CSR activity report


Improve and maintain governance structures by further disseminating an open, fair and clear corporate culture.

Outline of Activities in FY2018

[Target] Develop a governance organization for the entire Fujifilm Group and reinforce the business management process.
[Image]Training program for risk managers at overseas sites

Training program for risk managers at overseas sites

  • Increased the number of independent outside directors to four to augment deliberations by the Board of Directors and improve transparency of management decision-making by using an independent outside director.
  • Established the Nomination and Remuneration Advisory Committee chaired by an independent outside director as an arbitrary advisory body to the Board of Directors.
[Target] Improve compliance awareness across the entire global Group and reinforce risk management.
  • Revised the Fujifilm Group Charter for Corporate Behavior and Code of Conduct.

  • Follow-up investigation on the FY2017 compliance awareness survey ⇒ No major issues.

  • Implemented training programs for risk managers at several overseas regional headquarters.

  • Introduced the information security reporting system globally.

  • Implemented disaster prevention education and training to prepare for a wide-area disaster.

[Target] Maintain a fair and independent audit and improve the audit quality level.
  • Established methods for analysis of financial data and work record etc. as well as an e-mail forensics mechanism; all of which have already been deployed in domestic audits and have led to improving audit completeness and objectivity.

Future Activities and Targets
  • Strengthen consolidated management of compliance activities by operating companies FF & FX under an FH initiative and by execution of measures aimed at further improving compliance awareness among all employees.

  • Enhance deliberations by the Board of Directors and improve transparency of management decisionmaking.

Revision of Charter for Corporate Behavior and Code of Conduct

Covering SDGs, human rights, risk management and other issues in response to changes in the global situation

The Fujifilm Group believes a business corporation as an entity that provides value to society through its business activities and earns profits as fair compensation for its efforts. At the same time, we believe we must function as a member of society to contribute to sustainable development. In view of the ever-growing influence and importance of the role companies must fulfill in society, we introduced in 2017 the Sustainable Value Plan 2030 (SVP 2030) to meet the expectations of society. Furthermore, we have taken action in face of the changing demands of society and revised our Charter for Corporate Behavior and Code of Conduct in April 2019 to clarify how each employee should behave and act in business. The key is our declaration to “make an active contribution to resolving social issues through innovation.” It urges each and every employee to take on their assigned role in the face of many social issues and tackle innovative challenges with the aim of creating the sustainable society envisioned under SVP 2030. Additionally, it communicates to all employees that business activities must be conducted with “an open, fair and clear corporate culture” and explicitly states that compliance is the key to a company continuing to be needed and trusted by society.
To promote greater understanding of the Charter for Relationship between the Fujifilm Group Corporate Philosophy and Vision and the Charter for Corporate Behavior and Code of Conduct

Corporate Behavior and Code of Conduct, education programs will be implemented in a total of 24 languages so that they can reach all the employees in the Fujifilm Group worldwide.

Relationship between the Fujifilm Group Corporate Philosophy/Vision and the Charter for Corporate Behavior/Code of Conduct

Reinforcement of Governance

Improved audit capabilities through consolidation of audit organizations and introduction of advanced IT-based audit methods

In September 2017, FUJIFILM Holdings established its Global Audit Division, consolidating the existing audit organizations in each Group company, to create a system for the direct auditing of consolidated subsidiaries. This has led to the centralization of information at each company, swift reporting of action, effective utilization of auditing human resources scattered across the Group and other benefits that led to the auditing of all 300 companies in the Group in three years.

In addition, the Audit Planning Group was established to introduce new auditing methods utilizing IT. One such method is the e-mail forensics system, which is very often outsourced to external service providers in an emergency but not in a normal internal audit. At FUJIFILM Holdings, however, the original system was developed internally, utilizing our own AI and other internal systems. This led to analysis that combined more detailed internal data and produced greater accuracy, making it possible to detect problems and signs of wrongdoing as well as to save costs through internal development. The system has already been implemented at sites in other countries as well as in Japan, and we are going to expand its application in the future.

