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1/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Quality Compliance
2/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Background of the course
Major improper activities concerning quality by Japanese companies (2000-2017)
2000 Covering up of recalls by an automotive manufacturer
2002 Falsification of production venue of beef by a food manufacturer
2005 Forgery of a structural statement
2007 Falsification of quality labeling of minced beef
2015 Falsification of piling data
2017 Inspection by unqualified personnel at an automotive manufacturer
Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc.
Such improper activities would ruin brand images, and impact management / operations.
This is because Japanese society has become rapidly compliance oriented, and strict
compliance to laws and regulations, rules, agreements, etc. has become necessary.
We have conducted inspections and reviews on general quality management at Fujikura
Group.
As a result, many improper cases have been reported, and we ended up announcing these
cases externally in August 2018.
Many improper activities concerning quality by leading Japanese companies
have been reported across many industries / trades since the year 2000.
3/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Definition of improper activities concerning quality
In this course, “improper activities concerning quality” are defined as:
“Intentional” violation of laws and regulations, public standards, and/or
agreements with customers regarding quality and/or labeling of products
and/or services.
However, it is worth noting that violations caused by negligence should also be avoided
as a matter of course.
Some examples are:
 Falsification of inspection records
Filled an inspection forms and reports with false data.
 Did not carry out inspections
Inspections agreed with a customer were not carried out.
 Difference in inspection method
Inspection was carried out by a different method from what had been agreed with a
customer.
 4M change procedure not carried out
Application to a customer when manufacturing conditions are changed as agreed with the
customer was not carried out.
 False report regarding process capabilities, manufacturing environment, etc.
Even though there is an agreement with a customer on process capabilities, manufacturing
environment, etc., a false report on them was made to the customer.
4/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Purpose of the course
“Compliance” has been understood as “compliance to laws and
regulations,” but it also entails compliance to agreements with
customers, rules, etc.
“Regarding the laws and regulations,” educational courses on the
Anti-corruption Law, the Antitrust Law, and the Subcontract Law are
carried out at Fujikura Group.
In this course, however, we focus on the people’s behavioral
awareness that may lead to improper activities concerning quality.
Let’s attain common understanding as to the “people’s behavior” from
top executives to temporary employees.
Let’s meet trust from our customers and contribute to society by
understanding what quality compliance is through this course.
5/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Contents
As a beginning,
2.1 We will explain improper activities concerning quality in Japan before
presenting how to avoid progression of such activities with examples.
Then,
2.2 We will present the Fraud Triangle proposed by Professor Donald
Cressey, who specialized in organized crime, as the background of such
improper activities.
And finally,
2.3 We will check Fujikura Quality Policy, which plays an important role in
the quality compliance activities.
Additionally,
3.1 A comprehension check is waiting for you. So learn carefully.
6/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.1 Improper activities concerning quality in Japan
As a beginning,
we will explain improper activities
concerning quality in Japan.
Contents are:
1.1 Major improper activities concerning quality by Japanese
companies
1.2 Improper activities concerning quality
1.3 Mechanism of falsification / covering up
1.4 Why you think “It is OK” when actually it isn’t?
・Case 1: Falsification of shipping inspection data
・Case 2: Covering up of nonconformity
1.5 To avoid the progression of such improper activities
concerning quality
7/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.1.1 Major improper activities concerning quality by Japanese
companies
Major improper activities concerning quality by Japanese companies (2000-2017) [Repeated]
2000 Covering up of recalls by an automotive manufacturer
2002 Falsification of production venue of beef by a food manufacturer
2005 Forgery of a structural statement
2007 Falsification of quality labeling of minced beef
2015 Falsification of piling data
2017 Inspection by unqualified personnel at an automotive manufacturer
Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc.
Complex factors exist behind these
improper activities concerning quality
8/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.1.2 Improper activities concerning quality
Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc.
At the Japanese Society for Quality
Control, “improper activities
concerning quality” are discussed.
Improperactivitiesconcerningquality
(1) Lack of know-how
(inferior technology)
(2) Improper activities concerning know-how
(improper management)
Improve the technology
(i) Intentional (crime)
(ii) Falsification / covering up
Not covered
here
Next
Divided into two categories
Further divided into two categories
9/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.1.3 Mechanism of falsification / covering up
How does the [falsification / covering up] takes
place?
Let’s consider operations differing from the
standard documents (rules).
Lack of knowledge
Lack of skills
Careless mistake
No
Creation of and education on standard documents
You think “It is OK” when actually it isn’t
Evaluation / training of skills
Error proof
e.g.
Automation
No
No
Yes
Yes
Yes
Were you aware of the standard
documents?
Can you comply with the standard
documents?
Were you trying to comply with the
standard documents?
10/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.1.4 Why you think “It is OK” when actually it isn’t?
To comply with rules, consider
• the reasons why they are
established, and
• recognition and evaluation of
risks when they are violated.
Under what circumstances do you tend to think “It is OK” even
though it isn’t?
You think “It is OK,” since decision making based on
(i) Effect of complying with rules and
(ii) Efforts to complying with rules
are not properly carried out.
Effortsto
complyingwithrules
Effectof
complyingwithrules
Compliant
Notcompliant
Effectof
complyingwithrules
Effortsto
complyingwithrules
Compliant
Notcompliant
Effortstocomplying
withrules
Effectofcomplying
withrules
Compliant
Notcompliant
Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc.
11/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Case 1: Falsification of shipping inspection data
Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc.
Let’s take a look at the cases where improper activities concerning quality took place.
Circumstances
Understanding of the
person in charge
Improper activities
Efforts to complying with
rules
Omission of sampling inspection before shipmentScene
 Inspection methods are standardized
 The person in charge of the inspection was delegated the
authority of implementation
 100% automatic inspection was carried out during the
manufacturing process
 It takes time to carry out sampling inspection
 The PIC judged without proper reasons that sampling
inspection before shipment was unnecessary
 Use of old data for the falsification
12/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Case 2: Covering up of nonconformity
Let’s take a look at the cases where improper activities concerning quality took place.
Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc.
Circumstances
Understanding of the
person in charge
Improper activities
Efforts to complying with
rules
Shipping inspectionScene
 Inspection methods are standardized
 The person in charge of the inspection was delegated the
authority of implementation
 Failing acceptance inspection by the customer may result
in insufficient supply
 Changes to standards or operation methods take time
before obtaining the customer’s approval
 Judged that the standards are not rational, without
proper reasons
 No accident happened where the inspection results
affected safety
 Passed nonconforming products, etc. by rewriting the
inspection report
13/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.1.5 To avoid the progression of such improper activities
concerning quality
Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc.
In the next chapter, the background of why improper activities concerning quality
take place will be examined in detail.
How can we avoid the progression of improper activities concerning quality?
