Compliance

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 group compliance promotion plan for each fiscal year. Each department and group company is required to implement measures accordingly. In FY2025, 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 persons 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 officer in charge of Group Compliance. The persons 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 officer in charge of Compliance, 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.

	FY2023	FY2024	FY2025
Number of Serious Compliance Issues Requiring Public Disclosure	0	0	0

Building a system to promote consistent compliance Group-wide

At Konica Minolta, the President and CEO has ultimate responsibility for Group compliance. The officer in charge of Group Compliance, 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 officer in charge of Group Compliance 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 persons responsible for compliance from Business Units and Corporate Divisions in charge of Group-wide functions as well as certain C-suite executives.
To promote compliance in each department at Konica Minolta, Inc., the General Manager of each department serves as the person responsible; at subsidiaries inside and outside Japan, the president of each subsidiary serves as the person responsible at each company. The Chief Compliance Officer reports twice a year to the Audit Committee regarding progress on activities and important issues for the Group.

Strengthening Group-wide Coordination in Compliance Activities

The Legal Division of Konica Minolta, Inc. serves as the Group compliance support office, assisting the Chief Compliance Officer in formulating key compliance initiatives and promotion measures. It also directly and indirectly supports the compliance activities of each department and Group company while promoting compliance initiatives across the Group.
The Chief Compliance Officer also appoints regional compliance coordinators in Europe, North America, China, and Southeast Asia to implement compliance promotion activities tailored to the circumstances of each region.
In FY2025, the Group compliance support office and regional compliance coordinators worked together to support the implementation of compliance programs at newly acquired companies in Japan and overseas, as well as at smaller Group companies, thereby promoting the establishment of a strong compliance culture throughout the Group.

Konica Minolta has established the Konica Minolta Group Charter of Corporate Behavior as the principles of conduct to be shared by all Group employees, regardless of the country or region in which they work. Furthermore, the Charter is posted on the Group's intranet in dozens of languages (including Japanese, English, Chinese, German, French, Spanish, Portuguese, Italian, Russian, Korean, Thai, Vietnamese, and Malaysian) so that everyone working throughout the Group can share a common understanding of the Charter and put it into practice.

Presidents of Group companies in Japan and overseas prepare a declaration based on the Compliance Promotion Declaration made by the president of Konica Minolta, Inc. The Group utilizes every opportunity to promote awareness of this document among its employees.

Konica Minolta requires that officers and employees of Group companies submit a written acknowledgement that they will give top priority to compliance in their conduct, with an understanding of the Konica Minolta Group Charter of Corporate Behavior, the Compliance Promotion Declaration by the presidents of subsidiaries, and the significance of using and how to use the whistle-blowing system, "Help Line." To ensure this, Konica Minolta mandates that officers, managers, and employees of all Group companies worldwide submit a written compliance acknowledgement and reaffirm each year that they will behave with propriety and social responsibility, thoroughly understanding and adhering to compliance requirements.

	FY2023	FY2024	FY2025
Training completion rate for the Group Charter of Corporate Behavior	100%	100%	99.9%
Submission rate for the written compliance acknowledgement	100%	100%	99.9%

The Konica Minolta Group has established the Konica Minolta Group Charter of Corporate Behavior and the Konica Minolta Group Guidance for the Charter of Corporate Behavior, which outline specific actions for putting the Charter into practice. When the president of each Group company deems it necessary, they seek to use these as a basis for creating manuals and codes of conduct that comply with the laws, regulations, and corporate ethics of each country. These materials are posted on the company intranet to ensure widespread awareness among employees.

Based on the Konica Minolta Group Charter of Corporate Behavior, which sets out action guidelines to embody the Konica Minolta Philosophy, and the Konica Minolta Group Guidance for the Charter of Corporate Behavior, which describes how to put the Charter into practice, the company conducts a comprehensive risk assessment every year to identify compliance-related risks. These risks are reported to the Risk Management Committee, and are then identified as important compliance issues. The identified issues are then addressed as priority issues.
In addition, the Group has introduced a system that highly evaluates talent who act in accordance with the Konica Minolta Philosophy, and a system to evaluate employees who take on challenges and reflect that in compensation, regardless of the outcome. On the other hand, to promote the practice of compliance, the Group disciplines compliance violations in accordance with the employment regulations and internal rules of each company.

Konica Minolta, Inc. provides its employees at each level with various training programs on compliance. Programs are conducted every year for new hires, mid-career employees, mid-level employees, new managers, and new executives. Various trainings on laws and regulations are held annually for all employees (including part-time and contractors) of all Group companies in Japan. In FY2025, seminars were conducted on anti-corruption laws, the Antimonopoly Act, the Act on Proper Transactions for SMEs (the revised Subcontract Act), the Act on the Protection of Personal Information, the EU's General Data Protection Regulation (GDPR), and security export controls. At Group companies outside Japan, the regional compliance coordinators formulate an annual training plan and conduct their own training based on each country's laws. Group companies in North America and Europe provide business ethics training to all employees through e-learning every year.
Each year the company continues to provide compliance training for the newly appointed presidents and directors of Group companies. Through these training programs, Konica Minolta ensures that presidents and directors of subsidiaries constantly improve their sense of ethics and promote compliance. Interactive refresher training also has been held for presidents of Group companies who have been in their position for four years. The aim was to further promote compliance.

