Fujifilm Group

Global Healthcare Code of ConductHealthcare has become one of the world’s most important industries as people
pay increasing attention to health and wellness. Fujifilm Group, as acomprehensive healthcare company, offers a wide range of products andservices in the fields of prevention, diagnosis and treatment.
In all of our healthcare activities, we strive to promote the health and safety ofpatients and support our customers in accordance with applicable laws andregulations, anchored by our open, fair and clear corporate culture, along thefollowing fundamental principles:

Healthcare Business Mission Statement

1.

We treat the health and safety of patients as the first priority in all of ouractivities.

2.

We respect patients and their rights of self-determination, dignity, privacy
and human rights.

3.

We conduct research and development activities with the highest level ofquality, safety and integrity.

4.

We provide appropriate and clear information regarding our products
and services, and keep accurate books and records.

5.

We ensure appropriateness and transparency in our interactions withhealthcare professionals.

Fujifilm Group Global Healthcare Code of Conduct
General Provisions
1. Subject of Application
This Fujifilm Group Global Healthcare Code of Conduct (“Code of Conduct”) falls under
the Fujifilm Group Charter for Corporate Behavior and Fujifilm Group Code of Conduct,
and applies to all executives and all employees of FUJIFILM Holdings Corporation and allof its group companies (each a “Company” or "Fujifilm Group"), who are involved inresearch, development, application for approval, manufacturing, sales, provision or supportof medical devices, pharmaceuticals, in vitro diagnostics, regenerative medicine products,
life science products or healthcare-related services (collectively, the “HealthcareBusiness”). Moreover, we take appropriate steps to request related parties, including
contractors, dispatched employees, sales representatives, and business partners
associated with the provision, sales or support of healthcare products or services of each
Company engaged in the Healthcare Business to respect the standards and requirementsin this Code of Conduct.
2. Procedures for Establishment and Revision
The establishment and revision of this Code of Conduct shall be decided by the ESG
Committee of FUJIFILM Holdings Corporation. This Code of Conduct and any revisions
shall apply to each Company at the time of notification from FUJIFILM Holdings
Corporation.
3. Sanctions and Penalties against Violation
In the event that an executive or employee who is involved in the Healthcare Businessviolates this Code of Conduct, that person may be subject to disciplinary action or otherconsequences in accordance with the applicable Company regulations. In the event thatthe violation causes damage to the Company, the Company may take legal measures,
including seeking compensation for damages.
4. Reporting of Violations and Inappropriate Practices
In cases when a resolution cannot be reached even after consulting a superior, or when
consulting a superior is difficult, employees and executives can consult directly with theCompany’s compliance department, the helpline of each Company or the regional helpline,
without going through a superior. For more information regarding the helpline, pleaserefer to the websites and posters provided by FUJIFILM Holdings Corporation, regional
headquarters and the Company.

1. Relationships with Patients
We treat the health and safety of patients and participants in our research activities as thefirst priority in each process of the Healthcare Business, and we are fully committed torespecting patients’ and research participants’ rights of self-determination, dignity, andprivacy, as well as their human rights.
(1) Research and Development
We conduct the research and development of our healthcare products and services withthe highest level of quality, safety, and integrity, and comply with applicable laws, ethicalpolicies, 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, wehandle animals with due consideration to animal ethics.
(2) 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. Inaddition, 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.
(3) Disclosure of Test Results
When disclosing the results of tests and research activities, we ensure that the informationis accurate, up-to-date, unbiased and not misleading, regardless of the outcome.
(4) 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 ourhealthcare products and services.
(5) Privacy Protection
We take necessary measures to protect and secure the privacy and confidentiality ofpersonal data. We take extra care when handling any types of sensitive personal datathat require special protection.

(6) 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 thequality and safety of our healthcare products and services and provide such products andservices consistently. In addition, we make every effort to prevent adverse events byaccurately and comprehensibly displaying and describing information about the use ofhealthcare products and services. When it is necessary, we take corrective measures andpromptly report events to the relevant internal divisions, affiliates and regulatory authorities.
(7) 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 therelevant regulatory authorities as required.
(8) Safety Information
We continue to evaluate our healthcare products and services by conducting post-salesafety 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 anynecessary actions.
(9) Collaboration with Patient Organizations
When engaging with patient organizations, we shall maintain a strong sense of ethics andrespect the independence of the patient organizations. Our engagements with patientorganizations 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.