Manage the complexity of operation
* Make routine operations simple, effective, and efficient as necessary
How to proceed with establishing rules and delegation of authority
* Clarify the person who judges and decides after assuming possible issues
when establishing rules and delegation of authority of routine operations
Development and management of personnel
* Educate / train personnel who are in charge of information reporting so
that they understand the importance of information and all have fair
recognition of adverse effects caused by creating and reporting information
14/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.2 Background of the improper activities
Next, we will explain
Background of the improper activities.
Contents are as follows:
2.2.1 What is “Triangle of improper activities”?
2.2.2 What is “motivation”?
• Types of motivation
• Self-check of “motivation”
• How to deal with “motivation”
2.2.3 What is “opportunity”?
• Malfunctioning and emasculation of rules
• Self-check of opportunities
• Dealing with the opportunities
• “Internal Reporting System” of Fujikura Group
2.2.4 What is “justification”?
• Self-check of “justification”
2.2.5 What would you “lose”?
15/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Source: Created based on “System Fraud Triangle”
2.2.1 What is “Triangle of improper activities”?
American specialist in
organized crime
D. R. Cressey
(1919~1987)
Motivation
Circumstances of the PIC
and trigger
Justification
Excuse
Opportunity
Work environment
Improper activities
Professor Donald Cressey, who was an American specialist in organized crime,
proposed three factors behind improper activities in 1953, which was published
as the Fraud Triangle in 1991 by Professor Steve Albrecht.
Objective circumstances
Obvious to anyone
Subjective circumstances
Internal to the person in charge
Improper activities take place when all three
factors come together
16/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
e.g., Omission of sampling inspection before shipment
Improper activities take place when all three factors come together
If any one of the factors is missing, the improper activities are hard to take place
Above mentioned
“Falsification of inspection data prior to shipment (omission of sampling
inspection before shipment)” will be examined based on the three factors.
The three factors of “motivation,” “opportunity,”
and “justification” will be explained next.
Motivation
Circumstances of the PIC
and trigger
Three factors of improper activities
Opportunity Work environment
Justification Excuse
I need to go home early because one of my family
members is sick
Omission of sampling inspection before shipment
Inspection is carried out by one person
This person can bring an approval stamp outside
Past omission of the inspection did not cause
problems with the characteristics
17/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.2.2 What is “motivation”?
Let’s examine “motivation” that is important in people’s behavior.
Here, “motivation” is a set of subjective circumstances that motivate
improper activities.
In other words, it is a feeling that improper activities are critical in
solving “one’s own desires / worries.”
Even under similar circumstances (opportunity),
• Depends on the “person,” or
• If he/she is inexperienced or experienced for a
prolonged period of “time,”
the circumstances may or may not constitute a motivation.
Source: Created based on “Fraud Triangle” by D-Quest Group and “Courses for Raising Sensitivity
for Company Ethics and Compliance” by the Japan Management Association
18/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Types of motivation
Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
Motivation
Circumstances of the PIC and
trigger for doing improper
activities
Strong personal desire
• Improving treatment
• Fear of dismissal or
unemployment
Job related problems
• Cannot achieve the target
Problems that cannot be solved by laws and regulations,
or company rules
• Dissatisfaction against the company
• Grudge against the boss
Pressure
• Strong pressure for accomplishing the
assignment
Private problems
• Sickness of a family member
Let’s examine what can be a motivation.
You can see that “anything around you” can result in a
“motivation” of improper activities for any kind of person.
19/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Check the “motivation” yourself!
You can see that anybody has
“motivation” for improper activities.
Source: Created based on Wisdom Bag for Labor Management
and “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
Now start the self-check.
Some of the examples are as follows:
• I made a mistake in the job and cannot report it to the boss
• A difficult goal that I cannot achieve is imposed
• I have a job whose due date is hard to keep
• I can make profit by committing an unjust activity
• I have a grudge feeling for treatment by the company such as salary
or position
• I am anxious about dismissal or unemployment
If even one of the above is applicable, it is important to recognize that you have a
risk for committing improper activities
20/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
How to deal with “motivation”
Every job entails a certain level of “pressure.”
However, if you continue to be under extreme pressure, you
may be unable to make correct decisions.
The “pressure” may lead to “improper activities.”
Then how can we deal with such a situation?
• Taking good care of your own mental health,
• Having someone from whom you can seek advice, etc.
are some of the measures.
If you have subordinates,
• Be careful whether your subordinates make a conjecture about your hidden
intention to take an improper action
e.g., Let’s make every effort to achieve the goal
→You can do anything to achieve the goal
• Clarify the system and standards of evaluation / promotion and make them
known to the subordinates
Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
21/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.2.3 What is “opportunity”?
“Opportunity” here refers to an objective environment that facilitates the
conduct of improper activities.
In other words, it is a work environment in which you can do improper
activities whenever you want to.
Work environment can be divided into two types.
 “Position”
• Doing a specific job by one person
• Only one person knows the job
• Only one person can do the job
 “Authority”
• Authorized to use an approval stamp all by oneself
Source: Created based on “Fraud Triangle” by D-Quest Group and “Courses for Raising
Sensitivity for Company Ethics and Compliance” by the Japan Management Association
22/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
“Malfunctioning” and “emasculation” of rules
Normally, it is “natural” to deal with a work process by stipulating “rules
and systems” so that improper activities with “position / authority” may
not take place.
But in actual cases,
 Malfunctioning … neglecting rules
• Criteria are not met, but since there is no problem with
the performance, I will put the stamp of “pass” here.
 Emasculation … loophole of the rules
• You can put the stamp of “Inspected” even though it has
not been inspected.
Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
You are expected to
• Discover,
• Share within the division, and
• Eliminate
the “opportunities” of “risks for improper activities” that can
occasionally be seen in the workplace.
23/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Check the “opportunities” yourself!
Eliminating risks of the “improper activities” at the
“opportunities” will tip the balance of the “triangle of the
improper activities,” thereby preventing the “improper
activities” from taking place.
Now, check your own workplace.
Some of the examples are as follows:
 Examples of “position / authority”
• Doing the same job for a long period of time
• Some of the jobs are not transparent to people other than the PIC
 Examples of “malfunctioning / emasculation”
• Rules for approval and/or decision making are not determined for some of the jobs
• Some of the jobs are undertaken by a person who does not deserve the authority
(approval stamp)
• There are rules that are not kept or are not functioning
Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
If even one of the above is applicable, it is important to recognize that you have “risk(s) of
improper activities” by “opportunities.”
24/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Dealing with “opportunities”
(i) Ask your colleagues about their stories and for their opinions.
→Problems would surface by sharing information.
(ii) Report to / consult your boss
→ If you address your boss as follows,
“Points would become clear and the argument would become concrete”
so that your boss will understand your point smoothly.
• Use questions…e.g., “Is the customers’ quality information well
managed?”
• Point out…e.g., “Anyone can bring the customers’ quality
information outside.”
• Propose…e.g., “You need to review how the customers’ quality
information is stored.”
What should you do if you discover “opportunities” that may
lead to improper activities in the workplace?
