Furukawa Electric GroupCSR Procurement Guidelines 4th edition

August 30, 2024
FURUKAWA ELECTRIC CO., Ltd.

Introduction
Based on the Furukawa Electric Group Purpose, the Furukawa Electric Group is promoting ESG
management with the aim of improving corporate value (financial and social values) over the
medium to long term based on ESG (Environment, Social and Governance ).
To fulfill our corporate social responsibility as a member of society, our Group has established
Furukawa Electric Group CSR Code of Conduct" and are proactively engaged in CSR activities.
In order to promote CSR activities under 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" and the "Furukawa
Electric CSR Procurement Guidelines " to encourage our suppliers to promote CSR activities.
In response to the revision of the Code of Conduct of the Responsible Business Alliance(RBA), the world's largest organization promoting CSR procurement activities, we haveestablished the "Furukawa Electric Group CSR Procurement Guidelines (4th Edition).We
would like to ask our suppliers for their understanding and support of these guidelines. We
also request that our suppliers inform their suppliers of these guidelines and promote CSR
activities. The Group considers its suppliers not only as "Suppliers" who supply products andservices “Business Partners”, but also "Partners" who create value together. However, in theseguidelines, please note that the term “Suppliers” is used instead to make it easier tounderstand.
About Furukawa Electric Group CSR Procurement Guidelines:
Based on "Furukawa Electric Group CSR Code of Conduct" and "Furukawa Electric Group
Procurement Policy", these guidelines summarize the approaches and details which the
Furukawa Electric Group expects its suppliers to comply with and work on, referring to theCode of Conduct of RBA (Responsible Business Alliance), which is a corporate organizationthat promotes CSR in the supply chain, and "Responsible Business Conduct Guidelines" of theJapan Electronics and Information Technology Industries Association(JEITA) and otherpublications.
"Furukawa Electric Group CSR Code of Conduct"
https://furukawaelectric.disclosure.site/en/themes/123“Furukawa Electric Group Human Rights Policy”
https://furukawaelectric.disclosure.site/en/themes/203“Furukawa Electric Group Procurement Policy”
https://www.furukawa.co.jp/en/procure/standard.html“Responsible Business Alliance (RBA) Code of Conduct”
https://www.responsiblebusiness.org/media/docs/RBACodeofConduct8.0_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 .............................................................................................................................. 5
１－１ Prohibition of Forced Labor ................................................................................. 5
１－２ Young Workers .................................................................................................................5
１―３ Working Hours ....................................................................................................... 6
１－４ Wages and Benefits.................................................................................................... 6
１－５ Non-Discrimination/Non-Harassment/Humane Treatment ....................................6
１－６ Freedom of Association and Collective Bargaining ............................................. 7
２ HEALTH AND SAFETY .................................................................................................. 7
２－１ Occupational Health and Safety ........................................................................... 7
２－２ Emergency Preparedness.......................................................................................... 8
２－３ Occupational Injury and Illness ............................................................................ 8
２－４ Industrial Hygiene ..................................................................................................... 8
２－５ Physically Demanding Work .........................................................................................9
２－６ Machine Safeguarding............................................................................................... 9
２－７ Sanitation, Food, and Housing ................................................................................. 9
２－８ Health and Safety Communication ....................................................................... 10
２－９ Healthcare of Workers ................................................................................................. 10
３ ENVIRONMENT ................................................................................................................ 10
３－１ Environmental Permits and Reporting ................................................................. 10
３－２ Pollution Prevention and Resource Conservation ................................................ 11
３－３ Hazardous Substances ............................................................................................ 11
３－４ Solid Waste .....................................................................................................................11
３－５ Air Emissions ....................................................................................................... 12
３－６ Materials Restrictions ............................................................................................. 12
３－７ Water Management ..................................................................................................12
３－８ Energy Consumption and Greenhouse Gas Emissions ....................................... 13
３－９ Conservation of Biodiversity ............................................................................... 13
４ ETHICS ................................................................................................................................ 13
４－１ Business Integrity .................................................................................................... 13
４－２ No Improper Advantage .......................................................................................... 14
４－３ Disclosure of Information .................................................................................... 14
４－４ Intellectual Property ............................................................................................ 14
４－５ Fair Business, Advertising and Competition ........................................................ 15
４－６ Protection of Identity and Non-Retaliation ........................................................ 15
４－７ Responsible Sourcing of Minerals ....................................................................... 16
４－８ Privacy .................................................................................................................. 16
４－９ Appropriate Export and Import Controls ........................................................... 163

