comply with all applicable laws and regulations and conduct routine monitoring of theperformance of its wastewater treatment before discharging it. In addition, make further
improvements based on voluntary standards as necessary.
【Details】■In addition to monitoring water sources, water consumption, and wastewater volume,
suppliers shall work to conserve water resources by conserving and reusing water. Also,
conduct water management, including prevention of pollution of the waterways on thepremises.
■ Monitor the operating status of wastewater treatment systems and emergency
response equipment to ensure optimal operation and comply with local laws andregulations.

３－８

Energy Consumption and Greenhouse Gas Emissions

Strive to improve energy efficiency and continuously reduce energy consumption andgreenhouse gas emissions.
【Details】■In order to engage in activities to improve energy efficiency (energy conservation) andto continuously reduce greenhouse gas emissions, set voluntary reduction goals, makeplans, and surely implement them.
■Understand, record and document energy consumption and related greenhouse gas
emissions.
■Disclose information on improving energy efficiency and reducing greenhouse gas
emissions.
■ Greenhouse gases refer to seven groups of substances: carbon dioxide, methane,
nitrous oxide, HFCs, PFCs, sulfur hexafluoride, and nitrogen trifluoride.

３－９

Conservation of Biodiversity

Assess the impact of business activities on the ecosystem and make efforts to minimize
negative impacts.
【Details】■In order to minimize the negative impact of business activities on biodiversity on thesurrounding areas, identify ecosystem risks inside and outside the premises ofbusiness sites and production sites, and implement biodiversity conservation activities
appropriately.
■ For example, extermination of alien species for the protection of native species,
promotion and protection of endangered species should be carried out. In addition,please engage in biodiversity conservation activities as an effort for the entire value

13

chain of companies, including efforts for products and services.

４

ETHICS

４－１

Business Integrity

In every aspect of the business, the highest standards of integrity are to be upheld of

ethics and moral standards as a top priority. In conducting business activities, thecompany must fully understand and comply with the relevant laws and regulationsof your country and the country in which you operate and respect the international
codes of conduct.
【Details】■ Develop a policy prohibiting all forms of bribery, corruption, extortion andembezzlement.
■Establish a system for corporate ethics and legal compliance, disseminate information,raise awareness, and monitor the compliance status.
■Respect the religions, customs, cultures and traditions of each country and region.

４－２

No Improper Advantage

Maintain a sound and appropriate relationship with politics and governments andrefrain from bribery, illegal political contributions, etc. In addition, do not give or receive
inappropriate benefits in relation to all stakeholders.
【Details】■For the purpose of obtaining and maintaining improper benefits and preferential
treatment, do not directly or indirectly entertain, give gifts, give or receive money toall stakeholders.
■ Do not give improper benefits to anti-social forces (an antisocial individual ororganization) that would have adverse impact on the social orders or sound corporate
activities.
■Do not engage in insider trading involving the purchase and sale of shares based on
confidential material information related to the business of customers, etc.

４－３Disclosure of Information

In accordance with applicable laws and regulations or general industry practices,disclose information regarding business activities, products and services to stakeholders
in a timely and appropriate manner.
【Details】■Information to be provided and disclosed to stakeholders includes details of businessactivities, financial status, business performance, ESG (Environment, Social and14

Governance) information, etc. Falsification of records and misrepresentation of
conditions or practices are unacceptable.
■Disclose accurate information on the substances contained in the parts and materials
used in the products.
■Keep a record of management indicators of environmental conservation activities,
achievement of goals, and other important matters related to the environment, anddisclose information as necessary.

４－４Intellectual Property

Protect supplier’s intellectual property, respect the intellectual property rights and avoid
infringing those of other companies. In addition, please appropriately manage andprotect confidential information received from customers, suppliers, etc.
【Details】■ Intellectual property refers to patent rights, utility model rights, design rights,
trademark rights, copyrights, trade secrets, etc.
■Confidential Information generally refers to information disclosed in documents thathave been agreed to be confidential or information that has been verbally disclosed
after being notified that it is confidential.
■ Do not infringe on the intellectual property rights of others and use or transfer
technology or know-how.
■When developing, producing, selling or providing products or services, conduct a priorinvestigation into the intellectual property rights of others and do not use theintellectual property rights of others without permission unless there are reasonablebackgrounds.
■Do not infringe the copyrights by illegally copying or otherwise copying computer
software or other copyrighted materials.
■Do not illegally obtain or use trade secrets of others.
■Do not illegally or unreasonably obtain, use, disclose or leak confidential information.