Disaster Prevention Training

Training conducted to raise disaster prevention awareness among all employees

Fujifilm implements various activities to raise disaster prevention awareness in each and every employee. In FY2018, the first e-learning program for disaster prevention was implemented for all employees. Each participant studies for approximately 15 minutes to solidify their knowledge of disaster prevention, including the “basic information of disaster” and “the importance of preparation at home” through their responses to a Q&A checklist. Additionally, stockpiles to prepare for an emergency are being offered for sale at corporate cooperative unions in the Group. They come in the form of “original sets” consisting of foodstuffs, drinking water and supplies needed in an emergency. The items were selected by employees who experienced the Great East Japan Earthquake and the Kumamoto Earthquake. Each set comes with a service notifying the purchaser of the expiration date of the set six months in advance.

We will continue disaster prevention activities, based on the conviction that the safety and security of the lives of employees and their families will lead to the company’s early recovery and business continuity in the event of a disaster.

Compliance and Risk Management

In response to the inappropriate accounting experienced by Fuji Xerox overseas subsidiaries found in FY2017, we reviewed our corporate governance across the entire group. We also conducted a compliance education program concerning the incident to disseminate the open, fair, and clear corporate culture that we set as the foundation of Fujifilm Group conduct. This program aimed to ensure that we could listen to all stakeholders, exchange opinions in both directions, and adhere to the rules in a fair and just manner, and that we all take responsibility for the decisions and actions that we make and thereby maintaining business transparency with utter honesty.

We have revised the Charter for Corporate Behavior and the Code of Conduct in April 2019 to reflect the changes in social trends and in our approach to corporate social responsibility. These texts have been translated into 24 languages and distributed to different countries to enable our employees across the world to clearly understand the Charter and Code. We also provide all Group employees—both inside and outside—Japan with an e-learning program since May to cultivate their understanding of these important documents.

In FY2019, we did not experience any critical compliance issues that we needed to make public.

In FY2018, we implemented training programs for existing employees, new employees (including newly appointed executive officers and managers), and risk managers, as well as individual training programs for group companies (a total of 112,000 employees of the Fujifilm Group participated in these programs).

Contents of Compliance Education
Intended audience Details Participants (FY2018 results, Unit: person)
Fujifilm Group Fuji Xerox Group Fujifilm Holdings Total
Domestic Overseas Total Domestic Overseas Total Domestic Overseas Total
All employees
(Executive officers, managers of divisions, general employees)
Overall compliance - 12,660 12,660 - - 0 - 12,660 12,660
Compliance declaration for code of conduct - - 0 24,273 21,654 45,927 24,273 21,654 45,927
Information security, e-learning 21,934 - 21,934 26,412 - 26,412 48,346 - 48,346
New employees
(New executive officers, new managerial personnel, new general employees)
Overall compliance and risk management 473 - 473 752 - 752 1,225 - 1,225
Group companies
(domestic priority companies)
(Executive officers, general employees(including contract/temporary employees))
Harassment prevention 3,780 - 3,780 - - 0 3,780 - 3,780
Risk managers General risk management - 84 84 - - 0 - 84 84
Enhancement for harassment cases 67 - 67 - - 0 67 - 67
Sales companies
(Presidents and managerial personnel)
Training of compliance case study - - 0 - 62 62 - 62 62
Total 26,254 12,744 38,998 51,437 21,716 73,153 77,691 34,460 112,151
  • * We have completed the compliance training programs for all necessary employees in FY2019.

Conducting a follow-up survey to the FY2017 Compliance Awareness Survey

We conducted a Compliance Awareness Survey of all our Group employees (93,000 employees across 320 organizations) in December 2017. In September 2018, we undertook a follow-up survey targeting the organizations where a large number of respondents answered that they know about a compliance violation (27,000 employees across 23 organizations) to identify the concrete facts in these cases. As a result, actual compliance violations identified were as low as 4% of reported case and there were no serious problems that could affect our business. The concrete issues we discovered in the survey were further investigated within each organization to prevent any recurrence.