５ PRODUCT QUALITY AND SAFETY ........................................................................... 16
５－１ Ensure Product Safety ......................................................................................... 16
６ INFORMATION SECURITY ......................................................................................... 17
６－１ Secure Computer Networks Against Threats ...................................................... 17
７ BUSINESS CONTINUITY PLANS ............................................................................... 17
７－１ Formulation of Business Continuity Plans ......................................................... 17
８ MANAGEMENT SYSTEMS.......................................................................................... 18
８－１ Company Commitment ....................................................................................... 18
８－２ Management Accountability and Responsibility ................................................ 18
８－３ Legal and Customer Requirements ....................................................................... 18
８－４ Risk Assessment and Risk Management .............................................................. 19
８－５ Improvement Objectives.......................................................................................... 19
８－６ Training...........................................................................................................................19
８－７ Communication ........................................................................................................ 19
８－８ Worker/Stakeholder Engagement and Access to Remedy............................... 19
８－９ Audits and Assessments.......................................................................................... 20
８－１０ Corrective Action Process................................................................................. 20
８－１１ Documentation and Records ............................................................................ 20
８－１２ Supplier Responsibility ....................................................................................... 20

９ CONTRIBUTION TO SOCIETY ................................................................................... 21
Related Detailed Guidelines ...................................................................................................... 21

4

１

LABOR

Commit to respect the human rights of workers and to encourage your suppliers totake the same approach. In these guidelines, “workers” refer to all workers including
direct, temporary, migrant, student, contract, and indirect employees, and any othertype of worker.

１－１

Prohibition of Forced Labor

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 shall not be permitted.
■No unreasonable restrictions are imposed on access to workplaces, dormitories orresidential areas or 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 reasonable notice of resignation /retirement in accordance with relevant local laws and regulations. This shall be clearlystated in workers’ contracts.
■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.
■Participants shall maintain documentation on all leaving workers in accordance tolocal laws and regulations.

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. Manage
student workers appropriately based on local laws. Employers shall ensure proper
management of student workers in accordance with applicable laws and regulations.
【Details】■Child labor is not permitted. The term “child” refers to any person under the age of5

15, or under the age for completing compulsory education, or under the minimum
age for employment in the country, whichever is greatest.
■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, including night shifts, overtime, or other hazardous work as
required by local law.
■ If there are student workers, monitor the training contents, their workplace
practices, and the 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 supervisors.
■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.
■Equal pay for equal work and qualification shall be set for all workers.

１－５

Non-Discrimination/Non-Harassment/Humane Treatment

Respect the human rights of workers and there is to be no harsh or inhumane treatment
including abuse and harassment. All forms of discrimination and harassment related to
employment and occupation shall be prohibited, and appropriate preventive measures
shall be taken.
【Details】■There is to be no harsh or inhumane treatment including violence, gender-based

6

violence, abuse, corporal punishment, sexual harassment, power harassment
bullying, public shaming etc.
■In order to establish disciplinary systems and response procedures, etc. and to grasp
the facts of inhumane treatment, a grievance or reporting mechanism should be set up
and communicated to workers.
■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.
■Do not allow workers or potential workers to undergomedical tests that could
be used in a discriminatory way.
■Reasonable accommodation shall be provided to the workers who carry out
religious practices.
■Reasonable accommodation shall be provided to the workers with disabilities.

１－６

Freedom of Association and Collective Bargaining.In accordance with local laws, respect workers’ freedom of association (right ofassociation) and the right of 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.
■ The employer should approve workers' representatives for the purpose ofcollective
bargaining, promote voluntary negotiations between employers and workers, and theemployer shall not refuse collective bargaining activities unless there are reasonablegrounds.
■Respect the right of workers to participate in peaceful assemblies.

