Social Responsibility

Konica Minolta Group Conduct Guidelines (excerpts)

Basic Approach

1. We will observe all relevant laws and regulations, along with in-house rules and codes.
2. We will respect social norms and will act in full awareness of corporate ethics, as well as common sense, so as to be accountable for our acts.
3. We will seek to understand the Guidelines thoroughly, and to comply with them always.
4. We will not violate the Guidelines under any circumstances, even to benefit the Company or increase profits, even if so instructed by our superiors; or if the Guidelines have long been violated by our predecessors and many other companies, or their violation has become industrial or national practice.

Products and Services

• We will provide our customers with useful, safe and high-quality products and services. (Five other items under this article)

Fair Transactions

• We will observe the Anti-Trust Act or its equivalent and carry out fair, transparent transactions, duly respecting free competition between enterprises. (10 other items under this article)

Export and Import Procedures/Regulations

• We will abide by all relevant laws, regulations and in-house rules concerning export control, to ensure that our products and technologies cannot be misappropriated as tools that could threaten peace and security. (Two other items under this article)

Protection of Confidential Information and Intellectual Property

• We will thoroughly protect the confidential information of both our Company and third parties, in full recognition of the importance of confidentiality. (Four other items under this article)

Communication and Information Disclosure

• We will actively disclose information in a fair and timely manner, including information whose disclosure is not required by laws/regulations. (Four other items under this article)

Environmental Protection

• We will work to develop, produce and market environment-conscious products and services that have minimal impact on the environment throughout their lifecycles. (One more item under this article)

Contribution to Society

• We will seek to develop friendly and mutually beneficial relations with local communities. (One more item under this article)
• In addition, the Konica Minolta Group Conduct Guidelines stipulate corporate opposition to any illegal group or organization, respect for employees, and full compliance with in-house rules.

Compliance Education

A Broad Range of Compliance Education Conducted In and Outside Japan

The Konica Minolta Group companies in Japan provide their employees with various educational programs on compliance. Given the enactment of the Company Act in May 2006, we held internal control seminars for the management of our Japanese subsidiaries during fiscal year 2006. For directors and executive officers of our primary subsidiaries, we requested their cooperation to thoroughly promote corporate ethics. We also held seminars highlighted by case studies during October, the month designated as the Corporate Ethics Promotion Month by the Nippon Keidanren (Japan Business Federation). Moreover, we provided compliance education programs for a total of 380 staff by holding seminars separately for various target audiences: new employees, mid-level employees, new managers, new directors, etc.

In North America, we have issued a manual on the Antitrust Law and held annual Antitrust Law seminars for managers concerned. To vendors of Konica Minolta products, we have provided copies of the Distribution Code of Conduct and manuals on the Antitrust Law. In 2006, the president of our US subsidiary sent letters to vendors in which he asked them to promote thorough observance of the Antitrust Law and the Distribution Code of Conduct.

In Europe, we have published Manual on the Competition Law and provided our sales subsidiaries with its copies. In addition, we asked the subsidiaries to include the topic of the Law in agendas of their important meetings to act as reminders of the issue.

Compliance Reports

Monthly Compliance Reports

All our Group companies in Japan must submit to the Group Compliance Committee monthly reports on compliance promotion activities. Overseas Group companies must submit, to both the compliance committee of their parent company and the Group Compliance Committee, quarterly reports on the progress of their compliance activities. While such reports enable Konica Minolta Holdings to confirm the progress of compliance activities at each Group company, compiling the reports also fosters employee awareness regarding the importance of compliance at Group companies worldwide. Based on these reports, the Group Compliance Committee compiles monthly reports for submission to the Auditing Committee.

Protection of Internal Whistleblowers

"HelpLine" Ensures Access through Multiple Media

In Japan, we have established a "HelpLine" system, designed to enable employees who discover any act that violates laws/regulations/corporate ethics/in-house rules to report the fact to the President and CEO of Holdings, the compliance officer or the head of the Legal Division, via telephone, e-mail, letter etc. The Group companies in Japan have also established appropriate systems for whistleblowers to inform the fact that they discover to the Compliance and other relevant committees. The business companies in Japan have their own whistleblowing systems that also cover their respective subsidiaries. Some overseas Group companies also have such systems. Konica Minolta Business Solutions USA (BUS), for instance, estblished Whistleblower’s Hotline in August 2006 and takes various initiatives to protect whistleblowers. During fiscal year 2006, Holdings received more than ten such reports; BUS also received several reports. In response, we investigated the facts swiftly, while taking sufficient measures to protect whistleblowers.

Export Control

Rigorous Export Control to Maintain World Peace and Security

Given increasing concerns for proliferation of mass destruction weaponry and terrorists’ attacks, it is essential that in exporting our products and components, as well as providing technological information, we identify actual users and their intended end-usage of our items and technologies. Although our products and components are originally designed for civil use, we still need to confirm that they will not be misappropriated for developing or producing mass destruction weapons. To minimize this risk, the Konica Minolta Group companies in Japan have established the Export Control Code for Security Purposes, as well as rigorous export control systems, under which we determine whether or not items to export are applicable to the categories specified in the Arms Export Control Act, examine transactions, provide related education and conduct audit activities.

Information Security

We are reinforcing information security control, particularly those concerning in-house information control and safety operation of IT systems.

In tandem with the rapid diffusion of information technology in our business environment, the Konica Minolta Group has been actively introducing IT systems in the full-spectrum of our business operations. In this environment, we are committed to information security control, based on the full awareness of its vital importance.

Since the integration of Konica and Minolta in August 2003, we have been promoting the IT Security Code as part of a program to integrate networking systems of the former two companies. In 2005, we began using the Plan-Do-Check-Act (PDCA) cycle management in IT security control within the Group. Concurrently with these efforts, individual Group companies worked to obtain the Information Security Management System （ISMS 2.0） certification.

In October 2005, ISO 270001 was established as the international standard of the Information Security Management System. Since this new international system took the place of the ISMS in Japan in fiscal year 2006, in that year Konica Minolta began the Group-wide campaign to obtain ISO27001 certification, in line with which individual Group companies are promoting their respective action plans.

【Konica Minolta Information Security Policies】

• Konica Minolta Information Security Policies (37.4KB)

【Responses to Requirements of Relevant Laws and Regulations】

Regarding the security control initiatives stipulated in the Personal Information Protection Law, we are promoting security control in compliance with the control programs of the Information Security Management System (ISMS). To meet the requirements pertaining to the enterprise internal control operations stipulated in the Financial Products Transaction Law (Japanese SOX Act), we also take appropriate measures in the area of information security control in compliance with ISMS programs.

Protection of Personal Information

Protection of Personal Information and Measures to Prevent Information Leakage

In Japan, the Personal Information Protection Law took effect in April 2005. In fiscal year 2004, Konica Minolta began preparing personal information protection policies, building appropriate systems, and compiling related manuals. To thoroughly promote the Company’s policies to protect personal information, we have held explanatory meetings and taken various other means.

Despite such efforts, regrettably, there were several accidents involving loss of personal information: loss of a PC that contained data about our customers (June 2005), transmission of customers’ mail addresses to a wrong destination (July 2005), theft of a briefcase that contained documents on our customers (November 2005), and loss of a clear file containing customer information (November 2006). Immediately after each event, we reported to relevant governmental authorities, informed and apologized to customers concerned, and disclosed the fact on our website. Since all the incidents were caused by human error, by sending the corporate notice we have reminded all employees of the vital importance of personal information protection, promoted their awareness of relevant rules, reviewed and improved our information control systems, augmented employee education and audit, and took every possible measure to prevent recurrence.