Conducting Harassment Awareness Survey in “critical” workplaces in the Fujifilm Group

The Harassment Awareness Survey undertaken in December 2016 of all Fujifilm Group employees in Japan (21,000 employees in 36 companies) found out that seven companies had higher percentages of employees answering that they had experienced harassment than the Group mean figure. We conducted the same awareness survey in June 2018 on those seven companies and two additional companies that newly joined the Group. The additional survey identified an improvement in only one company but the remaining eight companies were still below the mean figure. Since September 2018, we have been providing a harassment prevention program and workplace discussions in each company to prevent any further cases of harassment.

The Fujifilm Group has a separate whistle-blowing system. One is in Fujifilm Holdings that can be accessed directly by all Fujifilm Group employees across the world (consultation available in Japanese, English and other 23 languages), and the other enables employees to report to each regional headquarter. Both can be accessed anonymously, and protection of the whistleblower is stipulated to protect them from detrimental treatment caused by reporting.

  • Number of whistle blowing reports in the Fujifilm Group in FY2018: 298 (199 in Japan and 99 in overseas) Seventy percent of the report contents were harassment, human relationship issues, and HR or labor matters; however, no serious issues were identified.

We reported the status of risk reporting in FY2018 and priority risk issues for FY2019 at the FUJIFILM Holdings ESG Committee meeting held in May 2019. We will continue working on risk prevention activities based on the Priority Risk Map.

FY2019 Priority Risk Map for the Fujifilm Group

FY2019 Priority Risk Map for the Fujifilm Group


Risk item Reason for selection Countermeasures
Information security In response to the expansion of ICT in products, services and manufacturing, the effective range of information security is expanding. Therefore, a review of conventional countermeasures is necessary.
  • Improvements to internal rules and risk management systems
  • Comprehensive implementation of a range of compliance, information security and risk training programs
Personal data management In the face of the growing reinforcement of local regulations in each country, the effects of violations and information leaks are growing. Therefore, more comprehensive management is necessary.
Compliance of Healthcare Business (Securing ethics and transparency) In the Healthcare Business, ethical conduct and transparency are requested by the regulation authorities in each country. We recognize this is one of our priority issues.
Eliminating misconducts and fraud Incidents are declining; however, more comprehensive management and education are necessary overseas.
Labor management In line with the Work Style Reform Law that was enacted in April 2019, we manage working hours to suitable lengths to prevent long working hours.
Harassment With society’s increasing interest in harassment issues, harassing behavior must be prevented.
Initiatives of FUJIFILM Corporation and its Subsidiaries

FUJIFILM Corporation and its subsidiaries apply a PDCA (Plan‐Do‐Check-Act) cycle to enhance risk prevention activities,  as we do for improving compliance awareness. We assign a risk manager (managerial personnel) to each division of FUJIFILM Corp. and its subsidiaries, who annually evaluates the probability of risk occurrence and the impact of risks on business. We extract priority risk issues and formulate action plans (P) and share and execute action plans across business units (D). We check the progress of action plans regularly and review them according to the progress and environmental changes (C) and leverage the outcome in formulating action plans in the following year (A).

Initiatives of Fuji Xerox Co., Ltd. and its Subsidiaries

In April 2018, Fuji Xerox Co., Ltd. established the Compliance & Risk Management Division (the “CP&RM Division”), a dedicated function to promote compliance and risk management activities, based on the concept of compliance and risk management as the two sides of the same coin. Each of its subsidiaries also established the compliance and risk management system. They are effectively and efficiently promoting measures to maintain and improve compliance practice, from the aspects of right conduct required in overall business activities and possible risks that may hinder such right conduct. 

Under this organizational framework, we take measures considering risks that may occur in our daily business activities, as well as enhancing response procedures to promptly and appropriately handle the occurrence of risks.

In FY2018, we established a system which all division heads of Fuji Xerox and its domestic subsidiaries identify priority risk issues and eliminate those risks at their respective division.

The Fujifilm Group has implemented procedures for reporting/handling the occurrence of risks led by FUJIFILM Corporation and Fuji Xerox Co., Ltd. in order to promptly handle the occurrence to prevent the expansion of risk impact. We also formulate recurrence prevention measures, actively promoting the prevention and recurrence of risks.

Initiatives of FUJIFILM Corporation and its Subsidiaries

FUJIFILM Corporation and its subsidiaries formulate the “Basic Regulations for Risk Management” to handle the occurrence of risks/potential risks. We also operate the “Risk Issue Reporting System” to comprehensively manage and handle risk issues. Any risks occurred are handled through a collaboration between the on-site workplace and the management division.