２

HEALTH AND SAFETY

２－１

Occupational Health and 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

design, engineering controls, and administrative controls, workers shall be
provided with appropriate, well-maintained, personal protective equipment

7

with free of charge.
■Gender-responsive measures shall be taken, such as not having pregnant women andnursing mothers in working conditions, which could be hazardous to them or theirchildren and to provide reasonable accommodations for nursing mothers.

２－２

Emergency 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 contact
information for emergencies, evacuation drills, installation of appropriate fire
detectionsystems,

installation

of

fire

extinguishers,

securingofexternal

communications, clear and unobstructed exits, adequate evacuation shelters,
stockpiling of emergency medical supplies 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, record, and investigate injury and illness
cases, provide necessary medical treatment, and implement corrective actions toeliminate their 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.
■Allow workers to remove themselves from imminent harm, without fear of retaliation.

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, monitoring, etc.).
■Where risks in the workplace cannot be adequately controlled by appropriate

engineering and administrative controls, provide workers with appropriate,
well-maintained, personal protective equipment 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】■Take managerial measures to improve the work environment by identifying tasks
including manual material handling and heavy lifting, forceful assembly tasks,
prolonged standing, and long hours of repetitive data input, etc.

２－６Machine Safeguarding

Assess the safety risks of the machinery and equipment used by workers and takeappropriate safety measures.
【Details】■If the use of machinery devices may cause accidents or health problems to workers
during work, adopt safety mechanisms called fail-safe, installsafety devices orprotective walls, and conduct periodic inspection and daily maintenance of machineryand 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】■Provide workers with ready access to clean toilet facilities, safe drinking water, foodprepared and stored in a sanitary environment, and a canteen.
■Worker housing such as dormitories must be provided with fire prevention measures,
emergency exits and appropriate living environments for storing personal andvaluable items.

9

２－８

Health and Safety Communication

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.
【Details】■Health and safety information provided for workplace hazards such as mechanical,
electrical, chemical, fire and physical hazards should be clearly posted in thefacilities or places accessible to workers, and informed and raised their awareness.
■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 andsafety concerns without fear of retaliation.

２－９

Healthcare of Workers

Manage appropriate healthcare for all workers.
【Details】■In order to prevent and detect diseases of workers at an early stage, conduct
medical checkups, etc., as prescribed by relevant locallaws and regulations. In
addition, sufficient consideration should be given to the prevention of healthproblems due to overwork and mental health care, etc. Dispatch of health-related
information and training should include contents that specify risks related togender, age, etc.

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】■Comply with the relevant local laws and regulations regarding the environment.
(In Japan, there are "Waste Disposal and Public Cleansing Law" and "Act on
Rationalizing Energy Use".)■Strictly comply with local laws and regulations regarding the obligation to appointa person in charge of managing poisonous and harmful substances, specified
chemical substances, hazardous substances, etc., according to the chemical
substances used in the business.
■Depending on the type of business and factory location, comply
with relevant laws and regulations, such as environmental impact assessments and10

government approvals for facilities handling hazardous materials..

３－２

Pollution Prevention and Resource Conservation

Set voluntary goals for resource and energy conservation, and continuously makeeffective use of resources and energy, as well as implement activities to reduce
environmental impact, such as reducing pollutants and waste.
【Details】■Carry out conservation activities for natural resources (water, fossil fuels,
minerals, etc.) by reducing their use through material substitution, recycling andreusing, and improving methods and processes for manufacturing, maintenance,
and facility operation.
■Reduce pollutants and generation of waste by controlling their sources or installing
equipment that prevents pollution, and by improving methods and processes for
manufacturing, maintenance, and facility operation.
■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 hazard to humans or the environment, and manage
them appropriately (tracked and documented, etc.).
【Details】■Comply with the relevant local laws and regulations related to hazardous
substances. (In Japan, there are "Act on the Regulation of Manufacture andEvaluation of Chemical Substances" and "Poisonous and Deleterious Substances
Control Act")■Establish rules regarding identification (including labeling) of chemical substances,safe handling, movement, storage, use, recycling or reuse, and disposal, and manage
their operation.