４－５

Fair Business, Advertising and Competition

Do not engage in any conduct that impedes fair, transparent, and free competition.
【Details】■In compliance with applicable national and regional competition laws (Antitrust Act,
Subcontract Act, etc. in Japan), do not engage in any acts such as unreasonable trading
restrictions, unfair trade methods, or abuse of dominant bargaining position.
■Do not engage in any acts that impede competition, such as making an agreement withother companies in the same industry regarding price, quantity, or sales area of
products and services (cartels), arranging the winning bidder and winning bid pricewith other bidders (bid rigging), unfair transactions, such as discriminatory treatment15

of prices and terms, unjust low-price sales, and unreasonable expensive purchases.
■Suppliers are requested to conduct procurement transactions faithfully, and fairly
based on contracts, etc. and not to engage in any abuse of dominant bargaining position
that imposes unreasonable demands or obligations, such as unilaterally determining
or changing the terms of transactions with suppliers, etc., using their position aspurchasers or consignors.
■Do not engage in unfair competition activities such as obtaining or using trade secretsof other companies in an illegal manner or using false or misleading displays regarding
products of other companies.
■Do not use expressions that are untrue or mislead consumers or customers, and do notinclude slander or infringement of rights of other companies or individuals in thedisplay of catalogues and advertisements related to product and services.

４－６

Protection of Identity and Non- Retaliation

The Company is requested to ensure the confidentiality of information and anonymityof whistleblowers regarding consultations and reports, and to respond promptly in
addition to establishing a consultation and reporting system that allows workers to raise
concerns without fear of retaliation and striving to prevent and detect misconduct at an
early stage.
【Details】■Establish a hotline for internal and external users (workers of the company andsuppliers) to consult and report on misconduct and ensure that all employees are wellaware of the hotline. Fraud should be dealt with promptly and provide feedback to thewhistleblower as appropriate.

４－７

Responsible Sourcing Minerals

Minerals produced in conflict areas and high-risk areas by improper methods and parts
made from such minerals shall not be used in the products.
【Details】■Establish a responsible mineral procurement policy and promote due diligence todetermine whether tantalum, tin, tungsten, gold and other minerals in the productscause serious human rights violations, environmental degradation, corruption,
conflicts and other incidents in conflict and high-risk areas.

４－８

PrivacyManage and protect the personal information of customers, suppliers, consumers,
workers, etc.

16

【Details】■Personal information refers to information that can identify a specific individual by
name, date of birth or other description.
■Comply with applicable personal information protection laws and regulations whencollecting, using, storing, transferring and sharing personal information.
■Personal information must not be illegally or unreasonably acquired, used, disclosed,or leaked.

４－９ Appropriate Export and Import Controls
A clear management system must be established, and appropriate import and export
procedures must be followed regarding the import and export of technologies and goods
regulated by laws and regulations.
【Details】■When importing or exporting parts, products, technologies, equipment, software, etc.
which are regulated by laws and regulations based on international agreements, etc.
(Wassenaar Arrangement, etc.), please go through procedures such as obtaining
permission from regulatory authorities, etc., as necessary.

５

PRODUCT QUALITY AND SAFETY

５－１ Ensure Product Safety
Fulfill your responsibility as a supplier by designing, manufacturing and selling
products that meet the safety standards stipulated by the laws and regulations of eachcountry and ensure sufficient product safety.
【Details】■ Fulfill your responsibility as a manufacturer by designing products that are
sufficiently safe.
■In addition to complying with the requirements set forth by laws and regulations, also
consider to the safety required by society.
■In order to ensure product safety, manage traceability (history of standards, materials,
parts, processes, etc.), prompt action to solve problems should be taken.

６ INFORMATION SECURITY
６－１

Secure Computer Networks Against Threats

Take precautions against threats on your computer network to prevent harm to yourcompany and others.

17

【Details】■ Threats on computer networks include, for example, computer viruses, computerworms, and spyware.
■If a computer connected to the internet is infected with a computer virus, etc. it may
cause a serious loss such as business suspension or loss of credibility. Therefore, takemeasures to ensure that computer network threats do not affect internal or external
parties.

７ BUSINESS CONTINUITY PLANS
７－１ Formulation of Business Continuity Plans
Establish a business continuity plan, and in the event of an unforeseen situation,
promptly restore important businesses and establish a system to provide a stable supplyof products.
【Details】■Business continuity plans should be carefully prepared for the purpose of continuingbusiness in the event of an unforeseen situation, such as a disaster or accident, as partof a company-wide activities and carry out business continuity and early recovery in an
emergency.

８

MANAGEMENT SYSTEM

Establish and operate a management system for the contents of these guidelines. The
purpose of the management system is to ensure compliance with laws, regulations andcustomer requirements related to business activities and products, compliance with therequirements of these guidelines, identification of risks related to the contents of theseguidelines, and prevention, elimination and reduction of the occurrence of risks.
Management system should include the following:

８－１

Company Commitment

Post policies in the facility regarding the company’s "social responsibility" and"environmental responsibility" that have been approved by management.
【Details】■The company’s policies approved by senior management should be written in local
language and in a language that workers can understand and should be posted in
facilities or posted in places that can be easily viewed such as the intranet so thatworkers can easily understand the content.

