Corporate Ethics/Compliance Promotion System

  The Anritsu Group's Corporate Ethics/Compliance Promotion Structure is presided over by the executive officer in charge of compliance, based on Basic Rules for Ethical and Legal Compliance. The Corporate Ethics Promotion Committee, under the CSR Promotion Committee, plans and promotes companywide compliance with internal committees such as those dealing with export control, fair trade promotion, information management and the environmental management. Each department's management regularly implements related measures with the support of the committee's secretariat, CSR Promotion Center, the Legal Department and other internal organs.

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Compliance Promotion Measures

Anritsu Group carries out the following compliance promotion measures.
(1) Anritsu Group Code of Conduct and Case Study Sheet
  Anritsu Group stipulated that its Code of Conduct is to outline compliance measures for executives and employees to put into business practice. We have distributed the code of conduct to all Anritsu Group Company employees in booklet form and uploaded it on Anritsu's website in Japan. The Code of Conduct enhances awareness of our compliance activities and values shared among Anritsu Group Companies worldwide. In December 2005, we started to circulate a few different cases each month in Case Study Sheets on our Intranet.
(2) Training and Awareness
  Anritsu has various training and awareness programs. The programs include training according to organizational hierarchy including new recruits and newly promoted managers to reinforce awareness of compliance and ethical matters in general. Specialized departments, including those for security trade control, information control and environmental management, also provide compliance training. Moreover, annual Compliance Reinforcement Week campaign lectures and training programs spotlight ethics-related issues. The latest series of such activities took place from January 30 to February 3, 2006.
(3) Monitoring
  Our Legal Department in Japan takes the initiative to conduct an annual questionnaire survey to gauge the extent to which Anritsu Corp. and Anritsu Group employees in Japan understand compliance and ethical matters, and develops compliance promotion activities accordingly. Temporary employees, as well as employees of suppliers and partners, also take a kind of survey. Such monitoring of employee behavior and ethics enhances compliance companywide.
(4) Helpline
  To prevent Anritsu Group from violating ethics and laws, we have a Helpline that accepts internal reports, notices and consultations. Employees can communicate such concerns internally through secure dedicated e-mail hotline and suggestion/complaint boxes, or by consulting with external legal representatives. The secretariat deals with such reports, reporters and consultants in utmost confidentiality based on internal rules and without retribution. In fiscal 2005, there were no reports about serious concerns.