３－４

Solid Waste

Comply with relevant laws and regulations, manage waste appropriately(tracked anddocumented, etc.), set voluntary goals for waste reduction, and continuously reduce
waste.

【Details】■Regardless of whether it is harmful or not, establish rules regarding theidentification, classification, storage, transportation, and disposal of waste, andmanage their operation.
■Set voluntary reduction goals and plans for waste to ensure that a systematic
approach is implemented.
■Continuously work on the 3Rs (Reduce, Reuse, Recycle) to reduce waste.

11

■Periodically evaluate whether contracted disposal companies and transporters ofhazardous wastes are disposing of them by the terms and conditions of the contract.

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】■Analyze the contents of hazardous substances (volatile organic compounds, aerosols,
corrosive substances, particulates, ozone‐depleting substances, combustion byproducts,etc.) and treat them as necessary based on the results, before discharging them into theatmosphere.
■Manage ozone-depleting substances in accordance with the Montreal Protocol
and applicable 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 inapplicable laws and regulations in products, ensure compliance with requiredlabeling requirements, 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
with applicable laws and regulations as well as customer requirements.

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 thewaterways on the premises.
■ Monitor the operating status of wastewater treatment systems andemergency

response equipment to ensure optimal operation and regulatory compliance.

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３－８

Energy Consumption and Greenhouse Gas Emissions

Strive to improve energy efficiency and continuously reduce energy consumption andgreenhouse gas* emissions.
*Greenhouse gases refer to seven groups of substances: carbon dioxide, methane, nitrous oxide,
HFCs, PFCs, sulfur hexafluoride, and nitrogen trifluoride.

【Details】■Establish and report on absolute emission reduction targets regarding greenhousegas emissions.
■Energy consumption and all Scopes 1, 2, and significant categories of Scope 3
greenhouse gas emissions shall be tracked, documented, and publicly reported.
■Set voluntary reduction targets, develop plans, and ensure that they are
implemented to engage in improvement of energy efficiency (energy conservation)and continuous reduction of greenhouse gas emissions.

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 inthe surrounding areas, identify ecosystem risks inside and outside the premises ofbusiness sites and production sites, and implement biodiversity conservation
activities appropriately.
■For example, remove introduced species to protect native species, and protect andbreed endangered species. Engage in biodiversity conservation activities as aneffort across the entire value chain as well as an effort through your products andservices.

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 any and all forms of bribery, corruption, extortionand embezzlement.
■Establish a system for corporate ethics and legal compliance, disseminate information,

13

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 government 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
to or from all stakeholders■ Do not provide improper benefits for anti-social forces (an antisocial individual
or groups) that adversely influence social orders or sound corporate activities.
■Do not engage in insider trading involving the buying and selling of a company's
stock or other securities based on undisclosed material information related to thebusiness of customers, etc.

４－３Disclosure of Information

In accordance with applicable laws and regulations or general industry practices,disclose information on business activities, products and services to stakeholders in atimely and appropriate manner.
【Details】■Information to be provided and disclosed to stakeholders includes details of businessactivities, financial situation, performance, ESG (Environment, Social andGovernance) information, etc. Do not falsify or misrepresent records, or disclose false
information noted above.
■Disclose accurate information on the substances contained in the parts andmaterials used in the products.
■Continuously record management indicators of environmental conservation
activities, degree of achieving goals, and other important environment-related
matters, and disclose them as necessary.

４－４Intellectual Property

Protect your company's intellectual property, respect the intellectual property rights ※ofother companies and do not infringe them those. In addition, appropriately manage andsafeguard confidential information※ received from customers, suppliers, etc.
Intellectual property right refers to patent rights, utility model rights, design rights,
trademark rights, copyrights, trade secrets, etc.
※Confidential Information generally refers to information disclosed in documents
agreed to be confidential or information orally disclosed after notification ofconfidentiality.
※■Do not infringe on the intellectual property rights of others or use or transfer
technology or know-how.
■When developing, producing, selling or providing products or services, thoroughly14

