cO

FUJITSUAIR CONDITIONING

Fujitsu General Air Conditioning
UK Limited
Modern Slavery Transparency
Statement
Publication Date: August 30, 2022
Executive Owner: Hirofumi Fuji

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement August 2022

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Contents
1.

lntroduction .............................................................................................................................................22.

Our Business, Structure and Supply Chains ..............................................................................................2

3.

FGG Policies ......................................................................................................................... .................... 4

4.

Risks of Modern Slavery Practices ............................................................................................................55.

Due Diligence Processes .......................................................................................................................... 6

6.

Training ...................................................................................................................................................8

7.

Effectiveness ............................................................................................................................................88.

Approva 1 •••••••• • •••••••••••••••••••••••••••••.............•.•••••••.••••.•..•••••...••••.••••.•..•••..•••.•..••....•...........•.••...••••••••••••••••••• 8

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement August 2022

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1. Introduction
At Fujitsu General Air Conditioning UK (FGACUK) we acknowledge that acting in line with the UK Modern
Slavery Act (MSA) is of paramount importance to FGACUK and we take our commitment to preventing modern
slavery very seriously.
Section 54 of the UK MSA 2015 requires businesses to disclose information relating to their efforts to assess
and address the risks of modern slavery and human trafficking in their operations and supply chains. The
following Statement responds to these requirements and outlines our efforts to combat modern slavery during
the financial year ended 31 March 2022.
The modern slavery reporting entity is FGACUK with its UK Head Office at Unit 150, Centennial Park, Centennial
Avenue, Elstree, Hertfordshire, WD6 3SG, U.K

2. Our Business, Structure and Supply Chains
Our Business
FGACUK purchases air conditioners produced by Fujitsu General Group's (FGG) air conditioner manufacturingsubsidiaries and sells them in the UK. FGG's air conditioners are the result of more than 60 years of advanced
design and development.
FGACUK employs 32 people in the UK. FGACUK procures and imports finished goods and spare parts into the
UK and provides post-sales support. FGACUK uses a 3rd party warehouse company for product storage anddelivery, along with its own warehouse for spare part storage. FGACUK sells its products to wholesalers, airconditioner specialists and installers.

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

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement August 2022

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

•
•

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

As at March of 2022 FGL had 1,710 employees and FGG had 8,398 employees.
FGACUK also uses a third party warehouse company for product storage and delivery.

Red Flags and Potential Risk Areas
Modern slavery can take many forms; of most relevance to FGACUK is the risk that manufacturers in the FGG's
supply chain might use forced labour, debt bondage or child labour. FGACUK recognises the possibility thatmodern slavery practices such as forced labour, debt bondage and child labour may exist in the operations ofservice and parts suppliers in the manufacturing sector that support its operations in Thailand and China .
The International Labour Organisation (ILO) has estimated that more than 40 million people are in some formof slavery today and that approximately 24.9 million of those are in forced labour. The International
Organisation for Migration estimates that 62% of people living in modern slavery are in the Asia-Pacific region
and that more than US $51 .8 billion each year is made in illegal profits in Asia from trafficking in forced labour.
FGACUK recognises that it has independent responsibility to combat modern slavery and has taken steps to
implement the recommendations of the UN Guiding Principles on Business and Human Rights.

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement August 2022

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3. FGG Policies
FGG's response to modern slavery is led by FGL's Corporate Vice President, Toshio Kano, Head of Sustainability
and General Manager of the Sustainability Promotion Division at the Head Office. Day-to-day responsibility
for modern slavery within each subsidiary of FGG sits with the Chief Executive Officer of each business unit.
The policies of CSR are created by the Division of Sustainability Promotion. The General Manager of Office ofSustainability Promotion are overseen by Toshio Kano, Corporate Vice President.
The Sustainability Promotion Department develops and reviews the CSR Procurement Guidelines andconducts on-site audits to ensure their effectiveness. The Sustainability Promotion Department is
responsible for the process of monitoring the FGG's CSR activities throughout the supply chain. The
Sustainability Promotion Department reviewed the CSR Procurement Guidelines for effectiveness andproduced an updated version in August 2020. In FY2022, FGG plans to revise the CSR Procurement
Guidelines, to align to changes from version 6 to version 7 of the Responsible Business Alliance Code of
Conduct.
As a subsidiary of FGL, FGACUK takes its corporate social responsibilities seriously. FGACUK is required tocomply with FGL policies and regulations, including the Corporate Social Responsibility (CSR) Guidelines (CSR
Procurement Guidelines).

Fujitsu General Way - Code of Conduct
Ethical behaviour is of the utmost importance to FGACUK and our commitment to instilling this within ouroperations begins with the Fujitsu General Way Code of Conduct ("The Code of Conduct"). The Code of Conduct
sets out the expected behaviours of our people, including to act ethically and to respect human rights.