Initiatives of Fuji Xerox Co., Ltd. and its Subsidiaries

Fuji Xerox Co., Ltd. and its subsidiaries formulate the “Crisis Escalation Guidelines” to handle the occurrence of crisis. These Guidelines clarify the rule of reporting to managerial personnel. It enables prompt reporting of the scale and impact of the issue to the management for appropriate decision-making and response when any crisis occur.

To nurture a corporate culture based on the open, fair, and clear sprit, as stated in the Group Vision, Chapter 2 (Fair Corporate Activities) of the Fujifilm Group Charter for Corporate Behavior and Code of Conduct clearly declares the requirement for Fair Sales Activities, Fair Procurement, Prevention of Corruption, and Prohibition of Bribery and restriction on gift-exchange and Entertainment. The chapter states that we must avoid any actions that could cause suspicion of a collusive relationship with a third party or could jeopardize the fair relationship with suppliers; we should avoid being involved in any corrupt activities; and we also should avoid any dubious action that could cause suspicion of fraud with retailers, business partners, public officials and government representatives. In response to the increasing reinforcement of corruption prevention laws across the world, each Group company implements anti-bribery rules. We also conduct regular onsite audits in areas where the risk is deemed to be high.

The Fujifilm Group never had a corruption or bribery, and we have never been investigated by administrative authorities concerning any anti-corruption matters.

The Fujifilm Group is committed to observing competition laws, by introducing a system for regular education programs and implementing annual self-audits. Over the past 10 years, we have never been subject to a penalty concerning competitive practice nor ongoing competition lawsuits. 

With respect to the Act against Delay in Payment of Subcontract Proceeds, Etc. to Subcontractors (the “Subcontract Act”), we implemented internal investigations in response to the document survey by the relevant authority, and confirmed that there was no material violation in FY2018. In FY2019, in response to the consumption tax rate hike implemented in October in Japan, we promoted the prevention of violations by revising our procurement system and communicating any system changes due to the tax rate hike to our business partners.

Initiatives of FUJIFILM Corporation and its Subsidiaries

FUJIFILM Corporation and its subsidiaries have long been committed to observing the competition laws the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade (the “Anti-Monopoly Act”). It formulated and implemented the Competition Law Compliance Program at each group companies in Japan, the US, Europe, and the Asia Pacific region. 

More specifically, FUJIFILM Corp. established in-house regulations governing compliance with the Competition Law. It also established a compliance system led by the Competition Law Compliance Officer. Under the system, each subsidiaries and division should conduct self-audits on a regular basis.In addition, considering the recent trends, such as the recent strengthened enforcement of the Competition Law on a global level and changes in our business environment, FUJIFILM Corp. provided each employee with the “Competition Law Compliance Manual” (which outlines basic knowledge about the act, the code of conduct for compliance etc.) and the “Competition Law Guide” (which outlines points to consider in compliance with the act at the time of business/marketing planning). These documents practically and comprehensibly outline example cases and check points to comply with the Competition Law. With the use of these tools and self-audits, FUJIFILM Corp. is actively promoting the compliance of the Competition Law.

With respect to the Subcontract Act, FUJIFILM Corp. allocates a Subcontract Management Officer to each division to ensure their compliance with the Subcontract Act. It also provides seminars for persons in charge of procurement in divisions that frequently conduct subcontract transactions. It also checks the status of compliance by each division that conducts subcontract transactions prior to the annual inspection by the Japan Fair Trade Commission or the Small and Medium Enterprise Agency. In this way, FUJIFILM Corp. and its subsidiaries are actively promoting the compliance of the Subcontract Act across the Group.

Initiatives of Fuji Xerox Co., Ltd. and its Subsidiaries

Fuji Xerox Co., Ltd. created and published the “Compliance Guideline for the the Act on Prohibition of Private Monopolization and Maintenance of Fair Trade (the “Anti-Monopoly Act”) on its intranet. This guideline explains the details of the act and points to consider in daily operations for employees of Fuji Xerox and its domestic subsidiaries.