investigate the intellectual property rights of others in advance and do not use theintellectual property of others without permission unless there are reasonablegrounds.
■Do not infringe the copyrights by illegal copying, etc. of computer software orother 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 the competition laws of the applicable country or region (inJapan, there are the Antimonopoly Act and the Subcontract Act, etc.), do not engage
in unreasonable restraint of trade, unfair trade practices, abuse of a superiorbargaining position, etc..
■Do not impede competition by making arrangements with other companies in the same industry
regarding the price, quantity, or sales area of products and services (cartel), by arranging thewinning bidder and winning bid price with other bidders (bid rigging), or by engaging in unfair
transactions, such as discriminatory treatment of prices and terms, unjust low price sales, andunjust high price purchasing.
■Conduct procurement faithfully and fairly according to the contracts, etc., and do
not abuse your dominant position to make unreasonable demands or impose
unreasonable obligations on suppliers, such as unilaterally determining orchanging the terms of transactions with suppliers, etc., by taking advantage of yourposition as a purchaser or consigner.
■Do not engage in unfair competition such as obtaining and using trade secretsof other companies in an illegal manner or making false or misleading
representations to customers concerning other companies' products.
■In catalogs and other representations and advertisements concerning products andservices, do not use expressions that are untrue or misleading to consumers about thecontents, nor do they contain content that includes slander or infringement of rights
of other companies or individuals.

４－６

Protection of Identity and Non- Retaliation

Establish a consultation and reporting system that allows workers to raise concerns without fear of
retaliation, strive to prevent and detect misconduct at an early stage, ensure the confidentiality of
information and the anonymity of whistleblowers, and respond promptly to consultation andreporting cases.

【Details】■ Set contact persons for consultation and reporting regarding misconduct andmade them known to internal and external parties (the workers of our company
and suppliers). Promptly deal with any misconduct and feed back to thewhistleblower on the results as appropriate.

15

４－７

Responsible Sourcing of 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 policy on responsible minerals sourcing and promote due diligence toclarify whether minerals such as tantalum, tin, tungsten, gold, cobalt, etc. in the
products cause or have a part in 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.
※Personal information refers to information that can identify a specific individual by
name, date of birth or other description.
【Details】■Comply with applicable personal information protection laws and regulations whencollecting, using, storing, transferring and sharing personal information.
■Do not illegally or unreasonably acquired, used, disclosed, or leaked personal
information.

４－９ Appropriate Export and Import Controls
Establish a clear management system, and follow appropriate import and export
procedures regarding the import and export of technologies and goods regulated bylaws and regulations.

【Details】■Take procedures of obtaining permission, etc. as necessary from the regulatory
authorities, etc. when importing or exporting parts, products, technologies, equipment,
software, etc. that are regulated by laws and regulations based on international
agreements (Wassenaar Arrangement, etc.).

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】■Design your products to ensure sufficient product safety to fulfill yourresponsibilities as a manufacturer.
■With regard to product safety, comply with the requirements set forth by laws and16regulations, and also consider the safety required by society.
■In order to ensure product safety, manage traceability (history of standard operatingprocedures, materials, parts, processes, etc.), and take prompt action to solve
problems.

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.
Threats on computer networks include, for example, computer viruses, computer※worms, and spyware. If a computer connected to the internet is infected with acomputer virus, etc. it may cause a serious loss such as business stagnation involving
the entire supply chain, leakage of confidential information or loss of credibility. Cyberattacks are becoming more sophisticated every year, and since there is no such thing as
absolute safety, it is essential to promote continuous protection measures and damage
mitigation measures in case of an attack.
【Details】■Take measures to protect your company from threats on computer networks.
■Take measures to mitigate damage to your company in the event of an attack via
computer networks.
■For your company's domestic and overseas bases, verify the status of the above-mentioned
measures and residual risks, and consider additional measures at least once a year. Also,build a system or framework for this purpose.
■In the event that your company is attacked through a computer network, in order toprevent damage from spreading, promptly share information with the affected customers
and business partners.
■After identifying business partners and contractors of critical systems that are
particularly important to your company, grasp the status of those countermeasures, andreflect them in your company's consideration of countermeasures.

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 ofcontinuing business in the event of an unforeseen situation, such as a disaster or
accident, as part of a company-wide activities and carry out business continuity andearly recovery in an emergency.