25/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.2.4 What is “justification”?
“Justification” here refers to a subjective environment that can be used to
accept the conduct of improper activities.
In other words, it means overcoming “qualms” that you feel when conducting
improper activities by inventing reasons that are favorable to you.
This is a matter of personal ethics.
Some examples are as follows:
• There are no rules in the company
• Colleagues are also doing it
• I am not evaluated fairly
• Improper activities (omission of inspections, etc.) does not affect quality,
etc.
• To improve performance of the department and/or company
• Prioritizing delivery date will lead to the next order
Source: Created based on “Fraud Triangle” by D-Quest Group and “Courses for Raising
Sensitivity for Company Ethics and Compliance” by the Japan Management Association
26/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Check “justification” yourself!
Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
Judgment criteria of “good or evil” depend on one’s personal ethics.
Ethics may be different for each person.
Such variation may lead to improper activities in daily operations.
Let’s discuss the situation at your workplace.
If everyone in the workplace all has common perception that improper activities “can
never be accepted”, risks for conducting improper activities through “justification” would
be reduced.
Now start the self-check.
Some of the examples are as follows:
• You can do anything as long as it does not violate laws and regulations
• If your boss accepts, violation of rules will be approved
• If told “It has been done for quite some time now,” I will accept it even though I feel
uncomfortable
• If the customer accepts, you can violate the agreement with the customer by keeping
it secret
• Anything would be acceptable if it is for achieving a goal
27/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.2.5 What would you “lose”?
Conducting improper activities concerning quality can be stopped if everyone has a high ethical
standard.
However, there are times when you are bewildered.
If such is the case, thinking about “what you lose” may “stop” the improper activities.
 By “doing,” what would you do if you compare
 <What you lose> now, and
 <What you will get> in the future?
Present Future
What you get
What you lose
If you act
 By “doing,” what would you do if you
compare
 <What you get> now, and
 <What you will lose> in the future?
Ask yourself and listen to “your internal voice.”
That way, you would have fewer regrets!
What you
get now
What you will
lose in the
future
What you
lose now
What you will get
in the future
28/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.3 Quality Compliance Activities
Finally, we will explain the Quality Compliance Activities.
Contents are as follows:
2.3.1 Compliance expands as time goes by
2.3.2 What happens if you disregard compliance?
2.3.3 To avoid violation of compliance,
• Management philosophy of the Fujikura Group
• Fujikura Quality Policy
We will review the above-mentioned items.
29/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.3.1 Compliance expands as time goes by
The word “compliance” comes from “respond (to something),
obey, and protect,” and is recognized as complying with laws
and regulations.
[Nothing special] about <complying with laws and
regulations>.
Meaning of <compliance> is expanding with time.
Internal rulesAgreement with customers
Compliance with laws and regulations
 Laws regarding business activities
 Laws for consumers
 Laws for employees
 Laws regarding the internet
etc.
People’s behavior (ethics of individual person) Triangle of improper activities
30/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
2.3.2 What happens if you disregard compliance?
Source: Created based on “Compliance for Employees” by Toshiba Solutions
What happens if you disregard compliance?
Possible consequences are:
 Lose credibility of the company
 Damage morale of the employees
 Lose human resources to outside
Then what should we mind?
 Daily efforts
• Identification of risks for improper activities
• Collect information on improper activities in society and/or the industry
• Audit and education / training
etc.
 When a problem occurs,
• Organize facts
• Investigate causes
• Respond properly
• Fulfill accountability in relation to media and customers
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2.3.3 To avoid violation of compliance
Two steps for avoiding “compliance violation” will be explained.
The first step
• Recognition and understanding of the management philosophy of
Fujikura Group [MVCV] by each employee.
• Its basis is “Fujikura Quality Policy.”
The second step
• Understanding the true purpose of “laws,” “agreements with
customers,” and “company regulations.”
Let’s check these items on
the next slide
32/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
The first step: management philosophy
Mission
• It defines the “raison d’être” of the company
• It applies universally
Vision (what we want to be)
• “Grand target of the future”
• It can be updated and changed
Core values (basic values)
• Type of behavior to obey and values to share
• Judgment criteria for what you should focus on in behavior or
process
33/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Management philosophy of the Fujikura Group (MVCV)
Mission
・ Fujikura Group contributes to value creation of customers and society
through technology that “connects”
・ We will continue to take on everlasting challenges in the field of
technology that “connects,” and provide valuable products and
solutions, thereby meeting customers’ trust and contributing to society
Vision
▪ To become the most trusted partner to customers in the field of
technology that “connects.”
▪ To become a leader in the field of technology that “connects” by
developing highly advanced and useful products and solutions
continuously.
▪ To form a group of globally competent talented people through the
awareness that “everyone plays a leading role.”
34/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Management philosophy of the Fujikura Group (MVCV)
Core values (basic values)
Customer Satisfaction
“Is the customer satisfied?”
Recognize everyone you are working with is a customer, and ask
yourself “Is the customer satisfied?” to provide high quality products
and services to the customer.
Change
“Are you committed to progress?”
Trying to progress and improve is sound and is a driving force for
change.
Individuals and organizations are to utilize every resources available for
the change and keep up with the changing customer needs.
Collaboration
“Are you cooperating with each other to utilize everyone’s ability?”
Fully utilize the abilities of every individual employee to meet customer
needs appropriately, thereby making Fujikura Group an excellent
company group.
For that purpose, create a totally optimized company culture where
everyone respects, encourages, and cooperates with each other.
35/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Management philosophy of the Fujikura Group (MVCV)
Code of conduct
▪ Above all, think and behave from the
customers’ point of view
▪ Always think of what to retain and what to
dismiss
▪ Show your goal clearly
▪ Always research to get one step ahead
▪ Act quickly based on the facts
36/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Fujikura Quality Policy (revised on April 1, 2019)
1. Pursue management based on “quality” to provide best
quality products and services to our customers.
2. Every employee is to be aware of the importance of
quality compliance strongly once again, comply with
laws and regulations, public standards, and agreements
with customers, and never repeat improper activities
concerning quality.
3. Create a transparent company culture by promoting
communication in the workplace and report to a boss
promptly when you recognize quality compliance
problem.
FETL company Quality Policy check revise or continue with simplify
37/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
The second step: Relevant laws
Major laws that are related to business
are as shown below.
All the laws are stipulated according to certain social requirements.
Please understand the background of each law.
1. Fundamental norms that define basic principles / rules of organization and governance of a
country
Constitution
2. Laws regarding business activities
Civil Code, Companies Act, Act on Prohibition of Private Monopolization and Maintenance
of Fair Trade, Copyright Act, Patent Act
Unfair Competition Prevention Act, Act on the Protection of Personal Information, etc.
3. Laws for consumers
Basic Act on Consumer Policies, Consumer Contract Act, Product Liability Act
Consumer Product Safety Act, etc.
