Compliance

Heart-to-Heart Communication between the President and Employees

“Heart-to-heart communication between the President and employees” meeting

Our New Frontier 2012 mid-term management plan declares our focus on the President's policy of thorough safety, quality and compliance in our business practices. We conduct our “Heart-to-heart communication between the President and employees” program so that the President can confirm for himself exactly how this focus on safety, quality and compliance is developed at our worksites and what activities are being undertaken, and for the President to get unvarnished opinions from employees on the spot. The program was conducted at six of our Works in fiscal 2011, where the Works Chiefs, Manufacturing Department General Managers, Forepersons, and Chief Operators sat down with the President to exchange opinions. We will expand the program to include our sales bases in fiscal 2012.

Compliance Roundtable

Compliance Roundtable for the Section Chief/Manager level

Members of the CSR Division visited the Furukawa Electric business bases for small-group roundtable discussions of compliance themes. 26 such meetings, delineated by rank, were held at 11 sites during the period May through July 2010, with a total of 200 employees in attendance. At the meetings, the CSR Division provided the results of the Employee Compliance Awareness Survey conducted in fiscal 2010, after which lively exchanges of opinion about compliance ensued. This of course enabled the unfiltered opinions of the participants about compliance to be expressed, while it also deepened the participants' understanding of compliance, making these roundtable discussions valuable.

The Employee Compliance Awareness Surveys are conducted reciprocally by Furukawa Electric and the affiliates in alternate years. In fiscal 2011, the Survey was conducted at 22 affiliates, with around 3,000 employees surveyed.

Monitoring

Strengthening the Group Auditing System and Functions

The CSR Division regularly tours each unit as well as the affiliates to conduct internal audits of business execution. Compliance was added last year to the list of important audit categories, and audits of 50 Headquarters units were conducted, mainly of those involved in manufacturing and sales, as well as at 30 consolidated subsidiaries. We also conduct internal audits at overseas affiliates, in addition to which outside experts in local laws and risks are enlisted to conduct special audits.

Voluntary Compliance Checks

Furukawa Electric has designated October and November of each year as “compliance months,” during which we execute our company-wide compliance activities. In fiscal 2011, we newly added checking using Individual Compliance Review Check Sheets and Area-Specific Check Sheets pertaining to individual areas such as the Anti-Monopoly Act. We will expand the range of items covered by the Area-Specific Check Sheets and continue to increase our Voluntary Compliance Check system.

We conduct compliance education for employees at every level of the company, from new recruits to directors. We published the Furukawa Electric Group CSR Compliance Handbook (4^th Edition), which explains the CSR Code of Conduct and other compliance-related matters, for use as a textbook, and develop compliance education throughout the Furukawa Electric Group in fiscal 2012.