In addition, it has discussed the theme of the Anti-Monopoly Act on its Legal Newsletter (monthly issued) several times to ensure that the employees of Fuji Xerox and its domestic subsidiaries have sufficient legal knowledge and improve their compliance awareness. The newsletter is designed to explain its employees about legal key points in their daily operations, in an easy-to-understand manner, using actual incidents and cases reported in Japan. Fuji Xerox also provides seminars by external professionals for overseas sales subsidiaries. In this way, it is actively promoting the compliance of the Anti-Monopoly Act.

With respect to the Subcontract Act, it provides seminars, etc. for persons in charge of procurement in divisions that frequently conduct subcontract transactions. It also checks the status of compliance by each division that conducts subcontract transactions prior to the annual inspection by the Japan Fair Trade Commission or the Small and Medium Enterprise Agency. In this way, Fuji Xerox and its subsidiaries are actively promoting the compliance of the Subcontract Act across the Group.

The Fujifilm Group has created the “Global Security Trade Control Policy,” one of the basic policies commonly shared across the Group. This Policy aims to prevent goods and technology that could be converted into arms or be adapted for military use from being obtained by terrorists or nations that could threaten international security. We therefore declare that we are committed to maintaining international safety and security not only by observing the related laws. We also formulated the “Fujifilm Group Security Trade Control Regulation” reflecting the policy and conduct export control in compliance with laws and regulations under our export control framework led by the president as an Export Control Chief Officer.

Our major initiatives are as follow:

We provide e-learning materials that explain the intent and purpose of trade control to help employees receive necessary training when needed. We regularly host seminars on trade control matters, such as revisions to the relevant laws, regulations, and rules, and export/import management methods to help employees gain more understanding. Furthermore, we conduct on-site audits in addition to annual document-based audits  at each group company and division to confirm any necessary improvements.

The Fujifilm group is continuously working on these initiatives and implements robust export/import controls. We never had an issue pointed out by administrative authorities concerning export/import control.

Fujifilm Group Export Control Framework
FH: FUJIFILM Holdings Corporation FF: FUJIFILM Corporation; FX: Fuji Xerox Co., Ltd.

FH: FUJIFILM Holdings Corporation
FF: FUJIFILM Corporation; FX: Fuji Xerox Co., Ltd.

Information security

The Fujifilm Group regards information security as one of the major risks and implements the following measures:

  1. Establishment of “Basic Policy on Information Security”, “Global Information Security Regulations” and “Information Security Guidelines”. Thorough implementation of security measures. Provision of regular education programs for employees
  2. Continuous security reinforcement to address cyber security threats that have been increasing recently.
  3. Establishment of an information security incident responses team in FUJIFILM and Fuji Xerox to minimize the damage from an information security incident, should one occur.  Implementation of simulation trainings for incidents (At lease once a year).
  4. Providing vulnerability tests (once in six months) for the web servers that have possibilities of attacks from outside.

In fiscal 2018, there were no serious cases related to information security were pointed out by administrative authorities and assessed to require public disclosure.

Privacy Protection

The Fujifilm Group specifies privacy protection as one of the items in the chapter of Respect for Human Rights in its Code of Conduct. This policy is also applied to the “Request to Suppliers” and to the entire business operations of the Fujifilm Group. We have also formulated the “Privacy Policy” and the “Personal Information Protection Regulations” for each group company to ensure the strict and appropriate management of personal information. We also conduct regular audits and employee education programs.

The importance of privacy protection is growing every year. We ensure privacy protection in the course of risk identification and action planning for the entire Group each year to assure the effectiveness of the Group’s risk management. In FY2017, we implemented measures in collaboration with the Group’s regional headquarters in Europe in advance of the introduction of the EU General Data Protection Regulations (GDPR) planned in May 2018. 

In FY2018, there was no serious issue of customer privacy pointed out by any third party or administrative authorities and determined to be disclosed externally.

Acquisition Status of Privacy Mark and ISMS

December 2019 

Type Certified subsidiaries


FUJIFILM Medical Co., Ltd. FUJIFILM Medical Solutions Co., Ltd.  FUJIFILM Imaging Systems Co., Ltd. 
FUJIFILM Imaging Protec Co., Ltd. FUJIFILM Techno Service Co., Ltd. FUJIFILM Media Crest Co., Ltd. 
Fuji Xerox System Service Co., Ltd.


