Fujifilm Group Global Healthcare Code of Conduct

Research and Development
We conduct the research and development of our healthcare products and services with the highest level of quality, safety, and integrity, and comply with applicable laws, ethical policies, international standards including GLP (Good Laboratory Practices) and GCP (Good Clinical Practices) and any related Company internal regulations.  When conducting animal experiments that are necessary for research and development, we handle animals with due consideration to animal ethics.

• * Fujifilm Group does not or will not conduct or have a third party conduct animal experiments in its development process for cosmetics.^*1 Fujifilm Group does not or will not obtain materials which were subject to animal experiments after April 1, 2017.
• *1 Note: Excluding the cases where it is required for us to explain to the society or authority on safety issues or to explain to authorities.

Proper Data Handling
We properly handle data obtained from the research and development of our healthcare products and services and do not tolerate any falsification or manipulation of data.  In addition, we take appropriate steps to supervise contractors and other business partners who may handle our data to ensure that the Fujifilm Group’s standards and requirements are followed.

Disclosure of Test Results
When disclosing the results of tests and research activities, we ensure that the information is accurate, up-to-date, unbiased and not misleading, regardless of the outcome.

Obtaining Informed Consent
We communicate with research participants in a fair and transparent manner and obtain their appropriate informed consent as required by applicable laws and ethical standards, when conducting tests and research for the development and improvement of our healthcare products and services.

Privacy Protection
We take necessary measures to protect and secure the privacy and confidentiality of personal data.  We take extra care when handling any types of sensitive personal data that require special protection.

Quality, Safety and Indications for Use of Products and Services
Product quality and safety is our top priority.  We take all possible measures to ensure the quality and safety of our healthcare products and services and provide such products and services consistently.  In addition, we make every effort to prevent adverse events by accurately and comprehensibly displaying and describing information about the use of healthcare products and services.  When it is necessary, we take corrective measures and promptly report events to the relevant internal divisions, affiliates and regulatory authorities.

Handling of Complaints
We promptly report to the relevant internal divisions and affiliates, appropriately investigate and take any corrective measures as necessary when receiving complaints regarding healthcare products and services.  We appropriately report such complaints to the relevant regulatory authorities as required.

Safety Information
We continue to evaluate our healthcare products and services by conducting post-sale safety management and surveillance.  Furthermore, we promptly and appropriately report safety information regarding our healthcare products and services to the appropriate internal divisions, affiliates and relevant regulatory authorities as required, and take any necessary actions.

Collaboration with Patient Organizations
When engaging with patient organizations, we shall maintain a strong sense of ethics and respect the independence of the patient organizations. Our engagements with patient organizations will be clearly documented, our interactions will be transparent and compliant with applicable laws, to ensure public trust and foster broad understanding that Company support contributes to the activities and development of patient organizations. 

Accurate Disclosure of Information
We provide healthcare professionals with appropriate and accurate information on our healthcare products and services. 

Compliance with Indications for Use and Advertising Regulations
We provide a complete and adequate picture of our indications for use and the benefits and risks associated with our healthcare products in our advertising and promotional labeling, including appropriate usage of our products and services as approved by the required approving agencies.  We comply with all regulations applicable to marketing and advertising of our healthcare products and services and strive to ensure clear and truthful information is provided in our marketing and advertising materials.  

Compliance with Anti-corruption Regulations
When we interact with both domestic and foreign healthcare professionals we comply with the anti-corruption regulations and competition laws in each country and region, including those that prohibit inappropriate solicitation, including the offer of or the provision of economic benefit, for the purpose of influencing decisions regarding the purchase or use of healthcare products and services, as well as the Company’s internal policies and guidelines.

Ensuring Transparency
We pay attention to any conflicts of interest when providing support and benefits to healthcare professionals.  We comply with the disclosure and transparency regulations in countries and regions seeking to record and report such information, as well as those disclosure regulations that are deemed as industry standards, and make appropriate publications in accordance with applicable laws and internal regulations.

Outsourcing, Joint Research and Development
We conduct appropriate selection when outsourcing necessary duties, such as consultations, to healthcare professionals and when conducting joint research and development with healthcare professionals.  In addition, we put the contents of the activities in writing, determine in advance the fees due for services in light of the contents of the duties required and services to be provided by healthcare professionals as well as the fair market value of the healthcare professionals’ time.  We do not unfairly solicit or require any purchase of the Fujifilm Group’s products or services in return for engaging with a healthcare professional, nor do we engage with healthcare professionals as a reward for prior purchases or as an inducement for future purchases of our products.

Product Evaluations and Tests, Feedbacks and Technical Support
We engage with appropriate healthcare professionals and enter into written agreements with those healthcare professionals prior to conducting product evaluations, tests and feedback for healthcare products and services.  We comply with applicable laws and regulations when providing technical support for healthcare products and services in the clinical front and as part of training for healthcare professionals. 

Gifts and Hospitality
We comply with anti-corruption and anti-bribery laws and our internal regulations related to the provision of gifts and hospitality to healthcare professionals.  In particular, we ensure that gifts and hospitality are limited in nature so that healthcare professionals are not inappropriately influenced when making decisions regarding opportunities to collaborate with or support the Company, or purchase healthcare products and services from the Company. 

Donations, Grants and Sponsoring
We donate and provide grants to medical institutions and external organizations only in accordance with applicable laws and regulations and in an appropriate and fair way. Such decisions are taken independently of any past or future sales activities.  In addition, we ensure that the purpose and content of any funding is recorded in writing.

Fair Trading
We comply with applicable laws, industry standards and related internal regulations when interacting with business partners, for example, when providing discounts or rebates for healthcare products and services.

Marketing Activities
In all our marketing and promotion activities, we adhere to applicable laws, industry standards and internal regulations.

Suppliers, Distributors and Other Third Parties
When we engage with third parties, including suppliers and distributors, we endeavor to act with the highest ethical and business standards and hold them to the same standards to which we hold ourselves, including quality requirements.  We expect our suppliers, distributors and other business partners to conduct business in a manner that is in compliance with applicable laws and internal regulations and expect our suppliers and distributors to maintain these standards down their supply chain.  We consider compliance with our standards to be essential when choosing new business partners or continuing our relationships with existing ones.

Trade Controls
We adhere to applicable trade control regulations and sanctions and apply internal processes designed to prevent the use of our healthcare products in improper ways. We refuse any business that bears the risk of misuse of our healthcare products, such as for nuclear, biological or chemical weapons or other improper activity.  We expect our business partners to strictly comply with these same commitments.

Relationships with Public Officials
We deal with public officials appropriately and do not act against the laws and regulations that are applicable to public officials as well as the regulations of the organization to whom such public officials belong.

Approvals
We obtain necessary approvals from the regulatory authorities and other approval agencies before we manufacture and sell healthcare products and provide services.  We comply with applicable laws and internal regulations, and maintain the accuracy and appropriateness of the materials and data used when applying for approval.  We do not tolerate any falsification or manipulation of materials and data, and fully supervise contractors commissioned by the Company.