Compliance and Risk Management

The Fujifilm Group defines “compliance” as “not only to pursue the law but to behave correctly within the framework of common sense and ethics.” Moreover, we think the promotion of compliance and the management of risk are two sides of the coin, as the lack of compliance awareness among employees would lead to grow the possible corporate risks. For this reason, the following four steps have been implemented in the PDCA (Plan-Do-Check-Act) cycle in the drive to increase awareness of compliance.

Promotion Structure

The Fujifilm Group appoints officers in charge of compliance and risk management at each of its business corporations and group companies, and implements a variety of measures to penetrate the spirit of an “open, fair and clear” corporate culture throughout the Group. Status on implementation of these measures is reported regularly from each organization to the ESG Committee of FUJIFILM Holdings, and from the ESG committee to the Board of Directors. The Board of Directors is responsible for supervising compliance and risk management for the entire Group. The Board also provides direction and advice on the report from the ESG Committee to assure the effectiveness of the processes.

Fujifilm Group Compliance and Risk Management System
[Figure]Fujifilm Group Compliance and Risk Management System

Compliance Promotion Policy

We have formulated the Fujifilm Group Charter for Corporate Behavior and Code of Conduct as the basic policies of the corporate activities. With these policies, we strive to ensure our activities to be carried out in compliance with laws and social ethics, as well as to communicate the priority of compliance in business operations to all employees of the Fujifilm Group through  Compliance Statement.

Risk Management Promotion Policy

Under the risk management regulations of Fujifilm Group, we identify issues for risk prevention and take action in the event of a risk incident.

To strengthen our risk prevention activities, especially in normal circumstances, we implement the following process every year on a global scale, covering all companies controlled by FUJIFILM Holdings, to identify the risks at each company and develop action plans to address them.

Risk Extraction and Process for Establishing an Action Plan
[Figure]Risk Extraction and Process for Establishing an Action Plan
Priority risks in FY2020

Please refer to the Yuka Shoken Hokokusho (Securities Report) for risk issues not listed below.

Risk item Reason for selection Countermeasures
Information security Rise in security risks for confidential data for growing areas such as regenerative medicine and an increase in services handling customer data
  • Improvements to internal rules and risk management systems
  • Comprehensive implementation of a range of compliance, information security and risk management training
Personal information protection Importance of exhaustive protection against data leaks, which can lead to significant loss of credibility, because of the large number of businesses handling massive volumes of personal data
Natural disasters & infectious diseases
  • Spread of COVID-19
  • Water-related damage from typhoons and rainstorms
Compliance of healthcare business (Securing ethics and transparency) In the healthcare business, higher ethical conduct and transparency are requested by the regulatory authorities in each country. Meeting social requirements as well as compliance with laws and regulations are necessary.
Fraud and misconduct Although incidents are on the decline, stronger governance and continuous training are necessary.
Harassment Impact of a power harassment occurrence is growing as the Power Harassment Prevention Act (as commonly called) took effect on June 1, 2020, attracting great social interest.
Response to crisis

Any crisis that takes place in a Group company is handled by the Compliance and Risk Management promotion structure and in accordance with the procedures set out in our risk management regulations. When found, it is reported to each business company and ESG Division of FUJIFILM Holdings, and at the same time addressed swiftly to prevent further propagation of the risk.

Each business company supervises the execution of recurrence prevention measures at the Group company in question and takes exhaustive action to prevent any recurrence through group-wide dissemination and application of the measures throughout the Group.

Serving as Secretariat, the ESG Division of FUJIFILM Holdings reports incidents received through our business companies to the ESG Committee and at the same time takes action to strengthen and promote risk management for the entire Group, based on the information received.

In the event of a serious incident, reports to the ESG Committee do not only include a summary of the incident, but also detailed information. We monitor the effectiveness of risk management in the Group through such information reports from the ESG Division to the Directors and Auditors in every quarter.

Milestones in Compliance and Risk Management

Since 1997, the Fujifilm Group has been committed to the establishment and enhancement of compliance and risk management frameworks at each group company. After introducing a holding company system in 2006, we have been actively implementing initiatives for both domestic and overseas sites at the entire group level.

Initiatives to Raise Employees’ Awareness and Monitoring


  • Distribution of the revised Fujifilm Group Charter for Corporate Behavior and Code of Conduct (Fujifilm Group)
  • Implementation of employee education on the revised Fujifilm Group Charter for Corporate Behavior and Code of Conduct at a global level (Fujifilm Group)
  • Implementation of the Harassment Awareness Survey for domestic employees (Fujifilm Group)
  • Implementation of safety checks (by raising disaster prevention awareness and confirming the response status) covering domestic division heads, site managers, and employees (FUJIFILM Business Innovation and its subsidiaries)
  • Implementation of compliance awareness-raising activities (through risk extraction by division heads and monitoring by the head office) (FUJIFILM Business Innovation and its subsidiaries)

Establishment of Organizations, Frameworks, and Systems

  • Establishment of the ESG Division (independently from the CSR Group in the Corporate Planning Division) (FUJIFILM Holdings)
  • Renamed the CSR Committee to the ESG Committee (Fujifilm Group)
  • Renamed the CSR Division to the ESG Division (FUJIFILM)
  • Implementation of a web system for domestic group companies to report risk incidents (Risk Incident Reporting System) and commencement of its operation (FUJIFILM and its subsidiaries)

Enforcement of Charters, Codes, and Regulations

  • Revision of the Fujifilm Group Charter for Corporate Behavior and Code of Conduct (Fujifilm Group)