Governance 2.2 Compliance and Risk Management 2.2.1 Basic Approach The Fujifilm Group defines “compliance” as “not only to pursue the law but to behave correctly within the framework of common sense and ethics.” Moreover, we think the compliance and the risk are two sides of the coin, as the lack of compliance awareness among employees would lead to grow the possible corporate risk. For this reason, we are promoting compliance and risk management. 2.2.2 History of the Measures Implemented for Compliance and Risk Management Establishment and reinforcement of foundation at each company ● Formulation of a Code of Conduct for employees ● 1995-2005 Establishment of responsible organization (committee) ● Opening of a helpline and whistle-blowing office ● Start raising employees’ Awareness, education, and monitoring through awareness surveys and briefings sessions Establishment and reinforcement of foundation for the entire Fujifilm Group ● 2006-2008 Establishment of FUJIFILM Holdings CSR Committee ● Expansion of initiative to Group companies outside of Japan ● Revision of Group’s Corporate Philosophy and Charter for Corporate Behavior , and formulation of Vision and code of Conduct and raising awareness Addressing new priority issues ● Introduction of anti-corruption regulations ● 2009-2013 Review of Group-wide risk issues related to natural disasters, such as large earthquake or possible eruption of Mt. Fuji ● Establishment of a system to ensure no relations with anti-social forces ● Introduction of information security regulations and guidelines etc. Further activity promotion toward Sustainable Value Plan 2016 targets 2014-2016 ● Review and clarification of major risks for the Fujifilm Group ● Strengthening measures to raise awareness on existing rules and regulations etc. Strengthening Corporate Governance as the Fujifilm Group ● Compliance education for all Employees and distribution of CEO message concerning the 2017-2019 inappropriate accounting issue ● Establishment of whistle-blowing system to report directly to FUJIFILM Holdings ● Revision of the Charter for Corporate Behavior and the Code of Conduct ● Establishment of FUJIFILM Holdings ESG Committee reorganized from CSR committee Strengthening compliance and risk management organizations and reinforcement of activities ● Consolidation and reorganization of compliance and risk management organizations at FUJIFILM Corporation and FUJIFILM Business Innovation Corp. under Fujifilm Holdings 2020-2022 Corporation ● Consolidation and integration of various policies and domestic whistleblowing systems of the two corporations ● Establishment of Fujifilm Group Global Healthcare Code of Conduct ● Update of message from the president regarding the Fujifilm Group Charter for Corporate Behavior and Code of Conduct. 31 FUJIFILM Holdings Corporation Sustainability Report 2023