18

８－２

Management Accountability and Responsibility

The corporate officers or representatives should be appointed, and management reviews
should be conducted regularly by the appointed management representatives to ensure
the implementation of the management system and related programs【Details】■The appointment of a management representative applies to each of the areas of Labor,
Health and safety, Environment, Ethics, Quality and Safety, Information Security,
Business Continuity Plan, and should be documented in the supporting document(organization chart, job description, management system documents, etc.).
■Conduct management reviews at least annually (once a year).

８－３

Legal and Customer Requirements

Identify applicable legal and customer requirements, including the requirements of thisguideline, and establish a mechanism to monitor compliance.
【Details】■ Record the monitoring results to understand the applicable legal and customer
requirements.

８－４

Risk Assessment and Risk Management

Establish a process to identify risks associated with these guidelines, manage identified
risks appropriately, and comply with regulations.
【Details】■Assess the relative importance of each risk and take steps or physical controls to
address the risk.

８－５

Improvement Objectives

Prepare improvement goals and implementation plans for this guideline, andperiodically evaluate the progress of the goals.
【Details】■Evaluate the progress in achieving improvement goals and implementation plans, andformulate additional action plans if progress is not being made as planned.

８－６ Training
Provide training for managers and workers (education and training) to implement thecompany's policies and related initiatives and procedures.
【Details】■Training should include the content of this guideline, applicable regulatory
requirements and should be documented and validated.

19

８－７

Communication

Establish a process to accurately communicate the company's policies, performance,
expectations, to workers, suppliers, and customers.
【Details】■As part of the communication, please hold a meeting regarding these guidelines with
suppliers.

８－８Worker Feedback, Participation and Grievance

Evaluate workers' level of understanding of the contents of this guideline and obtain
feedback and examples of violations to establish an effective grievance system to foster
continuous improvement.
【Details】■Reports of complaints or violations can be made anonymously, and workers should beprotected from retaliation and disadvantage.

８－９

Audits and Assessments

Regularly assess status of complying with applicable laws and regulations, the content
of this guideline and the customer requirements.
【Details】■ Establish and implement a self-assessment and internal audit process to ensurecompliance with the content of this guideline.

８－１０

Corrective Action Process

Establish and implement corrective action processes for nonconformities identified
through internal and external assessments, inspections, investigations and audits.
【Details】■The corrective action process involves developing a corrective action plan, managing
progress, and verifying effectiveness after corrective action is taken.

８－１１

Documentation and Records

Prepare documentation and records in accordance with applicable laws and regulations
and the companies own administrative requirements.
【Details】■Records of personal or confidential information must be kept secret and managed
appropriately.

20

８－１２

Supplier Responsibility

Communicate the contents of this guideline to the company’s suppliers and establish amechanism to monitor their compliance status.
【Details】■Identify your primary suppliers, communicate the contents of the guideline andobtain their consent. In addition, monitor their compliance status of this guideline
and understand the situation.

９

CONTRIBUTION TO SOCIETY

Voluntarily engage in activities that contribute to the development of international andlocal communities.
【Details】■The activities to contribute to the development of global society and local communities
mean the support using company’s management resources.
Typical approaches are as follows:- Social contribution using regular business operation and existing technologies.
- No pecuniary social contribution using facilities and human resources, etc.
- Monetary social donation

In the event of a disaster, determine the scope of activities that can be carried out by
the company, such as cooperation with local communities, support for activities by
employee volunteers, NPOs/NGOs, etc., donation activities, and the dissemination andintroduction of various information, and actively contribute to society.

21Related Guidelines:
Please also follow the guidelines below for green procurement, biodiversity conservation,and quality assurance.
・Furukawa Electric Green Procurement Guideline
https://www.furukawa.co.jp/en/procure/pdf/fgg_guideline.pdf
・Furukawa Electric Group Biodiversity Conservation Guidelines
https://furukawaelectric.disclosure.site/en/themes/161
・Quality Assurance Guidelines for Partners
https://www.furukawa.co.jp/en/procure/pdf/qag_guideline_en_202010.pdf
Revisions:First Edition: August 30, 2010 Referred to JEITA Supply Chain CSR Guideline
2nd Edition: April 8, 2013 Included “Initiatives for Responsible Mineral Procurement”
3rd Edition: February xx, 2021 Referred to RBA Code of Conduct 7.0
Changed name to Furukawa Electric Group CSR Procurement Guidelines
Publisher：
Furukawa Electric Co., Ltd.
Administration & CSR Division

CSR Department

MONOZUKURI Innovation Division Procurement Department22