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

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

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement August 2022

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4. Risks of Modern Slavery Practices
FGACUK recognises the possibility that modern slavery practices may exist in the operations of service andparts suppliers that support its operations in Thailand and China.
According to the Global Slavery Index issued by The Walk Free Foundation, in 2017 there were more than 62.1
million migrants in the Asia-Pacific region. Migration within the region is most often from developing
countries in the South to the more developed countries in the North. The migrating workers are often unskilled,uneducated or poorly educated and at a significant economic disadvantage in their new work environment.
FGACUK recognises a risk that migrating workers employed in the Asia-Pacific might be subject to high service
fees from recruitment agencies, labour placement organisations and employers. There is a risk that their travel
identity documents may be taken by the labour service provider or employer so that they cannot find adifferent or better paid position. There is also a risk that underage workers may be engaged. In summary,
FGACUK recognises a need to combat the possibility that organisations within its supply chain are using forced
labour, employees are subject to debt bondage or child labour is being used.
The factors listed in the previous paragraph contribute to a risk that individual workers in the rapidly growing
economies of Thailand and China may suffer exploitation in the form of modern slavery.
In terms of prevalence, the Global Slavery Index 2018 gives China a low prevalence rating and Thailand a highprevalence rating, estimating 2.8 victims per thousand and 8.9 victims per thousand respectively (see page
31 table 1 of the Asia and the Pacific Report). Although the Global Slavery Index gave China a low prevalence
rating in 2018, recent news articles about Uyghur forced labour in Xinjiang suggest that the prevalence ofmodern slavery could be higher than the 2018 rating. China has also been found to have the highest absolute
number of people living in modern slavery.
On page 34 (table 2) Thailand and China have similar ratings of 51.1 and 50.6 in terms of vulnerability tomodern slavery by country, ranked 12 th and 13 th , respectively. However, it should be noted that Thailand'shigh rating is partly a result of the conflict in Thailand's southern border. FGG does not have any facilities inThailand's provinces. Thailand and China are ranked 5th and 20 th respectively in the region based on eachcountry's government response to issues associated with modern slavery between 2016 and 2018.
FGACUK notes that laptops, computers and mobile phones manufactured in China are the top-rated categoryof product at risk of modern slavery, according to table 3 of the Global Slavery Index report. Although FGACUK
does not import or sell laptops, computers or mobile phones, the manufacturing processes associated with
consumer electronics is considered analogous to processes used to construct air-conditioners, and therefore
FGACUK recognises a potential risk in the manufacture of such products.

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement August 2022

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FGG Manufacturing Facilities
The table below summarises the source of components across FGL's manufacturing facilities:
Fujitsu General (Shanghai)Co.,Limite dCountry of origin of components used in

Fujitsu General (Thailand)Co.,Limited
Country of origin of components used in

manufacturing

manufacturinng
JAPAN
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THALANO■ FY2021■ FV2021 ■ FY2020■ FY2020

FGA (Thailand) Co.,limited
Country of origin of components used in

Fujitsu General Central Air-Condition er(Wuxi)Co. Ltd Country of origin ofcomponents used in m anufactu ring

manufacturing

CHINA

6.7%
3.7%

THAILAND■ FY2021■ FV2020■ FY2021■ FY2020

The table below is a summary of the source of components across all manufacturing facilities:
All Fujits u General M anufa ctu ring Faciliti es
Count ry of origin of com ponents used in manufacturing

INDON ESIA

0.02%
0.03%

MALAYSIA

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I o.6%JAPAN

THAILAND

Q-IINA

59.1%■ FY2021■ FY2020

5. Due Diligence Processes
Operations
FGCACUK performs background checks on all employees, including identity verification, to confirm age andplace of residence. The Rules of Employment stipulates the minimum age for employees employed by theCompany.
All employees receive training on the Fujitsu General Way Code of Conduct ('The Code of Conduct") , which sets
out the expected behaviours of our people. The Code is also communicated to all employees at least once ayear. We use internal controls to monitor the compliance of our employees, and in the case of non-compliance
we take action in accordance with the Employment Regulations.

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement Augu st 2022

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A corporate ethics helpline has been established and is in operation. The helpline is available to any officers
and employees who work for FGG (including FGACUK). contract employees, loaned employees and temporary
staff who come across unethical business conduct or behaviour, including suspected instances of modern
slavery. Reporting through the corporate ethics helpline can be made anonymously. Employees are madeaware of the helpline through the internal portal and via regular emails.
Responsibility for investigating and mitigating the risks of modern slavery sits with the Sustainability
Promotion Division at FGL, in conjunction with the relevant departments.
In FY2021, FGG conducted human rights due diligence on FGL's Head Office. We plan to conduct human rights
due diligence at our major foreign subsidiaries approximately once every three years.
In addition, FGG plans to establish a whistle-blowing mechanism at FGL to serve as a contact point for external
parties, including primary suppliers in Japan . The FGG's whistle-blowing mechanism provides a system(Including No Retaliation Clause) for the appropriate handling of reports and consultations regarding
compliance violations.

