4.5 | Human Rights explain the Code in detail were published at the same time and were revised in April 2023. We have been conducting training every year since the start of the program to ensure a broader awareness and full dissemination of the Code. Training in the Global Healthcare Code of Conduct was held in October through November 2022 for all 14,017 executive officers and employees in the healthcare business in Japan. Additionally, a Healthcare Compliance Seminar has been held for employees to ensure that they understand the severity of the laws and regulations that are increasing every year and to make them aware of the need to execute their jobs to a high ethical standard. The seminar targets all employees in the healthcare business in Japan, including marketing, services, sales, R&D, manufacturing and other divisions; it has also been offered as an e-learning program for 12,503 employees. (3) Fujifilm Group AI Policy As AI is being implemented in the Fujifilm Group at a rapidly growing pace to resolve social issues, in December 2020 we formulated the Fujifilm Group AI Policy to define the basic principles to be observed, including respect for human rights and fair use of AI technology. With the startup of the All-Fujifilm DX promotion program in July 2021 and the increasing speed with which AI-based DX is being used in various business fields, our policy on respect for human rights, which is based on the AI Policy and includes the requirement to confirm compliance even for the trial in-house use of generative AI, is being disseminated throughout the Group. 2. Efforts for the priority issues on human rights (1) Inappropriate work environment and labor practices at suppliers The Fujifilm Group pledges in its Human Rights Statement to respect human rights in its business activities and its supply chain. In the past, we assessed risks in the area of sustainable procurement with a self-check list on labor practices, human rights, the environment and corporate ethics and found that risks were minimal in our tier-1 suppliers in Japan and Western nations. In this activity, we have designated China and other countries in Asia, where a number of our manufacturing sites are located, as priority regions. In fiscal 2022, we continued to conduct risk assessment based on self-checks. We sent feedback sheets to all suppliers who responded to our self-checks, requesting improvements or revisions for any issues related to human rights and labor that require examination of conditions or review of activities. Sample check items included: "a fine or deduction from wages imposed as a disciplinary measure” (23% of respondents said yes), "there is no management system related to human rights/labor and occupational health and safety” (14% of respondents said yes) and "newly hired employees are required to deposit money or personal identification with the company” (3% of respondents said yes). We are making constant efforts to assess conditions and make improvements at suppliers through interviews conducted via the group companies that are their business partners. We are conducting expert on-site diagnoses for risk assessments at suppliers and supporting them in making improvements where problems in labor practices are found, to encourage improvements and revisions from the standpoint of human rights protection. In the diagnosis conducted in fiscal 2022, the following requests for improvement were made, and improvements were confirmed subsequently: • Employee handbooks supplied by the company have not been updated with revisions to the labor law and regulation changes. Regulations for leave and holidays showed descriptions that differ from actual operation. • Filters in the water dispensers installed in employee dormitories are changed, but drinking water inspections are not conducted regularly. It was confirmed that improvements to important items had been made by the end of the relevant fiscal year for all suppliers that underwent expert on-site diagnosis. At the same time, it is necessary for Fujifilm Group employees working in procurement to understand the importance of promoting respect for human rights at suppliers. Several times a year, the ESG Division together with Procurement & Equipment Manufacturing Division of FUJIFILM Holdings conducts interviews with the procurement and purchasing departments of 14 Fujifilm Group companies that directly procure materials, specifically to discuss rising social demands and Group policies and initiatives for sustainable procurement. In addition, for Group companies that request it, we hold separate training programs related to supply chains and human rights, including the risk of forced labor and other human rights violations as well as the responsibilities of the company in the supply chain. In addition to these activities, in February 2023 outside experts were invited to take part in a seminar on business and human rights, with the focus on human rights issues in the supply chain. It was attended by around 40 people including the general managers of legal affairs, procurement and ESG divisions at FUJIFILM Holdings. In the face of the recent increased international interest in modern slavery and human trafficking in the supply chain, 130 FUJIFILM Holdings Corporation Sustainability Report 2023
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