2.2 ｜ Compliance and Risk Management Intended Audience Category Objective Officers in charge Risk management in general Handling Promotion and guidance on compliance/risk of compliance/risk harassment inquiries and current management activities in each organization, in management at each topics on information security, etc. accordance with the groupwide policy. organization Managerial Program content focused on key points personnel and in preventing misconduct, workplace Education and training focused on key points to be general employees discussions, preventing harassment, strengthened in each organization, to ensure deeper of organizations to etc. knowledge and greater awareness and improvement be strengthened 3. Awareness survey The Fujifilm Group conducts regular compliance awareness surveys to examine the degree of awareness of compliance and comprehension among employees and to review the effectiveness of the Code of Conduct. In fiscal 2022, we introduced the Employee Engagement Survey covering past compliance awareness surveys. The survey consolidates the various theme-specific employee surveys, such as on compliance and brand management, in order to assess the status of engagement in the entire Group. The survey covers approximately 76,000 employees worldwide. The survey findings are reported to the Board of Directors, the ESG Committee and the top management of various Group companies. In addition, they are incorporated in the training programs and measures at each company to maintain and improve compliance awareness and to prevent violations. ● E mployee Engagement Survey (global): Conducted every year Objective: Examine the level of dissemination of awareness and comprehension of compliance in general, examine the level of awareness of whistle-blowing and consultation system ● H arassment survey (Japan): Conducted in alternate years Objective: Examine the actual conditions of harassment 4. Whistle-blowing and consultation system The Fujifilm Group prepares two separate whistle-blowing systems. One is through the contact points in Japan and regional headquarters that accept a range of questions and reports including inter-personal issues and compliance in day-to-day business. The other is by directly contacting the ESG Division (the compliance division) of FUJIFILM Holdings concerning critical issues that could significantly impact our business, such as a misconduct and violation of laws. This type of report can be made in 24 different languages, including Japanese and English. Reports and inquiries are being handled swiftly and properly at each system for prompt resolution of problems. If a probable violation of the Code of Conduct is identified, the ESG Division (compliance division) investigates the issue. If a violation is confirmed, corrective actions are taken properly to prevent for further occurrence. A serious case is immediately notified to the executive officer responsible for the ESG Division and top management to discuss and determine the response. Anonymous reporting is essentially possible under each whistle-blowing system. As the regulations on whistle-blowing are established, investigations are conducted with confidentiality and protection for the whistle-blower, to prevent the retaliation as a result of their report. Particularly in Japan, in accordance with a new requirement by the amended Whistle- blower Protection Act of 2022, officers engaged in responding to whistle-blowing reports were appointed in each Group company. We disseminate this whistle-blowing and consultation system among all employees through posters and the intranet to ensure that they can make contact whenever necessary. For external stakeholders, we provide “Contact regarding Sustainability” form on our official website to listen to the feedbacks on our sustainability activities including those related to human rights from the public at large, either anonymous or named. All complaints and suggestions are examined and handled appropriately after investigating the facts. The number of whistle-blowing reports and contents are regularly reported to the board of directors with due consideration to the whistle-blower. 36 FUJIFILM Holdings Corporation Sustainability Report 2023