4. Laws for employees
Labor Standards Act, Whistleblower Protection Act, etc.
5. Laws regarding the internet
Act on Prohibition of Unauthorized Computer Access, etc.
Source: Created based on Business Compliance written by Nobuo Gohara
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Summary
(i) Customer oriented business operation does not necessarily mean to
“obey what you are told by a customer,” but is to
・ Understand content of standards and agreements,
・ Agree with the customer, and
Sometimes, guide the customer;
(ii) Exertion of leadership by all levels of leaders to recognize
・What must be done and
・What must not be done;
(iii) Be aware that every individual employee is contributing to the
organization;
(iv) Identify risks of improper activities keeping the triangle of improper
activities in mind; and
(v) Perform better communication with stakeholders.
ABC method
A…Do obviousthings
B… properly
C…Without ignoring
Justification
Excuse
Opportunity
Work environment
Motivation
Pressure
Improper activities
39/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
3.1 Comprehension check
How was the course?
Do you have a better understanding of what quality compliance is?
Let’s execute daily operation with a firm determination that you will never
repeat improper activities concerning quality through this course.
This material has been reviewed while quoting the materials below.
Quoted materials (in random order)
(1) “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc.
(2) System Fraud Triangle
(3) “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
(4) Wisdom Bag for Labor Management
(5) “Fraud Triangle” by D-Quest Group
(6) IT glossary that makes you “understand” what was seemingly “understandable” but actually was “hard to understand”
(7) Business Compliance written and edited by Nobuo Gohara
(8) Kawaii furii sozai shuu (cute free materials) by Irasutoya
Lastly, you will have a comprehension check. Repeat it until you can answer all the questions correctly.
40/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 1 If the following statement is correct, select “〇”; otherwise select “X.”
At the Japanese Society for Quality Control, “improper activities concerning
quality” are discussed.
When you are not making a decision based on
・ The effect of complying with rules and
・ Efforts to complying with rules,
you may end up accepting improper activities saying “It is OK.”
To comply with rules,
・ Understanding the background of the rules, and
・ Recognition and evaluation of the risks when rules are violated
are important.
<<〇>> [〇]
<<〇>> [X]
41/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 2 Choose the best combination of words from below for the blanks of [1] - [3] in
the following sentence.
Factor of risks for improper activities [1] is obvious to anyone, and classified as
“objective circumstances.”
Factors [2] and [3], on the other hand, are something internal to PIC, which others
cannot be aware of, and are classified as “subjective circumstances.”
<<〇>> A… 1: Motivation 2: Opportunity 3: Justification
<<〇>> B… 1: Justification 2: Opportunity 3: Motivation
<<〇>> C… 1: Opportunity 2: Motivation 3: Justification
42/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 3 If the following statement is correct, select “〇”; otherwise select “X.”
Three factors of risks for improper activities are:
・ “Opportunity”…workplace environment
・ “Motivation”…circumstances of PIC or trigger
・ “Justification”…excuse.
Improper activities are likely to take place when all three factors come together.
<<〇>> [〇]
<<〇>> [X]
43/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 4 The table below shows the three factors of improper activities of “omission of
sampling inspection prior to shipment.”
Choose the best combination of words from below for the blanks of [1] - [3] in
the table.
<<〇>> A… 1: Justification 2: Motivation 3: Opportunity
<<〇>> B… 1: Opportunity 2: Motivation 3: Justification
<<〇>> C… 1: Motivation 2: Opportunity 3: Justification
[1]
Circumstances of the PIC
and trigger
Three factors of improper activities
[2] Work environment
[3] Excuse
I need to go home early because one of my family
members is sick
Omission of sampling inspection before shipment
Inspection is carried out by one person
This person can bring an approval stamp outside
Past omission of the inspection did not cause
problems with the characteristics
44/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 5 Which one of the statements below is most inappropriate as an explanation of
“motivation,” one of the three factors of risks for improper activities?
<<〇>> A… Various things can be a “motivation” for PIC. Everyone has a trigger for
improper activities.
<<〇>> B…“Motivation,” one of the three factors of risks for improper activities, is
internal to the PIC, and others cannot avoid the occurrence of such improper
activities.
<<〇>> C…“Motivation,” one of the three factors of risks for improper activities, may be
influenced by time; e.g., certain circumstances may have been “pressure” to
someone while it is “no longer” pressure to the same person now after
experience.
45/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 6 Which one of the statements below is most inappropriate as an explanation of
words and deeds that a boss should consider for “motivation,” one of the three
factors of risks for improper activities?
<<〇>> A… I make the “Internal Reporting System” of the company known to everybody
in the department.
<<〇>> B… I always mention that achieving the goal of the department is the top
priority, and is a responsibility of every individual member of the
department.
<<〇>> C… I pay attention to subordinates so that they do not take a wrong action by
conjecturing the hidden intention of my order.
46/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 7 Which one of the statements below is most inappropriate as an explanation of
“opportunity,” one of the three factors of risks for improper activities?
<<〇>> A… If you do the same job for a long period of time, “risk for improper
activities” by “opportunity” rises, making the improper activities more likely
to happen.
<<〇>> B… Products do not meet the shipping standards, but should be shipped if there
is no problem with the performance because you can reduce waste that
way, and thereby contribute to society.
<<〇>> C… If there are operations with which rules for approval or decision making are
not established, “risk for improper activities” by “opportunity” rises, and
“improper activities” are more likely to happen.
47/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 8 Choose the most inappropriate statement as an explanation of “opportunity,”
one of the three factors of risks for improper activities.
<<〇>> A… When reporting to and seeking consultation from your boss, it is better to
begin with questions and then point out the problem before providing your
proposal so that your boss will understand your problem better.
<<〇>> B… It is better to use the “Internal Reporting System” without consulting your
colleagues or boss at all when you find the “opportunity,” one of the three
factors of improper activities at your workplace.
<<〇>> C… It is also effective to set up a vacation system of one week or so, where
some other person takes over the job during vacation.
48/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 9 Choose the most inappropriate statement as an explanation of “justification,”
one of the three factors of risks for improper activities.
<<〇>> A… If you are sure to be able to judge “good from evil,” you are aware that
“improper activities should not be done,” which would stop the improper
activities. However, if there are some reasons to “justify” improper
activities, nothing can stop such activities, resulting in conducting one.
<<〇>> B… One example of “justification” (excuse) is “falsifying shipping data of
defective products” because “you need to prioritize delivery date to obtain
the next order.”
<<〇>> C… “To improve performance of the department or company” is one example of
“justification” (excuse), but it is inevitable.
49/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1)
Comprehension check
Question 10 Below is the “Fujikura Quality Policy.”
Choose the best combination of words from below for the blanks of [1] - [3] in
the table.
1. Pursue management based on [1] to provide best quality products and services to our
customers.
2. Every employee is to be aware of the importance of [2] strongly once again; comply with
laws and regulations, public standards, and agreements with customers; and never repeat
improper activities concerning quality.
