Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity

Environment

Society/Labor

GovernanceCorporate Citizenship Activities

Materiality 10 Thorough Compliance ...................................................................................... 131
Compliance .......................................................................................................................................................................... 133

Materiality 11 Strengthening Corporate Governance .................................. 137
Corporate Governance ........................................................................................................................................... 139

Materiality 12 Strengthening Risk Management .................................................. 141
Risk Management ....................................................................................................................................................... 143
Risk Management for Information Assets and Cybersecurity
145

Governance

Code of Conduct training
participation rate in thedomestic group95%

Tax risk assessment

Conducted
quarterly on a
global basis

Significant information
security incidents in the past
3 years0
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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity

Environment＞ Thorough Compliance

Materiality10

Society/Labor

Governance＞ Strengthening Corporate GovernanceCorporate Citizenship Activities＞ Strengthening Risk Management

Thorough ComplianceReason for Prioritization【Activity Policies】

The global social situation facing companies continues to change rapidly. No matter how the times may change, we will continue
to fulfill our social responsibilities by thoroughly complying with corporate ethics as well as laws and regulations.
Cases where even one misconduct has caused a loss of credibility that has endangered a companyʼs existence are too numerous
to mention. Therefore, in addition to preventing misconduct before they occur, it is important to strengthen compliance systems
in a broad sense in accordance with international guidelines and directives, while simultaneously carrying out appropriate risk
evaluation and training.

■ Nikon Code of Conduct■ Nikon Anti-Bribery Policy【Organizations】■ Compliance Committee

Commitment
The Nikon Code of Conduct constitutes the fundamental rules of the Group based on its Corporate Philosophy ofTrustworthiness and Creativity. All employees working for the Nikon Group must be firmly aware of the importance ofcompliance based on the Nikon Code of Conduct in their daily business activities. Furthermore they must always maintaina high ethical standard and act sincerely and appropriately when making judgments and taking action. The Nikon Code of
Conduct also represents the foundation on which we will strengthen global governance and respond to the expectations of
the international community. We aim to become a company that meets the expectations of society by consistently educatingand establishing our Code of Conduct, and by fostering a culture of sincere behavior, including compliance with laws andregulations, to prevent compliance violations and maintain the trust of the community.
In order to realize our Corporate Philosophy of Trustworthiness and Creativity and contribute to the sustainable developmentof society, I will continue to pursue thorough compliance through the practice of the Nikon Code of Conduct.

Takumi Odajima
Representative Director and Executive Vice President
General Manager of Group Governance & Administration Division

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity

Environment＞ Thorough Compliance● Fiscal Year 2022 Materiality Goals and Results
Goals for Fiscal Year 2030

What Nikon Needs to Do

Implement awareness-raising initiatives andeducation regarding to laws, regulations andethicsGovernance＞ Strengthening Corporate GovernanceCorporate Citizenship Activities＞ Strengthening Risk Management

Self-evaluation ○ : Achieved △ : Measures started but not yet achieved
Related
SDGs

Scope

Goals for Fiscal Year 2022

Nikon Group in
Achieve a read rate of at least 90% for the Code of Conduct
Japan

Becoming a company that is trusted by society,by ensuring conformity with the Nikon Code of
Conduct and by acting with integrity, including
compliance with laws and regulations

Society/Labor

Nikon Group
16

Provide education to Nikon divisions and Group companies related
to competition law

Nikon Group in Respond to the revision of laws and regulations related to theJapanwhistleblower system in Japan

Results for Fiscal Year 2022

Self-Evaluation

Conducted training on the Code of Conduct at Nikon Group companies in Japan,
achieving a 95% participation rate〇

Provided competition law training at Nikon and Group sales companies〇

In response to the revised Whistleblower Protection Act of June 2022, the company added
an external contact point specifically for cases related to heads of organizations and otherexecutives and revised the Code of Conduct Hotline Operating Regulations.
Conducted training on the revised Whistleblower Protection Act and ensured that all
employees were aware of and familiarized with the law

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity

Environment＞ Thorough ComplianceSociety/Labor

Governance＞ Strengthening Corporate GovernanceCorporate Citizenship Activities＞ Strengthening Risk Management

