KONICA MINOLTA

About Konica Minolta

Compliance

Basic Concept and Promotion System of Compliance

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Basic Concept

Promoting compliance as the basis of its business activities

Konica Minolta believes that maintaining and increasing the trust of stakeholders, including customers, local and international communities, business partners, shareholders, and investors, is the basis of its business activities, and the practice of compliance is its underlying foundation. Compliance at Konica Minolta naturally involves complying with laws and regulations, but is also based on corporate ethics and company rules that define what the Company believe to be right.
The Konica Minolta Group has established the Konica Minolta Group Charter of Corporate Behavior, which sets forth the behavior required of all Konica Minolta Group companies and its personnel. The Group implements measures under a global promotion system to ensure that each employee acts in accordance with this Charter.


Scope of Compliance at Konica Minolta

Group Compliance Promotion System

Building a system to promote consistent compliance Group-wide

At Konica Minolta, the Chief Compliance Officer, a person appointed by the Board of Directors, determines important matters for the promotion of the Group's compliance and is responsible for promoting and overseeing compliance activities such as anti-corruption measures and personal information protection. The Chief Compliance Officer reports directly to the President of Konica Minolta, Inc., who has ultimate responsibility for Group compliance. To fulfill that responsibility, the Chief Compliance Officer convenes the Group Compliance Committee, which is composed of officers responsible for compliance from Business Units and Corporate Divisions in charge of Group-wide functions.
To promote compliance in each department at Konica Minolta, Inc., the General Manager of each department serves as the officer responsible; at subsidiaries inside and outside Japan, the president of each subsidiary serves as the officer responsible at each company. The Chief Compliance Officer reports regularly to the Audit Committee regarding progress on activities and important issues for the Group.


Note: An executive officer or a corporate vice president plays the role of Chief Compliance Officer.
Group Compliance Promotion System

Global Group Support System

Strengthening the coordination of Group compliance

The Legal Division at Konica Minolta, Inc. drafts plans to address important matters and measures regarding the promotion of the compliance, serving as a Group compliance support office assisting the Chief Compliance Officer. The Legal Division also assists each department and subsidiary with its activities, directly and indirectly, and promotes group-wide compliance activities.
The Chief Compliance Officer also appoints regional compliance coordinators in Europe, North America, China, and Southeast Asia, tasking them with implementing activities to promote compliance, considering the circumstances of each region.
In fiscal 2023, the Group compliance support office and regional compliance coordinators worked together to help newly acquired companies inside and outside Japan as well as small Group companies to adopt compliance measures, seeking to instill compliance throughout the entire Konica Minolta Group.

Planning Compliance Promotion and Verifying Progress

All departments at Konica Minolta, Inc. and all of its Group companies are required to carry out compliance according to a group compliance promotion plan and report their progress.

Konica Minolta identifies material issues by looking at trends in social expectations and the results of compliance risk assessments, and prepares a medium-term promotion plan. Furthermore, based on the medium-term plan, a group compliance promotion plan is prepared for each fiscal year, and each department and group company is required to implement measures accordingly. In fiscal 2023, each department, including subsidiaries under their management, formulated their own plans and implemented measures that took into consideration risks in their respective business domains.
The officers responsible for each department at Konica Minolta, Inc., and at each group company inside Japan are required to submit monthly reports on the progress of their measures, as well as any compliance issues in that department or company, to the Chief Compliance Officer. The officers responsible for compliance at each Group company outside Japan must do likewise on a quarterly basis. When a serious compliance issue arises which may cause a violation against Konica Minolta Group Charter of Corporate Behavior, it must be reported to the Chief Compliance Officer immediately.
Based on these reports submitted to the Chief Compliance Officer, the Group compliance support office and regional compliance coordinators cooperate as needed to conduct activities Group-wide. Any remaining issues are reflected in the plan for the following year.
The Corporate Audit Division, which reports directly to the President, conducts internal audits of Konica Minolta, Inc. and its worldwide subsidiaries. The audits also look at compliance, and detailed checks are made to ensure that measures are being implemented according to the annual plans of target group companies, and to confirm that the system to ensure thorough compliance is functioning properly. When an issue is identified, a corrective plan is prepared and implemented with the assistance of the support office and the relevant regional compliance coordinator. Progress is then verified through follow-up audits.
Konica Minolta routinely reports on these compliance promotion activities (compliance system) to the auditing firm.
There were no significant compliance violations requiring public disclosure in fiscal 2023. The number of compliance incidents is noted in the “Governance Data” section of the ESG Data page.

Whistle-blowing System (Help Line)

Building and improving Whistle-blowing Systems at each Group company

Konica Minolta's Whistle-blowing System (Help Line)

In the Konica Minolta Group in Japan, the Group-wide Help Line is available so that employees can use it to seek consultation and directly contact the general manager of the Legal Division, the persons in charge of Help Line, or an outside lawyer via various channels such as telephone and email, when they become aware of any conduct that poses a risk of non-compliance.
Furthermore, Konica Minolta's overseas Group companies in North America, Europe, China, Southeast Asia, and other regions accept the whistle-blowing hotlines for all Group companies in each region. Not only have we set up internal whistle-blowing hotlines within Group companies, but also external hotlines staffed by third parties such as outside lawyers and others. In Europe, the hotlines provide 24-hour multilingual support. In addition, all of the Konica Minolta Group Help Lines can be contacted and consulted anonymously. In addition, the whistleblowers do not suffer any negative repercussions for having contacted or consulted the hotlines. Each report made is examined fairly, equitably and with integrity to determine the need for an investigation.
The content of a hotline report in each case is kept confidential and investigated in detail. In the event of a compliance issue, the main department for the hotline system works in cooperation with the relevant departments to correct the problem and prevent any recurrence. The Chief Compliance Officer reports all information on the records of the whistle-blowing systems to the Audit Committee regularly.
In fiscal 2023, there were 13 reports to the whistle-blowing hotlines in Japan and 29 reports to the overseas hotlines. There were no significant incidents reported that required disclosure.
In fiscal 2023, there were seven of these reports in Japan and 14 of these overseas regarding human rights issues (abuse of power, sexual harassment, discrimination, and improper treatment).

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