Building and Improving Whistle-Blowing Systems at Group Companies

In the Konica Minolta Group in Japan, the Group-wide Help Line is available so that employees can 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 have established whistle-blowing hotlines for all Group companies in their respective regions. These include not only internal whistle-blowing hotlines within Group companies but also external hotlines staffed by third parties, including outside lawyers. In Europe, the hotlines provide 24-hour multilingual support. In Japan, China, and Southeast Asia, the Konica Minolta Group's hotlines are available to suppliers. In Europe, Konica Minolta has also begun making the hotlines available to suppliers. In North America, the hotlines are open to all stakeholders, including suppliers.
In addition, whistleblowers do not suffer any negative repercussions for contacting or consulting with the Konica Minolta Group's hotlines. Each report is examined fairly, equitably, and with integrity to determine whether an investigation is required.
The content of each hotline report is kept confidential and investigated thoroughly. In the event of a compliance issue, the department responsible for the hotline system works in cooperation with the relevant departments to correct the problem and prevent any recurrence. The Chief Compliance Officer regularly reports on the operation of the whistle-blowing systems to the Audit Committee.
There were no whistle-blowing cases requiring disclosure during the fiscal year.

Number of Whistle-blowing Reports	FY2023	FY2024	FY2025
Total	42	71	77
Japan	13	17	19
Overseas	29	54	58

Implementing global anti-corruption measures focusing on areas with high corruption risk

Along with economic globalization, the need for anti-corruption measures has increased, and relevant regulations are being strengthened not only within Japan, but also for international commercial transactions. The guidelines for preventing corruption are set forth under Section 2, "Fair and Transparent Business Activities" of the Konica Minolta Group Guidance for the Charter of Corporate Behavior. They include a prohibition of bribery, policies on contributions and political donations, political activities, sponsorships, and charity donations, and a prohibition on insider trading, conflict of interest, and ties with antisocial forces.
In the Group Annual Compliance Plan, which is formulated every year considering the expectations of society, the degree of impact on the company and society and the possibility of occurrence, antitrust laws and anti-corruption measures were positioned as priority issues in FY2025. Under the compliance promotion structure that has been established worldwide, the Group continued to provide education in line with the relevant laws, business environments, and customary practices of each country and region. The compliance issues and risks in each region are reported to the Chief Compliance Officer via monthly or quarterly compliance reports.
Konica Minolta revises its anti-corruption guidelines in countries and regions in and outside Japan in response to changes in their respective laws, cultures, and social conditions, and ensures that all Group employees are fully aware of them.
As part of the company's comprehensive anti-corruption efforts, standards and rules have been in operation concerning the provision of gifts and entertainment to clients. They have been prepared by referring to the country rankings in the annual Corruption Perceptions Index (CPI) reported by Transparency International (TI), and are applicable to Konica Minolta organizations operating in countries where the risk of corruption is high. Accounting monitoring and verification have been conducted and deployed at each subsidiary, and reports are sent every quarter to the compliance department.

	FY2023	FY2024	FY2025
Number of incidents involving bribery and corruption (cases)	0	0	0

Formulating antitrust law policy and undertaking education in accordance with the laws and business environment in each region

Konica Minolta recognizes that when violations of an antitrust law occur, the impact on companies, the economy and society is extremely serious. Section 2, "Fair and Transparent Business Activities" of the Konica Minolta Group Guidance for the Charter of Corporate Behavior stipulates the following. Complying with applicable laws, regulations, etc. related to prohibition of monopolization, fair competition, and fair trade in respective countries and regions in which it operates, and for fairness and transparency in transactions between companies. Antitrust law measures have again been designated as a Konica Minolta group-wide priority in the Group's FY2025 compliance promotion plan. The Group compliance support office and the regional compliance coordinators have taken the lead in providing education to relevant employees at Konica Minolta, Inc. and its subsidiaries worldwide, in line with the laws and business environment in each region.
Monthly and quarterly reports on the progress of compliance promotion are regularly submitted to the Chief Compliance Officer, including the status of antitrust law issues and risks.

	FY2023	FY2024	FY2025
Number of antitrust law violations (cases)	0	0	0

Practicing strict export control to maintain international peace and security

Today there is heightened concern over the proliferation of weapons of mass destruction and terrorist attacks. Accordingly, as a member of the international community, the government of Japan participates in international treaties and regimes such as the Nuclear Nonproliferation Treaty and the Wassenaar Arrangement and has reflected their rules to be observed in Japan's Foreign Exchange and Foreign Trade Control Law. This law regulates the trade not only of weapons, but also of goods and technology that could be used to produce weapons. It specifies that companies are required: (1) to determine whether the item is an advanced technology or goods that could be used for weaponry as listed under international agreements (technical classification); and (2) to check the users and the intended use for any risk of its being used for the development or manufacture of weapons of mass destruction (transaction screening).
Konica Minolta has established an Export Control Code for Security Purposes and created an export control system in group companies in Japan, and it carries out strict technical classification of products and transaction screening to ensure adherence to the Foreign Exchange and Foreign Trade Control Law. In addition, Konica Minolta systematically provides security export control training to employees and conducts internal audits on security export control operations.

Konica Minolta has established the Konica Minolta Group Charter of Corporate Behavior and the Konica Minolta Group Guidance for the Charter of Corporate Behavior as its global standard for the disclosure of useful and reliable information.
In its advertising, Konica Minolta gives first priority to compliance with the relevant laws and industrial regulations in each region of the world. Beyond the basic laws, the company endeavors to conduct fair and proper advertising, taking into account the voluntary restrictions and advertising standards that apply in each of its business fields, as well as respecting public morality and the viewpoints of stakeholders.
For example, laws and standards that the company observes in Japan include regulations governing advertisements such as the Act against Unjustifiable Premiums and Misleading Representations, the Standards for the Representation of Copiers and Multi-Function Printers of the Japan Business Machine and Information System Industries Association (JBMIA) and screening standards for various media.