Compliance
Nikon Code of Conduct

SystemThe Nikon Code of Conduct is a specific set of standards thateach and every employee should understand in depth andutilize to implement the concept of compliance. In the Codeof Conduct booklet, we include messages from the president,
company principles, explanations of terms, and Q&As topromote understanding of the Nikon Code of Conduct
among all employees, both domestically and internationally.
The Code of Conduct and explanatory materials have beentranslated into 16 languages and posted on the portal site
so that all employees can refer to it whenever necessary.
Furthermore, the content of the Code of Conduct andexplanatory materials is reviewed regularly.
Additionally, to ensure thorough compliance with theCode of Conduct across the Nikon Group, the head ofeach department at Nikon and above, and the presidentof each Group company make a pledge each year to takeresponsibility for compliance with the code of conduct in theorganizations of which they are in charge.

The Nikon Group has established a Compliance Committee
under the Risk Management Committee to strengthen
governance and risk management. The committee ischaired by the General Manager of the Group Governanceand Administration Division, who is also a Representative
Director of Nikon. It deliberates and decides on measuresrelated to priority compliance promotion issues, such as antibribery. The Compliance Section of the Legal and Intellectual
Property Division, which spearheads compliance promotion
activities, and the Internal Control Promotion Section of theGroup Governance & Administration Division, both serve as
secretariats of the committee.
The Nikon Group promotes compliance according to thesystem outlined in the diagram. In Japan, the Compliance
Section undertakes compliance promotion activities in eachof Nikonʼs departments and at Group companies, by holding
liaison meetings of compliance coordinators, etc. Outside● Compliance Promotion Structure Diagram

Nikon Code of Conduct
https://www.jp.nikon.com/company/sustainability/
management/codeofconduct/(As of April 1. 2023)
Compliance Committee【Secretariat】
Compliance Section, Legal &Intellectual Property DivisionInternal Control Promotion Section, Group
Governance & Administration Division

Outside Japan

Compliance Section, Legal &Intellectual Property Division

Regional Headquarters

Liaison Meeting of Compliance Coordinators

Liaison Meeting ofCompliance Coordinators

Compliancecoordinators ineach of Nikon's
departments

Compliancecoordinators at Group
companies outside Japan

Compliancecoordinators at Group
companies in Japan

Japan, we cooperate with each group company, led by theregional headquarters, to address the risk of violations oflocal laws and regulations. Furthermore, we are promoting
initiatives in line with the culture, customs, as well as the local
laws and regulations of each country and region.

Code of Conduct Hotline(Reporting and Consulting System)
The Nikon Group has included provisions regarding areporting and consulting system in the Nikon Code of
Conduct and has established such systems at all Group
companies in and outside Japan in order to respond toreports of violations or potential violations of the Nikon Codeof Conduct.
In Japan, the Code of Conduct Hotline has been established
as a unified Reporting and Consultation System for the
Nikon Group in Japan (including non-consolidated Group
companies). The Code of Conducts Hotline has both aninternal contact point and an external contact point set
up with a specialized vendor. The external contact point isavailable every day of the year except during the year-end
and New Year holidays. In Japan, in accordance with theenforcement of the revised Whistleblower Protection Act
on June 1, 2022, an external contact point for cases related
to heads of organizations and other executives has been
established at a law firm handling whistleblower cases in
FY2022, and a full-time member of the Audit & Supervisory
Board Committee is handling these cases.
Outside Japan, as a general rule, each Group company
has established its own internal contact point. In addition,
contact points handled by external specialist firms have been
set up and are being operated in Europe, the Americas andAsia (excluding Republic of Korea). The external contact point

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity

Environment＞ Thorough Compliance● Diagram of the Reporting and Consulting System in Japan

Governance＞ Strengthening Corporate GovernanceCorporate Citizenship Activities＞ Strengthening Risk Management

Major Initiatives

Cases involving the head of an organization or other executives

Findings/ResponseGroup in Japan:

ReportReporting/Consulting
Notification of findings/
countermeasures

ReportCooperation
as needed

Compliance Committee/Chairman

ReportInternal Contact Point

Reporting/Consulting

External
Contact Point

Directors
Permanent
employees
Part-time
employees
Temporary
personnel
Dispatched workers
Retirees (within 1
year)

