2.2 ｜ Compliance and Risk Management Anti-corruption regulations are designed to control the following. ● Providing, requesting or promising monetary and other benefits for inappropriate purposes or outside normal social propriety. ● Advanced application and approval procedure required when providing benefits that are within the scope of normal social propriety. ● Preparatory inspections made before starting to trade with agents such as distributors and other intermediaries and anti-corruption provisions included in contracts. ● P rocedure for handling reports in the event of violations or matters of concern To deal with such cases, Fujifilm Group companies in Japan and other countries receive an annual self-audit on compliance with anti-corruption regulations and a review of the status of their anti-corruption training program. Agents such as distributors and other intermediaries are also required to submit annual reports to confirm that they are free from any corrupt practices. In addition, agents are told to employ the services of an external research firm in carrying out compliance due diligence with the focus on preventing corruption. An annual status report on these anti-corruption activities is sent to the Board of Directors of Fujifilm Holdings. Status for FY2022 ● As a result of the self-audits conducted by all Group companies on a global scale, anti-corruption training has been given to all employees that require it. There have been no serious corruption incidents requiring disclosure. The findings are reported to the Board of Directors of Fujifilm Holdings. ● In Japan and the Americas, compliance due diligence focusing on anti-corruption is conducted by an external research firm. This is expected to take effect in more areas. 2. Preventing anti-competitive practices The Fujifilm Group is working hard to observe anti-trust laws and has developed manuals and guidebooks that provide basic knowledge of anti-trust laws, standards of conduct to be observed and important points to be noted. We maintain regular employee education systems, and have introduced annual self audits. For compliance with Japan’s subcontractor law (Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors), regular training sessions are organized for personnel responsible for order management at business divisions where subcontractor business volumes are large. At the same time, divisions are monitored for their state of compliance with the subcontractor law in response to inspections either by the Japan Fair Trade Commission or the Small and Medium Enterprise Agency. In-house seminars on Japan’s anti-trust law and subcontractor law were held for major affiliates to ensure that these laws are firmly established and complied with. In fiscal 2022, an assessment of employees in Japan was conducted to determine their knowledge of Japanese laws, including the Japanese anti-monopoly law and subcontractor payment law, and their awareness and compliance with these laws and regulations. As for the anti-trust laws, self audits were carried out at each Group company worldwide and no serious violations were found. Since 2008, we have not been subjected to any penalties for antitrust/anti-competitive practices, nor are there any serious cases pointed out by administrative authorities. Also, there have been no ongoing antitrust lawsuits. 3. Initiative on the Pharmaceutical and Medical Device Act (Act on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices) The Fujifilm Group Global Healthcare Code of Conduct was established in fiscal 2020 to ensure legal compliance in the area of healthcare. Status for FY2022 Training was given to executive officers and employees working in the healthcare business, along with an internal audit of pharmaceutical affairs. In addition, the guidelines established in 2020 to promote the application of compliance in day-to-day business operations were revised in April 2023 and this raised the level of awareness across the Group. The administrative authorities have not identified any serious cases. 38 FUJIFILM Holdings Corporation Sustainability Report 2023