Compliance

About Compliance

What does “compliance” mean in general?

Compliance refers to the act of following laws, regulations, standards and policies that apply to a particular industry or organization. Compliance is important because it helps to ensure that companies and individuals are acting in a way that is consistent with the rules and regulations that are in place to protect consumers and society in general, as well as employees and companies themselves. Non-compliance can have legal and financial consequences and damage a company’s reputation.

 

How does Fujifilm understand compliance?

In the Fujifilm Group Compliance Statement, compliance is defined as more than simply not breaking the law:

“We believe compliance includes acting correctly in the light of common sense and ethics. In all aspects of our corporate activities, we emphasize compliance and endeavour to create new value. If compliance requirements conflict with business profits or the demand of third parties, we give priority to compliance. An open, fair, and clear corporate culture is the basis for all our activities.”

 

Fujifilm Europe Whistleblowing System

In cases where open communication is not possible, we offer all internal and external parties a secure and confidential way to report concerns about violations of laws or company policies, serious misconduct, or other irregularities in Europe, the Middle East and Africa. Fujifilm employees and external stakeholders like customers or suppliers can raise their concerns to Fujifilm through this website via a protected login procedure:

Fujifilm Europe Whistleblowing System

The system is hosted and managed by an independent third party supplier. It is available 24-hours-a-day, 365-days-per year and stored on secured servers in Germany. The system is available in Czech, Dutch, English, French, German, Hungarian, Italian, Japanese, Polish, Portuguese, Russian, Spanish and Turkish. 

What incidents can you report?

• Corruption or conflict of interest
• Competition law or antitrust violations
• Theft or fraud
• Improper accounting, auditing, finance or tax violations
• Discrimination, harassment, workplace violence, unethical behavior
• Safety, health or environmental issues
• Data protection and data security violations
• Other significant breaches of laws or regulations

Who receives and examines your report?

Incoming reports are initially handled by Fujifilm Europe’s Compliance Department at Fujifilm Europe’s headquarter in Germany. Each report will be treated as strictly confidential and handled with the highest degree of care and attention. Depending on the nature of the incident, selected individuals within other functions of Fujifilm may also need to be added to the incident management team under strict adherence to confidentiality.

Is anonymous reporting possible?

Yes! The Fujifilm Europe Whistleblowing System allows to report an incident anonymously. The anonymity is protected by means of a secured web-based postbox which can be accessed via a protected login procedure with username and password. The system allows to communicate with Fujifilm Europe’s Compliance Department back and forth without revealing your identity, if desired.

Nonetheless, Fujifilm explicitly encourages you to disclose your identity when making use of the Fujifilm Europe Whistleblowing System. Knowing the identity of the person who submitted the report often proves to be advantageous for both incident handling and subsequent improvement actions.

Am I protected against retaliation?

Yes! Internal whistleblowers who report their concerns in good faith are protected against any kind of retaliation by company policy.

We appreciate your support to combat corruption, safeguard integrity, enhance accountability, and support an ethical business environment. By using Fujifilm Europe’s Whistleblowing System whenever necessary, you help us to identify wrongdoings in the organization and eradicate them in a prompt, professional and confidential way.
More information regarding the whistleblowing system is available here:

Fujifilm Europe Whistleblowing System

 

Which topics is the Compliance & Risk Management Team responsible for?

The Compliance & Risk Management Team is primarily responsible for the prevention, identification and remediation of compliance risks in the following areas:

Global Code of Conduct

Fujifilm Group’s Code of Conduct provides guidelines for employees on the following topics:

1. Respect for human rights

   Respecting human rights includes that we embrace diversity, that we do not discriminate for any reason such as nationality, gender, ethnicity or religion, that we do not engage in any form of bullying or harassment, and that we do not take part in human trafficking, forced labour or child labour.

2. Fair corporate activities

   We strive to ensure that our corporate activities are open, fair and clear. This includes that we communicate openly, that we compete fairly and in accordance with antitrust and fair-trade laws, that we prevent bribery and corruption, and that our products and services are safe.

3. Protection and preservation of corporate assets and information

   The use of company assets or assets of business partners, such as information, is essential for our success. We protect such assets, manage them properly and do not abuse them for our own personal benefit.

4. Measures related to environmental issues

   Environmental issues are one of the major challenges that humanity is facing. We will work together to help achieve a carbon-neutral society, contribute to a circular economy, e.g., by recycling of resources, and take measures to ensure a safe and effective use of chemicals.