ReportAudit and Supervisory
Committee

From the Nikon

ReportFull-time Audit
and Supervisory
Committee Members

Informer

Reporting/Consulting

External Contact
Point(Law Firm)

is available 24 hours a day, 7 days a week, 365 days a year, in
local languages.
Reporting can be done anonymously. When violations or
potential violations of the Code of Conduct are reported,
we promptly investigate the facts and take steps to resolve
the matter and prevent recurrence. For each case received
through the system, information is gathered from thereporter and persons relevant to the matter in order tounderstand the issue objectively. We then work together
with relevant departments to resolve the case and follow
up as necessary. We treat each case with the utmost care byrespecting human rights, which includes keeping the matterin strict confidence, protecting privacy, ensuring anonymity,
and preventing any negative treatment as a result of using
the system.
In fiscal year 2022, the Nikon Group as a whole received 77
reports. The pie chart in the Reporting and Consultation
System Utilization Results section shows the number ofreports and consultations in fiscal year 2022 by category.
In addition, to ensure that this reporting and consultation
system is functioning properly, the secretariat operating
the Code of Conduct Hotline reports regularly to theMembers Compliance Committee on the development
and operational status of the system, which is based on theregulations. The Committee is also informed of the statusof overseas operations.
The Nikon Group makes employees aware of this systemthrough a booklet on the Nikon Code of Conduct, which isaccessible to all employees, and relevant training programs.

Society/Labor

Related departments● Use of Reporting and Consulting System in Fiscal Year2022 (Number of Consultations)
Information management: 2 cases
Bribery: 0 cases

Other: 4 cases

Improper use of company
assets and expenses:
6 cases
Procurement:
0 cases
Quality: 2 cases
Environmental,
health, and safety:
7 cases

Employment, labor,
and work environment:
56 cases

Total number of consultations in Japan and overseas. In reports received up until last year,
the number of consultations in Japan was reported as the number of cases investigated andaddressed after the consultation service was utilized. However, in our latest report, we havestandardized definitions with our overseas locations, and are reporting the number of times theconsultation service was utilized.

Compliance Training for Directors andEmployees of the Nikon GroupThe Nikon Group aims to instill an awareness of theconcept of compliance in every person at the Nikon Group,from our top management to each and every employee.
At the December 2022 meeting of the Compliance
Committee, a compliance seminar was conducted by aspecialist lawyer for 23 committee members, including
Nikon's full-time directors. Seminar topics included
compliance issues and information management specificto the COVID-19 pandemic.
For employees, we provide classroom training and e-learning.
In fiscal year 2022, the Nikon Group in Japan, after noticing
a decline in the level of dissemination of the Code in theprevious year's awareness survey, prepared Code of Conduct
training materials and implemented an e-learning program in
March 2023. In addition, compliance coordinator from each
Nikon department and domestic Group company regularly
provided employees of each division and company withtraining on such topics as unconscious bias, anti-bribery, andthe Reporting and Consulting system.
At Group companies outside Japan, the Regional Headquarters
take the lead in continuously implementing activities to train andraise awareness of the Code of Conduct. In fiscal year 2022, theRegional Headquarters provided training on the prevention ofharassment and discrimination, anti-bribery, and prevention ofcompetition law violations as part of the activities.
In addition to this, in our quarterly sustainability newsletterto all Nikon Group employees, we explain the Nikon Group's
approach to compliance by featuring compliance-related
news that is attracting attention around the world.

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity

Environment＞ Thorough Compliance

Global Awareness Survey (Monitoring)
The Nikon Group conducts monitoring through an awarenesssurvey given to its employees at Group companies in andoutside Japan every one or two years. The survey enables the
Nikon Group to assess the degree of compliance awareness,level of employees' confidence in the reporting andconsulting system, and the current status of Code of Conduct
training, and reflect the results in improvements made to the
Nikon Groupʼs promotional activities.
In fiscal year 2022, we conducted an awareness survey for the
Nikon Group in and outside Japan with 17,704 employees
responding (response rate of 91.5%). The response rateincreased slightly from the previous 2020 Global Awareness
Survey (90.2%). This year, we have also made new efforts
to understand the reality of employees by creating newquestions that allow for global comparisons of work
enthusiasm and engagement.
The results of the survey and requests for improvement wererelayed back to each Nikon department and Nikon Group
company, and they are working to make improvements
based on these results.
Through such efforts, the Nikon Group has established a
PDCA cycle for promoting compliance in all regions where
we conduct business activities.