Supply Chain
Adherence to C5R Procurement Guidelines
Since November 2019, suppliers of FGG are asked to agree to the CSR Procurement Guidelines prior to onboarding. For suppliers on-boarded prior to November 2019, consent was obtained after on-boarding once
again. As of March 31, 2022, 1,097 out of 1,132 suppliers signed up, using the CSR Procurement Guidelines
consent confirmation form. Of the suppliers that have signed up using the guidelines, 657 are in Japan, 277
are in China and 163 are in Thailand. FGL's top 10 suppliers have agreed to comply with the CSR Procurement
Guidelines.
Commencing in November of 2019, FGL assessed suppliers for compliance with the CSR Procurement
Guidelines. The CSR Procurement Guidelines set criteria for the evaluation and selection of suppliers.

Supplier audits
FGL select suppliers for audits based on spend, how critical the supplier is to the business, country risk and therelationship with the supplier.
The review process is conducted by the Sustainability Promotion Division according to rules created andimplemented by the Division:•••

Before a supplier is audited, they are requested to complete a Self-Assessment Questionnaire (SAO).
Then, the Sustainability Promotion Division conducts a CSR local audit using a detailed version of theassessment questionnaire, and compares the results of the self-assessment with the results of theon-site audit.
Having reviewed the results, the Sustainability Promotion Division provides guidance on
improvements and corrective actions to the supplier.

The aim of conducting the SAO on the CSR Procurement Guideline questionnaires and local audits is to workwith suppliers to improve their compliance and performance over time by creating an opportunity for
improvement and providing support to suppliers that are willing to invest and improve.
During the fiscal year 2019, FGG asked suppliers to complete the SAO on CSR procurement guidelines andconducted three on-site audits in China (November 2019) and Thailand (September and December 2019).
FGG planned to conduct 12 times local audits in the fiscal year 2021, but they were cancelled due to COVID19. In lieu of the local audits, FGG requested that its suppliers complete the SAO on the CSR Procurement
Guidelines. Two suppliers in Japan, two in China and one in Thailand completed the SAO in FY2021. The
survey did not uncover any modern slavery issues. Although we will continue to monitor the impact of the
new coronavirus infection, we plan to conduct 12 on-site audits in FY2022.
We have not identified any cases of modern slavery in our operations or supply chain through our reviews andaudits to-date.

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Modern Slavery Statement August 2022

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6. Training
All employees receive training on human rights via e-learning as part of the Fujitsu General Way Code of
Conduct training ("The Code of Conduct"). The Code of Conduct is communicated to all employees at least oncea year. We use internal controls to monitor the compliance of our employees, and in the case of noncompliance we act in accordance with the Employment Regulations.
Commencing in November of 2019, FGG started to provide CSR Procurement Guidelines training for suppliers,
to introduce and explain the CSR initiatives and guidelines. Briefing sessions have been held for suppliers
across Japan, China and Thailand.
In FY2021, we also conducted an e-learning course on human rights to provide all directors and employeeswith basic knowledge and awareness of "business and human rights" from a global perspective, and toencourage them to think about human rights issues as "their own issue" and act.

7. Effectiveness
FGACUK recognises that our review and assessment of our actions to identify and address modern slavery risks
across our operations and supply chain will be an ongoing and evolving process. We use the following Key
Performance Indicators (KPl's) to better understand the effectiveness of our approach to managing modern
slavery risks:
1) Ensuring all suppliers have signed up to the CSR Procurement Guidelines2) Implementing the SAO on the CSR Procurement Guidelines -An additional five suppliers during FY2021
were requested to complete the SAO - 2 Japan, 2 China, 1 Thailand, all suppliers completed them.
In FY2022, we plan to expand the number of suppliers performing SAOs.
3) Conducting on-site audits using the detailed version of the assessment questionnaire (target number ofsuppliers per year: 12 companies)
Due to the impact of COVID-19, we did not complete item 3) in 2021.
In 2022, we aim to work towards following up on our new Policy which clarifies that we do not tolerate childlabour or forced labour in FGG's supply chain.
Over subsequent reporting periods we will continue to review and evaluate these KPl's and develop future
metrics to assess the effectiveness of our actions, and enhance our monitoring over time, in line with
continuous improvement.

8. Approval
This Modern Slavery Transparency Statement for the year ended March 31, 2022 has been approved by the
Board of Directors of FGACUK, on August 30, 2022 .

Hirofumi Fuji, Chief Executive Officer

FUJITSU GENERAL AIR CONDITIONING UK LIMITED
Modern Slavery Statement August 2022

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