3. Create a transparent company culture by promoting communication in the workplace and
report to [3] promptly when you recognize quality compliance problem.
<<〇>> A…1: Quality 2: Quality Compliance 3: Boss
<<〇>> B…1: Quality Compliance 2: Boss 3: Quality
<<〇>> C…1: Boss 2: Quality 3: Quality Compliance

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Quality complaiance (ver1.1) for fetl eng

  • 1. 1/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Quality Compliance
  • 2. 2/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Background of the course Major improper activities concerning quality by Japanese companies (2000-2017) 2000 Covering up of recalls by an automotive manufacturer 2002 Falsification of production venue of beef by a food manufacturer 2005 Forgery of a structural statement 2007 Falsification of quality labeling of minced beef 2015 Falsification of piling data 2017 Inspection by unqualified personnel at an automotive manufacturer Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc. Such improper activities would ruin brand images, and impact management / operations. This is because Japanese society has become rapidly compliance oriented, and strict compliance to laws and regulations, rules, agreements, etc. has become necessary. We have conducted inspections and reviews on general quality management at Fujikura Group. As a result, many improper cases have been reported, and we ended up announcing these cases externally in August 2018. Many improper activities concerning quality by leading Japanese companies have been reported across many industries / trades since the year 2000.
  • 3. 3/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Definition of improper activities concerning quality In this course, “improper activities concerning quality” are defined as: “Intentional” violation of laws and regulations, public standards, and/or agreements with customers regarding quality and/or labeling of products and/or services. However, it is worth noting that violations caused by negligence should also be avoided as a matter of course. Some examples are:  Falsification of inspection records Filled an inspection forms and reports with false data.  Did not carry out inspections Inspections agreed with a customer were not carried out.  Difference in inspection method Inspection was carried out by a different method from what had been agreed with a customer.  4M change procedure not carried out Application to a customer when manufacturing conditions are changed as agreed with the customer was not carried out.  False report regarding process capabilities, manufacturing environment, etc. Even though there is an agreement with a customer on process capabilities, manufacturing environment, etc., a false report on them was made to the customer.
  • 4. 4/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Purpose of the course “Compliance” has been understood as “compliance to laws and regulations,” but it also entails compliance to agreements with customers, rules, etc. “Regarding the laws and regulations,” educational courses on the Anti-corruption Law, the Antitrust Law, and the Subcontract Law are carried out at Fujikura Group. In this course, however, we focus on the people’s behavioral awareness that may lead to improper activities concerning quality. Let’s attain common understanding as to the “people’s behavior” from top executives to temporary employees. Let’s meet trust from our customers and contribute to society by understanding what quality compliance is through this course.
  • 5. 5/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Contents As a beginning, 2.1 We will explain improper activities concerning quality in Japan before presenting how to avoid progression of such activities with examples. Then, 2.2 We will present the Fraud Triangle proposed by Professor Donald Cressey, who specialized in organized crime, as the background of such improper activities. And finally, 2.3 We will check Fujikura Quality Policy, which plays an important role in the quality compliance activities. Additionally, 3.1 A comprehension check is waiting for you. So learn carefully.
  • 6. 6/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.1 Improper activities concerning quality in Japan As a beginning, we will explain improper activities concerning quality in Japan. Contents are: 1.1 Major improper activities concerning quality by Japanese companies 1.2 Improper activities concerning quality 1.3 Mechanism of falsification / covering up 1.4 Why you think “It is OK” when actually it isn’t? ・Case 1: Falsification of shipping inspection data ・Case 2: Covering up of nonconformity 1.5 To avoid the progression of such improper activities concerning quality
  • 7. 7/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.1.1 Major improper activities concerning quality by Japanese companies Major improper activities concerning quality by Japanese companies (2000-2017) [Repeated] 2000 Covering up of recalls by an automotive manufacturer 2002 Falsification of production venue of beef by a food manufacturer 2005 Forgery of a structural statement 2007 Falsification of quality labeling of minced beef 2015 Falsification of piling data 2017 Inspection by unqualified personnel at an automotive manufacturer Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc. Complex factors exist behind these improper activities concerning quality
  • 8. 8/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.1.2 Improper activities concerning quality Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc. At the Japanese Society for Quality Control, “improper activities concerning quality” are discussed. Improperactivitiesconcerningquality (1) Lack of know-how (inferior technology) (2) Improper activities concerning know-how (improper management) Improve the technology (i) Intentional (crime) (ii) Falsification / covering up Not covered here Next Divided into two categories Further divided into two categories
  • 9. 9/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.1.3 Mechanism of falsification / covering up How does the [falsification / covering up] takes place? Let’s consider operations differing from the standard documents (rules). Lack of knowledge Lack of skills Careless mistake No Creation of and education on standard documents You think “It is OK” when actually it isn’t Evaluation / training of skills Error proof e.g. Automation No No Yes Yes Yes Were you aware of the standard documents? Can you comply with the standard documents? Were you trying to comply with the standard documents?
  • 10. 10/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.1.4 Why you think “It is OK” when actually it isn’t? To comply with rules, consider • the reasons why they are established, and • recognition and evaluation of risks when they are violated. Under what circumstances do you tend to think “It is OK” even though it isn’t? You think “It is OK,” since decision making based on (i) Effect of complying with rules and (ii) Efforts to complying with rules are not properly carried out. Effortsto complyingwithrules Effectof complyingwithrules Compliant Notcompliant Effectof complyingwithrules Effortsto complyingwithrules Compliant Notcompliant Effortstocomplying withrules Effectofcomplying withrules Compliant Notcompliant Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc.
  • 11. 11/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Case 1: Falsification of shipping inspection data Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc. Let’s take a look at the cases where improper activities concerning quality took place. Circumstances Understanding of the person in charge Improper activities Efforts to complying with rules Omission of sampling inspection before shipmentScene  Inspection methods are standardized  The person in charge of the inspection was delegated the authority of implementation  100% automatic inspection was carried out during the manufacturing process  It takes time to carry out sampling inspection  The PIC judged without proper reasons that sampling inspection before shipment was unnecessary  Use of old data for the falsification
  • 12. 12/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Case 2: Covering up of nonconformity Let’s take a look at the cases where improper activities concerning quality took place. Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc. Circumstances Understanding of the person in charge Improper activities Efforts to complying with rules Shipping inspectionScene  Inspection methods are standardized  The person in charge of the inspection was delegated the authority of implementation  Failing acceptance inspection by the customer may result in insufficient supply  Changes to standards or operation methods take time before obtaining the customer’s approval  Judged that the standards are not rational, without proper reasons  No accident happened where the inspection results affected safety  Passed nonconforming products, etc. by rewriting the inspection report
  • 13. 13/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.1.5 To avoid the progression of such improper activities concerning quality Source: Created based on “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc. In the next chapter, the background of why improper activities concerning quality take place will be examined in detail. How can we avoid the progression of improper activities concerning quality? Manage the complexity of operation * Make routine operations simple, effective, and efficient as necessary How to proceed with establishing rules and delegation of authority * Clarify the person who judges and decides after assuming possible issues when establishing rules and delegation of authority of routine operations Development and management of personnel * Educate / train personnel who are in charge of information reporting so that they understand the importance of information and all have fair recognition of adverse effects caused by creating and reporting information
  • 14. 14/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.2 Background of the improper activities Next, we will explain Background of the improper activities. Contents are as follows: 2.2.1 What is “Triangle of improper activities”? 2.2.2 What is “motivation”? • Types of motivation • Self-check of “motivation” • How to deal with “motivation” 2.2.3 What is “opportunity”? • Malfunctioning and emasculation of rules • Self-check of opportunities • Dealing with the opportunities • “Internal Reporting System” of Fujikura Group 2.2.4 What is “justification”? • Self-check of “justification” 2.2.5 What would you “lose”?