Prevention of Bribery
The Nikon Group has established the Nikon Anti-Bribery
Policy with the approval of the Executive Committee toreconfirm our commitment to the prevention of bribery
both internally and externally. To ensure compliance with
the Nikon Anti-Bribery Policy, led by the Compliance
Section, regional headquarters outside Japan have each
formulated Anti-Bribery Guidelines. These guidelines
reflect regional characteristics and summarize businessapproaches, precautions and operational procedures, etc.,
for entertainment, gifts and donations that are necessary tocomply with the policy.
Specifically, we are taking steps to ensure full compliancewith written application and approval procedures for
expenditures related to public officials, etc. As a general rule,
we have banned facilitation payments.
In addition, at the start of transactions with third parties,
such as intermediaries, Nikon makes the Nikon Anti-Bribery
Policy known to all parties, and in principle, the contract must
include a clause regarding the prohibition of bribery. We
have a system in place to confirm matters using a prescribedchecklist in situations deemed to be high risk. In fiscal year
2022, we began working on the revision of the Anti-Bribery
Guidelines to reflect the latest social trends.
The Compliance Section and regional headquarters outside
Japan are working continuously to provide training andmake procedures regarding anti-bribery known to all. EachGroup company also checks the operation of the Anti-Bribery
Guidelines using a self-assessment checklist at the end of
every fiscal year, and the results are used to improve practices
in the subsequent fiscal year.
In fiscal year 2022, compliance coordinator from each
Nikon department and domestic Group company

Society/Labor

Governance＞ Strengthening Corporate GovernanceCorporate Citizenship Activities＞ Strengthening Risk Management

provided training on anti-bribery with employees in eachdepartment and company.
We also conducted anti-bribery training at overseas Group
companies in the Americas, Europe, South Korea, and HongKong. The Nikon Group has not experienced any violations ofanti-bribery laws and regulations in the current fiscal year.
Nikon Anti-Bribery Policy
https://www.nikon.com/company/sustainability/
governance/compliance/anti-bribery_policy.pdf

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Contents/Editorial Policy

Message from the President

Nikon Group Profile

Nikon’s Sustainability

Business Activity

Environment＞ Thorough CompliancePrevention ofCompetition Law Violations
As set out in the Free Competition and Fair Business Dealings
section of the Nikon Code of Conduct, the Nikon Groupʼsfundamental position is to carry out fair competition andengage in business deals that comply with the competition
laws of each country.
In recent years, the international community has increased its
focus on compliance with competition laws, requiring more
stringent efforts to comply with these laws. Through thistraining, which the Nikon Group provides on an annual basis,
we strive to promote and raise awareness of legal complianceacross the entire Nikon Group, as well as prevent competition
law violations.

Training on Competition Law

Society/Labor

Governance＞ Strengthening Corporate GovernanceCorporate Citizenship Activities＞ Strengthening Risk Management

Responding to Misconduct
In the event of violations of employment rules or the Nikon
Code of Conduct, the Nikon Group will take strict disciplinary
action in accordance with internal regulations afterinvestigating all related matters.
In the fiscal year 2022, there were a total of seven significant
disciplinary cases based on misconduct, etc., in the Nikon
Group. The parties involved (a total of eight persons), andthe management and supervisory personnel (a total of eight
persons), were reprimanded. The main reasons for resulting
in disciplinary actions above were involved theft, leakage
of information, and illegal activities conducted outside ofworking hours at Group companies outside of Japan.
Nikon continually provides education for employees throughthe newsletter, e-learning and other means in order toprevent the recurrence of misconduct.

In order to provide competition law training that is inline with the laws and regulations of each country where
we operate, the Nikon Group conducts training globally.
Specifically, Nikon's Compliance Section takes the lead role incompetition law training for the entire group, and the sameoffice is in charge of training for the Nikon Group in Japan.
Outside Japan, the legal department of each business
operations site and each Group company prepares acurriculum and provides training with the assistance of local
law firms as necessary.
In the fiscal year 2022, the Nikon Group in Japan continued
to implement e-learning programs, while outside Japan,
training was provided based on the risks associated with eachcompanyʼs business activities.

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