About Konica Minolta

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Compliance Promotion System

Group Compliance Promotion System

Building a system to promote consistent compliance Group-wide

At Konica Minolta, the Chief Compliance Officer, who is 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 and CEO 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 corporate departments 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 official responsible for compliance; at subsidiaries inside and outside Japan, the president of each subsidiary serves as the official responsible for promoting compliance at each company. The Chief Compliance Officer reports regularly to the Audit Committee regarding the progress of compliance activities and important compliance issues in the Group.

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 Group’s compliance, serving as a Group compliance support office assisting the Chief Compliance Officer. The Legal Division also assists each department and subsidiary with compliance activities, directly and indirectly, and provides support for group-wide information management.

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 2017, 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.

In order to promote compliance at Group companies, the Group compliance support office draws up a medium-term compliance promotion plan with the cooperation of the regional compliance coordinators, which is then approved by the Chief Compliance Officer. 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 2018, each department, including subsidiaries under their management, formulated their own plans and implemented measures that take into consideration compliance risks in their respective business domains.

The officials responsible for compliance in 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 officials responsible for compliance at each Group company outside Japan must do likewise on a quarterly basis. When a 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 that support the promotion of compliance Group-wide. Any remaining issues are reflected in the compliance promotion 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 include a compliance standpoint, and detailed checks are made to ensure that measures are being implemented according to the annual plans of target group companies, and that important affairs are prepared to ensure thorough compliance. When an issue is identified, a corrective plan is prepared and implemented with the assistance of the Group compliance support office and the relevant regional compliance coordinator. Progress is then verified through follow-up audits.

There were no significant violations involving bribe, fraud, embezzlement, privacy protection, or any other area of the Konica Minolta Group Charter of Corporate Behavior which warrant disclosure in fiscal 2018.

Internal Hotline Systems(Helpline)

Building and improving hotlines at each Group company

In the Konica Minolta Group in Japan, the Group-wide helpline is available so that employees can use it to seek consultation and directly contact the president, Chief Compliance Officer, general manager of the Legal Division, 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.

Konica Minolta has also established internal hotlines outside Japan. Konica Minolta Business Solutions U.S.A., Inc., an office equipment and solutions sales company in the U.S., has a Whistleblower's Hotline, which has served as an internal reporting system for its employees in North America, including its subsidiaries in Canada and Mexico. In Europe, the Integrity Hotline has served as a 24-hour, multi-lingual reporting system for all Group employees in Europe. Furthermore, the Group expanded its internal hotline systems in 2015. In China, an internal hotline system using an outside lawyer as a receiver of reports was established for all Group companies in China (excluding companies in Hong Kong). Konica Minolta Business Solutions Asia Pte. Ltd. in Singapore continued to establish internal hotlines for Group companies in Southeast Asia. In addition, measures to raise awareness of internal hotline systems were taken again at subsidiaries in and outside Japan, in order to increase their accessibility.

These hotlines can be contacted and consulted anonymously. In addition, the whistleblowers do not suffer any negative repercussions for having contacted or consulted the hotlines.

The content of a hotline report in each case is kept confidential and investigated in detail, and instructions are given to concerned departments for immediate improvements, taking care to ensure that whistleblowers suffer no negative repercussions. The Chief Compliance Officer reports information on the records of the internal hotline systems to the Audit Committee regularly.

In fiscal 2018, there were 23 reports to the internal hotlines in Japan (none of these to the outside lawyer) and 24 reports to the overseas hotlines. 15 of these reports in Japan and 16 of these overseas were regarding human right issues (power harassment/sexual harassment/discrimination/improper treatment).

There were no significant incidents reported from these internal hotlines that warrant disclosure either inside or outside Japan in fiscal 2018.

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