  • 15. 15/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Source: Created based on “System Fraud Triangle” 2.2.1 What is “Triangle of improper activities”? American specialist in organized crime D. R. Cressey (1919~1987) Motivation Circumstances of the PIC and trigger Justification Excuse Opportunity Work environment Improper activities Professor Donald Cressey, who was an American specialist in organized crime, proposed three factors behind improper activities in 1953, which was published as the Fraud Triangle in 1991 by Professor Steve Albrecht. Objective circumstances Obvious to anyone Subjective circumstances Internal to the person in charge Improper activities take place when all three factors come together
  • 16. 16/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) e.g., Omission of sampling inspection before shipment Improper activities take place when all three factors come together If any one of the factors is missing, the improper activities are hard to take place Above mentioned “Falsification of inspection data prior to shipment (omission of sampling inspection before shipment)” will be examined based on the three factors. The three factors of “motivation,” “opportunity,” and “justification” will be explained next. Motivation Circumstances of the PIC and trigger Three factors of improper activities Opportunity Work environment Justification Excuse I need to go home early because one of my family members is sick Omission of sampling inspection before shipment Inspection is carried out by one person This person can bring an approval stamp outside Past omission of the inspection did not cause problems with the characteristics
  • 17. 17/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.2.2 What is “motivation”? Let’s examine “motivation” that is important in people’s behavior. Here, “motivation” is a set of subjective circumstances that motivate improper activities. In other words, it is a feeling that improper activities are critical in solving “one’s own desires / worries.” Even under similar circumstances (opportunity), • Depends on the “person,” or • If he/she is inexperienced or experienced for a prolonged period of “time,” the circumstances may or may not constitute a motivation. Source: Created based on “Fraud Triangle” by D-Quest Group and “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
  • 18. 18/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Types of motivation Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association Motivation Circumstances of the PIC and trigger for doing improper activities Strong personal desire • Improving treatment • Fear of dismissal or unemployment Job related problems • Cannot achieve the target Problems that cannot be solved by laws and regulations, or company rules • Dissatisfaction against the company • Grudge against the boss Pressure • Strong pressure for accomplishing the assignment Private problems • Sickness of a family member Let’s examine what can be a motivation. You can see that “anything around you” can result in a “motivation” of improper activities for any kind of person.
  • 19. 19/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Check the “motivation” yourself! You can see that anybody has “motivation” for improper activities. Source: Created based on Wisdom Bag for Labor Management and “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association Now start the self-check. Some of the examples are as follows: • I made a mistake in the job and cannot report it to the boss • A difficult goal that I cannot achieve is imposed • I have a job whose due date is hard to keep • I can make profit by committing an unjust activity • I have a grudge feeling for treatment by the company such as salary or position • I am anxious about dismissal or unemployment If even one of the above is applicable, it is important to recognize that you have a risk for committing improper activities
  • 20. 20/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) How to deal with “motivation” Every job entails a certain level of “pressure.” However, if you continue to be under extreme pressure, you may be unable to make correct decisions. The “pressure” may lead to “improper activities.” Then how can we deal with such a situation? • Taking good care of your own mental health, • Having someone from whom you can seek advice, etc. are some of the measures. If you have subordinates, • Be careful whether your subordinates make a conjecture about your hidden intention to take an improper action e.g., Let’s make every effort to achieve the goal →You can do anything to achieve the goal • Clarify the system and standards of evaluation / promotion and make them known to the subordinates Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
  • 21. 21/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.2.3 What is “opportunity”? “Opportunity” here refers to an objective environment that facilitates the conduct of improper activities. In other words, it is a work environment in which you can do improper activities whenever you want to. Work environment can be divided into two types.  “Position” • Doing a specific job by one person • Only one person knows the job • Only one person can do the job  “Authority” • Authorized to use an approval stamp all by oneself Source: Created based on “Fraud Triangle” by D-Quest Group and “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
  • 22. 22/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) “Malfunctioning” and “emasculation” of rules Normally, it is “natural” to deal with a work process by stipulating “rules and systems” so that improper activities with “position / authority” may not take place. But in actual cases,  Malfunctioning … neglecting rules • Criteria are not met, but since there is no problem with the performance, I will put the stamp of “pass” here.  Emasculation … loophole of the rules • You can put the stamp of “Inspected” even though it has not been inspected. Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association You are expected to • Discover, • Share within the division, and • Eliminate the “opportunities” of “risks for improper activities” that can occasionally be seen in the workplace.
  • 23. 23/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Check the “opportunities” yourself! Eliminating risks of the “improper activities” at the “opportunities” will tip the balance of the “triangle of the improper activities,” thereby preventing the “improper activities” from taking place. Now, check your own workplace. Some of the examples are as follows:  Examples of “position / authority” • Doing the same job for a long period of time • Some of the jobs are not transparent to people other than the PIC  Examples of “malfunctioning / emasculation” • Rules for approval and/or decision making are not determined for some of the jobs • Some of the jobs are undertaken by a person who does not deserve the authority (approval stamp) • There are rules that are not kept or are not functioning Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association If even one of the above is applicable, it is important to recognize that you have “risk(s) of improper activities” by “opportunities.”
  • 24. 24/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Dealing with “opportunities” (i) Ask your colleagues about their stories and for their opinions. →Problems would surface by sharing information. (ii) Report to / consult your boss → If you address your boss as follows, “Points would become clear and the argument would become concrete” so that your boss will understand your point smoothly. • Use questions…e.g., “Is the customers’ quality information well managed?” • Point out…e.g., “Anyone can bring the customers’ quality information outside.” • Propose…e.g., “You need to review how the customers’ quality information is stored.” What should you do if you discover “opportunities” that may lead to improper activities in the workplace?