These guidelines must be followed by all executives and employees of the Fujifilm Group in their daily business activities. Like this, Fujifilm will continue to be a company that is needed and trusted by society.

Anti-Corruption

Corruption refers to the act of using one’s position or influence for personal gain or to benefit a company or a particular individual. The most common form of corruption is bribery. Bribery is the act of offering, giving, requesting or receiving any kind of benefit in order to unduly influence a business decision or official action. Any kind of benefit may be suitable as a bribe – be it money, a gift, any kind of invitation, donation or even loaning out equipment free of charge.

Examples:

1. A Fujifilm sales representative invites a healthcare professional and her spouse to a weekend stay at a luxury hotel in order to influence the healthcare professional´s decision to purchase Fujifilm products for her practice.

2. A public official mention that his wife’s charity organization is looking for new donors. He indicates that a generous donation from Fujifilm would prompt him to approve a new Fujifilm product more quickly so that it can be launched before the competition.

Competition Law

Competition law is designed to promote and protect competition by preventing anti-competitive practices such as cartels. Competition law aims to ensure that businesses are able to compete with each other on a level-playing field, and that consumers have a choice of products and services at competitive prices. It aims to prevent the abuse of market power and collusion between competitors, such as price fixing, market allocation, or bid rigging, which can lead to higher prices and less choice for consumers.

Examples:

1. Bid rigging: A competitor asks Fujifilm to let him submit the lowest bid for a public tender for CTs that both companies are participating in. In return, the competitor promises to let Fujifilm win in the next tender. If both companies had genuinely competed with each other, their bids would have been much lower both times.

2. Price fixing: Fujifilm coordinates with a competitor to offer the same 50% discount on photo paper in January. The ultimate goal is to drive a third competitor out of the market.

Anti-Money Laundering

Money laundering refers to the act of disguising the proceeds of illegal activities (e.g., drug trafficking or corruption) as legitimate funds. This is typically done through a series of financial transactions designed to obscure the true source of the funds and make it difficult to trace their origin. Money laundering can take many forms and may involve complex financial transactions and the use of shell companies, offshore accounts, and other means to conceal the true nature of the funds. Money launderers may also use legitimate businesses to launder money, such as casinos, real estate firms, or companies like Fujifilm.

Example:

The invoice issued by Fujifilm to a new customer is not paid by the customer itself, but by another company unknown to Fujifilm (so called Third-Party Payer). A background check reveals that this third party is a shell company located in tax haven Panama and has a record of being involved in illegal activities like cybercrime.

Business Crimes

So-called white-collar crimes are non-violent crimes that are typically committed by business professionals. These crimes are usually financially motivated and involve the use of deception, fraud or other forms of misrepresentation to obtain money, property or some other benefit.

Examples:

1. Embezzlement: An employee who has been entrusted with funds to purchase new equipment for the office, misuses those funds to buy personal items.

2. Fraud: Fujifilm receives what appears to be an email from a long-term supplier asking to change the bank account to which Fujifilm makes all payments for services purchased from that supplier. It later turns out that the supplier never sent such a request. A fraudster had forged the supplier’s email address and used his own bank account to receive the funds.

Data Protection

Data protection refers to the practice of safeguarding sensitive and personal information, i.e. any information relating to an identified or identifiable natural person, from unauthorized access, use, or disclosure. This involves implementing contractual measures such as data protection agreements as well as polies and technical measures and protocols to ensure that data, whether digital or physical, is kept secure and its privacy is upheld.

Disposal of electrical appliances used exclusively for commercial purposes (B2B appliances)

The Electrical and Electronic Equipment Act (=ElektroG) regulates take-back obligations for electrical and electronic devices, as well as their environmentally sound disposal. To ensure that we fulfill our take-back obligations and that any devices we put on the market for commercial use (B2B) get disposed environmentally soundly, we selected a certified disposal company as our partner. Please permanently delete any personal data potentially remaining on the devices before handing them over to the disposal company. Please contact us whenever you wish to return one of our devices for commercial use via the email-address Product_Compliance_EU@fujifilm.com.

We are registered at the stiftung elektro-altgeräte register under the WEEE registration number DE69891307 and the battery registration number DE30276443.

Addtionally, we are registered at the Stiftung Zentrale Stelle Verpackungsregister under registration number DE3866425733906.