2. Relationships with Healthcare Professionals
In the Healthcare Business, we are required to maintain appropriate and transparent
relationships with healthcare professionals and medical institutions. We provide themwith appropriate information and respond ethically and in good faith avoiding any acts thathave an inappropriate impact.
(1) Accurate Disclosure of Information
We provide healthcare professionals with appropriate and accurate information on ourhealthcare products and services.

(2) 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 promotionallabeling, including appropriate usage of our products and services as approved by therequired approving agencies. We comply with all regulations applicable to marketing andadvertising of our healthcare products and services and strive to ensure clear and truthful
information is provided in our marketing and advertising materials.
(3) Compliance with Anti-corruption Regulations
When we interact with both domestic and foreign healthcare professionals, we comply withthe anti-corruption regulations and competition laws in each country and region, including
those that prohibit inappropriate solicitation, including the offer of or the provision ofeconomic benefit, for the purpose of influencing decisions regarding the purchase or useof healthcare products and services, as well as the Company’s internal policies andguidelines.
(4) Ensuring Transparency
We pay attention to any conflicts of interest when providing support and benefits tohealthcare professionals. We comply with the disclosure and transparency regulations incountries and regions seeking to record and report such information, as well as thosedisclosure regulations that are deemed as industry standards, and make appropriate
publications in accordance with applicable laws and internal regulations.
(5) Outsourcing, Joint Research and Development
We conduct appropriate selection when outsourcing necessary duties, such as
consultations, to healthcare professionals and when conducting joint research anddevelopment with healthcare professionals. In addition, we put the contents of theactivities in writing, determine in advance the fees due for services in light of the contentsof 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 orrequire 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.
(6) Product Evaluations and Tests, Feedbacks and Technical Support
We engage with appropriate healthcare professionals and enter into written agreementswith those healthcare professionals prior to conducting product evaluations, tests andfeedback for healthcare products and services. We comply with applicable laws andregulations when providing technical support for healthcare products and services in theclinical front and as part of training for healthcare professionals.

(7) Gifts and Hospitality
We comply with anti-corruption and anti-bribery laws and our internal regulations related tothe provision of gifts and hospitality to healthcare professionals. In particular, we ensurethat gifts and hospitality are limited in nature so that healthcare professionals are notinappropriately influenced when making decisions regarding opportunities to collaborate
with or support the Company, or purchase healthcare products and services from theCompany.
(8) Donations, Grants and Sponsoring
We donate and provide grants to medical institutions and external organizations only inaccordance with applicable laws and regulations and in an appropriate and fair way. Suchdecisions are taken independently of any past or future sales activities. In addition, weensure that the purpose and content of any funding is recorded in writing.

3. Relationships with Business Partners
In all business activities, we strive to ensure that relationships with our business partners
are in line with our open, fair and clear corporate culture, and we do not conduct any act
that may raise any doubt regarding unfair relationships.
(1) Fair Trading
We comply with applicable laws, industry standards and related internal regulations wheninteracting with business partners, for example, when providing discounts or rebates forhealthcare products and services.
(2) Marketing Activities
In all our marketing and promotion activities, we adhere to applicable laws, industry
standards and internal regulations.
(3) Suppliers, Distributors and Other Third Parties
When we engage with third parties, including suppliers and distributors, we endeavor to actwith the highest ethical and business standards and hold them to the same standards towhich we hold ourselves, including quality requirements. We expect our suppliers,
distributors and other business partners to conduct business in a manner that is incompliance with applicable laws and internal regulations and expect our suppliers anddistributors to maintain these standards down their supply chain. We consider compliancewith our standards to be essential when choosing new business partners or continuing ourrelationships with existing ones.

(4) 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 fornuclear, biological or chemical weapons or other improper activity. We expect ourbusiness partners to strictly comply with these same commitments.

4. Relationships with Public Officials, Governmental
Agencies, Regulatory Authorities and Politicians
We strive to create appropriate and transparent relationships with public officials,
governmental agencies and regulatory authorities. We ensure that any funds provided topoliticians, political parties, political organizations or other parties are made in accordancewith applicable laws and internal regulations.
(1) 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 whomsuch public officials belong.
(2) Approvals
We obtain necessary approvals from the regulatory authorities and other approval agencies
before we manufacture and sell healthcare products and provide services. We complywith applicable laws and internal regulations, and maintain the accuracy andappropriateness of the materials and data used when applying for approval. We do nottolerate any falsification or manipulation of materials and data, and fully supervise
contractors commissioned by the Company.
Release date: July 1, 2020
Revised date: January 22, 2024