  • 25. 25/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.2.4 What is “justification”? “Justification” here refers to a subjective environment that can be used to accept the conduct of improper activities. In other words, it means overcoming “qualms” that you feel when conducting improper activities by inventing reasons that are favorable to you. This is a matter of personal ethics. Some examples are as follows: • There are no rules in the company • Colleagues are also doing it • I am not evaluated fairly • Improper activities (omission of inspections, etc.) does not affect quality, etc. • To improve performance of the department and/or company • Prioritizing delivery date will lead to the next order Source: Created based on “Fraud Triangle” by D-Quest Group and “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association
  • 26. 26/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Check “justification” yourself! Source: Created based on “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association Judgment criteria of “good or evil” depend on one’s personal ethics. Ethics may be different for each person. Such variation may lead to improper activities in daily operations. Let’s discuss the situation at your workplace. If everyone in the workplace all has common perception that improper activities “can never be accepted”, risks for conducting improper activities through “justification” would be reduced. Now start the self-check. Some of the examples are as follows: • You can do anything as long as it does not violate laws and regulations • If your boss accepts, violation of rules will be approved • If told “It has been done for quite some time now,” I will accept it even though I feel uncomfortable • If the customer accepts, you can violate the agreement with the customer by keeping it secret • Anything would be acceptable if it is for achieving a goal
  • 27. 27/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.2.5 What would you “lose”? Conducting improper activities concerning quality can be stopped if everyone has a high ethical standard. However, there are times when you are bewildered. If such is the case, thinking about “what you lose” may “stop” the improper activities.  By “doing,” what would you do if you compare  <What you lose> now, and  <What you will get> in the future? Present Future What you get What you lose If you act  By “doing,” what would you do if you compare  <What you get> now, and  <What you will lose> in the future? Ask yourself and listen to “your internal voice.” That way, you would have fewer regrets! What you get now What you will lose in the future What you lose now What you will get in the future
  • 28. 28/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.3 Quality Compliance Activities Finally, we will explain the Quality Compliance Activities. Contents are as follows: 2.3.1 Compliance expands as time goes by 2.3.2 What happens if you disregard compliance? 2.3.3 To avoid violation of compliance, • Management philosophy of the Fujikura Group • Fujikura Quality Policy We will review the above-mentioned items.
  • 29. 29/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.3.1 Compliance expands as time goes by The word “compliance” comes from “respond (to something), obey, and protect,” and is recognized as complying with laws and regulations. [Nothing special] about <complying with laws and regulations>. Meaning of <compliance> is expanding with time. Internal rulesAgreement with customers Compliance with laws and regulations  Laws regarding business activities  Laws for consumers  Laws for employees  Laws regarding the internet etc. People’s behavior (ethics of individual person) Triangle of improper activities
  • 30. 30/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.3.2 What happens if you disregard compliance? Source: Created based on “Compliance for Employees” by Toshiba Solutions What happens if you disregard compliance? Possible consequences are:  Lose credibility of the company  Damage morale of the employees  Lose human resources to outside Then what should we mind?  Daily efforts • Identification of risks for improper activities • Collect information on improper activities in society and/or the industry • Audit and education / training etc.  When a problem occurs, • Organize facts • Investigate causes • Respond properly • Fulfill accountability in relation to media and customers
  • 31. 31/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 2.3.3 To avoid violation of compliance Two steps for avoiding “compliance violation” will be explained. The first step • Recognition and understanding of the management philosophy of Fujikura Group [MVCV] by each employee. • Its basis is “Fujikura Quality Policy.” The second step • Understanding the true purpose of “laws,” “agreements with customers,” and “company regulations.” Let’s check these items on the next slide
  • 32. 32/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) The first step: management philosophy Mission • It defines the “raison d’être” of the company • It applies universally Vision (what we want to be) • “Grand target of the future” • It can be updated and changed Core values (basic values) • Type of behavior to obey and values to share • Judgment criteria for what you should focus on in behavior or process
  • 33. 33/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Management philosophy of the Fujikura Group (MVCV) Mission ・ Fujikura Group contributes to value creation of customers and society through technology that “connects” ・ We will continue to take on everlasting challenges in the field of technology that “connects,” and provide valuable products and solutions, thereby meeting customers’ trust and contributing to society Vision ▪ To become the most trusted partner to customers in the field of technology that “connects.” ▪ To become a leader in the field of technology that “connects” by developing highly advanced and useful products and solutions continuously. ▪ To form a group of globally competent talented people through the awareness that “everyone plays a leading role.”
  • 34. 34/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Management philosophy of the Fujikura Group (MVCV) Core values (basic values) Customer Satisfaction “Is the customer satisfied?” Recognize everyone you are working with is a customer, and ask yourself “Is the customer satisfied?” to provide high quality products and services to the customer. Change “Are you committed to progress?” Trying to progress and improve is sound and is a driving force for change. Individuals and organizations are to utilize every resources available for the change and keep up with the changing customer needs. Collaboration “Are you cooperating with each other to utilize everyone’s ability?” Fully utilize the abilities of every individual employee to meet customer needs appropriately, thereby making Fujikura Group an excellent company group. For that purpose, create a totally optimized company culture where everyone respects, encourages, and cooperates with each other.
  • 35. 35/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Management philosophy of the Fujikura Group (MVCV) Code of conduct ▪ Above all, think and behave from the customers’ point of view ▪ Always think of what to retain and what to dismiss ▪ Show your goal clearly ▪ Always research to get one step ahead ▪ Act quickly based on the facts
  • 36. 36/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Fujikura Quality Policy (revised on April 1, 2019) 1. Pursue management based on “quality” to provide best quality products and services to our customers. 2. Every employee is to be aware of the importance of quality compliance strongly once again, comply with laws and regulations, public standards, and agreements with customers, and never repeat improper activities concerning quality. 3. Create a transparent company culture by promoting communication in the workplace and report to a boss promptly when you recognize quality compliance problem. FETL company Quality Policy check revise or continue with simplify
  • 37. 37/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) The second step: Relevant laws Major laws that are related to business are as shown below. All the laws are stipulated according to certain social requirements. Please understand the background of each law. 1. Fundamental norms that define basic principles / rules of organization and governance of a country Constitution 2. Laws regarding business activities Civil Code, Companies Act, Act on Prohibition of Private Monopolization and Maintenance of Fair Trade, Copyright Act, Patent Act Unfair Competition Prevention Act, Act on the Protection of Personal Information, etc. 3. Laws for consumers Basic Act on Consumer Policies, Consumer Contract Act, Product Liability Act Consumer Product Safety Act, etc. 4. Laws for employees Labor Standards Act, Whistleblower Protection Act, etc. 5. Laws regarding the internet Act on Prohibition of Unauthorized Computer Access, etc. Source: Created based on Business Compliance written by Nobuo Gohara
  • 38. 38/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Summary (i) Customer oriented business operation does not necessarily mean to “obey what you are told by a customer,” but is to ・ Understand content of standards and agreements, ・ Agree with the customer, and Sometimes, guide the customer; (ii) Exertion of leadership by all levels of leaders to recognize ・What must be done and ・What must not be done; (iii) Be aware that every individual employee is contributing to the organization; (iv) Identify risks of improper activities keeping the triangle of improper activities in mind; and (v) Perform better communication with stakeholders. ABC method A…Do obviousthings B… properly C…Without ignoring Justification Excuse Opportunity Work environment Motivation Pressure Improper activities
  • 39. 39/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) 3.1 Comprehension check How was the course? Do you have a better understanding of what quality compliance is? Let’s execute daily operation with a firm determination that you will never repeat improper activities concerning quality through this course. This material has been reviewed while quoting the materials below. Quoted materials (in random order) (1) “To secure the quality oriented country of Japan” by the Japanese Society for Quality Control, etc. (2) System Fraud Triangle (3) “Courses for Raising Sensitivity for Company Ethics and Compliance” by the Japan Management Association (4) Wisdom Bag for Labor Management (5) “Fraud Triangle” by D-Quest Group (6) IT glossary that makes you “understand” what was seemingly “understandable” but actually was “hard to understand” (7) Business Compliance written and edited by Nobuo Gohara (8) Kawaii furii sozai shuu (cute free materials) by Irasutoya Lastly, you will have a comprehension check. Repeat it until you can answer all the questions correctly.