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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
and customer requirements related to business activities and products, compliancewith the requirements of these guidelines, identification of risks related to thecontents of these guidelines, and prevention, elimination and reduction of theoccurrence of risks.
Management system should include the following:

８－１

Company Commitment

Post policies for continual improvement regarding the company’s "social responsibility"and "environmental responsibility" approved by management in the facility.
【Details】■Your company’s policies, approved by senior management, are prepared in local
languages and in languages understood by workers and are posted in the facility,
on the intranet, or in other locations with easy access so that workers can easily
view the content.

８－２Management Accountability and Responsibility

Appoint the corporate officers or representatives to ensure the implementation of the
management system and related programs, and conduct periodic management reviewsby the appointed management representative.

【Details】■Appoint management representatives in each of the areas of Labor, Health and
Safety, Environment, Ethics, Quality and Safety, Information Security, andBusiness Continuity Plan, which are described in the related documents(organization chart, job descriptions, management system documents, etc.)■Conduct management reviews at least annually (once a year).

８－３

Legal and Customer Requirements

Establish a mechanism to identify applicable legal and customer requirements,
including the requirements of these guidelines, and to monitor compliance.
【Details】■Record the monitoring results to understand the applicable legal and customer
requirements.

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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 significance for each risk and take procedures or physicalcontrols to address the risk.

８－５

Improvement Objectives

Develop improvement goals and implementation plans related to these guidelines, andperiodically evaluate the achievement of these goals.
【Details】■Evaluate the achievement of your improvement goals and implementation plans, andalso formulate additional action plans if progress is not being made as planned.

８－６ Training
Provide training for managers and workers to implement the company's policies andrelated initiatives and procedures.
【Details】■Include the content of these guidelines and applicable regulatory
requirements in your training. Keep records of the training and evaluate
its effectiveness.

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 efforts, hold explanatory meetings on these guidelines
for suppliers.

８－８Worker/Stakeholder Engagement and Access to Remedy

Evaluate workers' level of understanding of the contents of these guidelines and obtain
feedback and examples of violations from workers to establish an effective grievancesystem to foster continuous improvement. Also, provide opportunities for dialogue withworkers, their representatives, and other stakeholders as needed for continuous
improvement.

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【Details】■Reports of grievances or violations can be filed anonymously. Workers should beprotected from being treated unfairly without fear of retaliation

８－９

Audits and Assessments

Periodically assess the status of compliance with applicable laws and regulations, thecontent of these guidelines and the customer requirements.
【Details】■ Establish and implement self-evaluations and internal audit process to ensure
conformity with the content of these guidelines.

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 corrective action plans, managing
their progress, and verifying effectiveness after the 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】■Secure and appropriately manage the records of personal and confidential
information.

８－１２

Supplier Responsibility

Communicate the contents of these guidelines to your company’s suppliers andestablish a mechanism to monitor their status of compliance.

【Details】■Identify your primary suppliers, communicate the contents of these guidelines
to them and obtain their consent. Also, monitor the status of compliance tothese guidelines and understand the situation.

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９

CONTRIBUTION TO SOCIETY

Voluntarily engage in activities※ that contribute to the development of international
and local communities.
※

The activities to contribute to the development of global society and local communities

mean the support using company’s management resources.
・ Social contribution using regular business operation and existing technologies
・ Non-monetary social contributions using facilities and human resources, etc.
・ Social contribution through monetary donations【Details】■Determine the scope of activities your company can carry out and actively engage insocial contribution by cooperation with local communities in the event of a disaster,
employee volunteer activities, support for NPO/NGO activities, donation, dispatchof information, etc.

Related Guidelines:
Please also follow the guidelines below for green procurement and quality assurance.
・Furukawa Electric Group Green Procurement Guideline
・Quality Assurance Guidelines for Partners
https://www.furukawa.co.jp/en/procure/guideline.html

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 26, 2021 Referred to RBA Code of Conduct 7.0
Changed name to Furukawa Electric Group CSR Procurement Guidelines
Referred to RBA Code of Conduct 8.0

４th Edition: August 30, 2024
Publisher：

Furukawa Electric Co., Ltd.
Strategy Division Corporate Sustainability office
MONOZUKURI Innovation Division

Procurement Department

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