FUJIFILM Corporation Recording Media Products Division  
FUJIFILM Global Graphic Systems Co., Ltd. 
FUJIFILM Software Co., Ltd. 
FUJIFILM Imaging Systems Co., Ltd.  
FUJIFILM Imaging Protec Co., Ltd. 
FUJIFILM Medical Co., Ltd.  
FUJIFILM Business Expert Corporation
Fuji Xerox Co., Ltd. 
Fuji Xerox domestic sales companies (31 companies) 
Fuji Xerox Information Systems Co., Ltd. 
Fuji Xerox System Service Co., Ltd. 
Fuji Xerox Printing Systems Co., Ltd. 
Fuji Xerox InterField Co., Ltd. 
Fuji Xerox Manufacturing Co., Ltd. 
Fuji Xerox Service Creative Co., Ltd. 
Fuji Xerox Service Link Co., Ltd. 
Fuji Xerox overseas manufacturing companies (5 companies) 
Fuji Xerox Asia Pacific Pte Ltd. 
Fuji Xerox overseas sales companies (16 companies)

  • *1 Privacy Mark: A mark granted by the Japan Information Processing Development Corporation (JIPDEC) to companies in which personal information is handled appropriately.
  • *2 ISMS: Information Security Management System. Certification regarding the overall management framework for information, including personal information
  • *3 For the certified companies of Fuji Xerox Group, please visit the website “Compliance and Risk Management” of Fuji Xerox Co., Ltd.
Initiatives of FUJIFILM Corporation and its Subsidiaries

FUJIFILM Corporation and its subsidiaries created the “Compendium of Information Security Case Studies” (revised in July 2015) focusing on actual information security incidents. The document is available to their employees through the intranet. In addition, we started e-learning programs in FY2014 to help our employees gain an understanding of the “Information Security Regulations” and the “Information Security Guidelines” (which outlines specific activities to be observed by employees). We also conducted a survey on personal information management internally as well as at our external subcontractors. We confirmed the existence of subcontract agreements and the security status of electronic data handled by these subcontractors. 

In September 2019, we provided practical training for risk managers assigned to each division and each Japanese group company of FUJIFILM Corp. regarding information security and personal information protection (twice in total with 120 attendants).

Initiatives of Fuji Xerox Co., Ltd. and its Subsidiaries

As the global environment changes, such as rising sea level by climate change and abnormal weather occurrence, risks concerning natural disasters are increasing.

Based on the damage estimations, We are enhancing and reinforcing the anti-disaster measures as a part of the Business Continuity Plans (BCPs) to further improve the Group response to a wide-area natural disasters in Japan, including preparations for a Tokai-Tonankai-Nankai multiplate earthquake (Nankai megathrust earthquake), Tokyo Metropolitan earthquake, eruption of Mt. Fuji., torrential rain, river floods and rising sea level.

We also implement BCPs and reinforce employee safety measures for natural disasters specific to America, Europe, and Southeast Asia, such as earthquakes, tornados, and wildfires.

Initiatives of FUJIFILM Corporation and its Subsidiaries

In FY2018, FUJIFILM Corporation implemented disaster prevention e-learning for all employees of FUJIFILM Corp. and its domestic group companies for the first time. It also facilitates the stockpile of emergency supplies for employees through collaboration with the Group Cooperatives. FUJIFILM Corp. will continue disaster prevention activities based on the conviction that the safety and security of the lives of employees and their families should lead to the company’s early recovery and business continuity in the event of a disaster.

Initiatives of Fuji Xerox Co., Ltd. and its Subsidiaries

Fuji Xerox Co., Ltd. and its subsidiaries specify September 1 as the “Disaster Preparedness Day” and reinforce disaster prevention activities on that day every year. In FY2018, Fuji Xerox implemented training not only for earthquake disasters but also for wide-area heavy rain incidents which have caused extensive damage recently, to strengthen its capabilities to handle such disasters. The management also attended these training programs.