  • 40. 40/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 1 If the following statement is correct, select “〇”; otherwise select “X.” At the Japanese Society for Quality Control, “improper activities concerning quality” are discussed. When you are not making a decision based on ・ The effect of complying with rules and ・ Efforts to complying with rules, you may end up accepting improper activities saying “It is OK.” To comply with rules, ・ Understanding the background of the rules, and ・ Recognition and evaluation of the risks when rules are violated are important. <<〇>> [〇] <<〇>> [X]
  • 41. 41/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 2 Choose the best combination of words from below for the blanks of [1] - [3] in the following sentence. Factor of risks for improper activities [1] is obvious to anyone, and classified as “objective circumstances.” Factors [2] and [3], on the other hand, are something internal to PIC, which others cannot be aware of, and are classified as “subjective circumstances.” <<〇>> A… 1: Motivation 2: Opportunity 3: Justification <<〇>> B… 1: Justification 2: Opportunity 3: Motivation <<〇>> C… 1: Opportunity 2: Motivation 3: Justification
  • 42. 42/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 3 If the following statement is correct, select “〇”; otherwise select “X.” Three factors of risks for improper activities are: ・ “Opportunity”…workplace environment ・ “Motivation”…circumstances of PIC or trigger ・ “Justification”…excuse. Improper activities are likely to take place when all three factors come together. <<〇>> [〇] <<〇>> [X]
  • 43. 43/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 4 The table below shows the three factors of improper activities of “omission of sampling inspection prior to shipment.” Choose the best combination of words from below for the blanks of [1] - [3] in the table. <<〇>> A… 1: Justification 2: Motivation 3: Opportunity <<〇>> B… 1: Opportunity 2: Motivation 3: Justification <<〇>> C… 1: Motivation 2: Opportunity 3: Justification [1] Circumstances of the PIC and trigger Three factors of improper activities [2] Work environment [3] Excuse I need to go home early because one of my family members is sick Omission of sampling inspection before shipment Inspection is carried out by one person This person can bring an approval stamp outside Past omission of the inspection did not cause problems with the characteristics
  • 44. 44/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 5 Which one of the statements below is most inappropriate as an explanation of “motivation,” one of the three factors of risks for improper activities? <<〇>> A… Various things can be a “motivation” for PIC. Everyone has a trigger for improper activities. <<〇>> B…“Motivation,” one of the three factors of risks for improper activities, is internal to the PIC, and others cannot avoid the occurrence of such improper activities. <<〇>> C…“Motivation,” one of the three factors of risks for improper activities, may be influenced by time; e.g., certain circumstances may have been “pressure” to someone while it is “no longer” pressure to the same person now after experience.
  • 45. 45/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 6 Which one of the statements below is most inappropriate as an explanation of words and deeds that a boss should consider for “motivation,” one of the three factors of risks for improper activities? <<〇>> A… I make the “Internal Reporting System” of the company known to everybody in the department. <<〇>> B… I always mention that achieving the goal of the department is the top priority, and is a responsibility of every individual member of the department. <<〇>> C… I pay attention to subordinates so that they do not take a wrong action by conjecturing the hidden intention of my order.
  • 46. 46/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 7 Which one of the statements below is most inappropriate as an explanation of “opportunity,” one of the three factors of risks for improper activities? <<〇>> A… If you do the same job for a long period of time, “risk for improper activities” by “opportunity” rises, making the improper activities more likely to happen. <<〇>> B… Products do not meet the shipping standards, but should be shipped if there is no problem with the performance because you can reduce waste that way, and thereby contribute to society. <<〇>> C… If there are operations with which rules for approval or decision making are not established, “risk for improper activities” by “opportunity” rises, and “improper activities” are more likely to happen.
  • 47. 47/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 8 Choose the most inappropriate statement as an explanation of “opportunity,” one of the three factors of risks for improper activities. <<〇>> A… When reporting to and seeking consultation from your boss, it is better to begin with questions and then point out the problem before providing your proposal so that your boss will understand your problem better. <<〇>> B… It is better to use the “Internal Reporting System” without consulting your colleagues or boss at all when you find the “opportunity,” one of the three factors of improper activities at your workplace. <<〇>> C… It is also effective to set up a vacation system of one week or so, where some other person takes over the job during vacation.
  • 48. 48/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 9 Choose the most inappropriate statement as an explanation of “justification,” one of the three factors of risks for improper activities. <<〇>> A… If you are sure to be able to judge “good from evil,” you are aware that “improper activities should not be done,” which would stop the improper activities. However, if there are some reasons to “justify” improper activities, nothing can stop such activities, resulting in conducting one. <<〇>> B… One example of “justification” (excuse) is “falsifying shipping data of defective products” because “you need to prioritize delivery date to obtain the next order.” <<〇>> C… “To improve performance of the department or company” is one example of “justification” (excuse), but it is inevitable.
  • 49. 49/43Fujikura Ltd. Quality Control Center[Electronic version] Quality Compliance (Ver. 1.1) Comprehension check Question 10 Below is the “Fujikura Quality Policy.” Choose the best combination of words from below for the blanks of [1] - [3] in the table. 1. Pursue management based on [1] to provide best quality products and services to our customers. 2. Every employee is to be aware of the importance of [2] strongly once again; comply with laws and regulations, public standards, and agreements with customers; and never repeat improper activities concerning quality. 3. Create a transparent company culture by promoting communication in the workplace and report to [3] promptly when you recognize quality compliance problem. <<〇>> A…1: Quality 2: Quality Compliance 3: Boss <<〇>> B…1: Quality Compliance 2: Boss 3: Quality <<〇>> C…1: Boss 2: Quality 3: Quality Compliance