Canon

COMPANY REGULATION OF WHISTLE BLOWING SYSTEM

Chapter 1 General Provisions

Article 1: Purpose

The purpose of this regulation is to realize compliance management by discovering and resolving illegal acts, violation acts of corporate ethics and compliance and so on at early stage. Then we shall establish a system and stipulate its rules to detect and correct the illegal or unethical acts (hereinafter referred to as "illegal acts") itself or the employee who conducts illegal acts in our workplaces and so on, by receiving reports from our employees and business partners regarding illegal acts found in our workplaces and so on (hereinafter "whistleblowing system”).

Article 2: Jurisdiction

This regulation is drafted by the General Manager (herein after GM) of Internal Audit Office and approved by General Director (herein after GD).

Chapter 2 Operation of Whistleblowing System

Article 3: Persons who can use Whistleblowing System

All our employees and employees of our business partners, stakeholders are eligible to use whistleblowing system.

Article 4: Definition of Whistleblowing

Whistleblowing means that a whistleblower, as defined in Article 3, discovers and reports on his/her own initiative, any illegal acts that has been or is presumed to have been committed by our employee, either at our workplace or at our business partners.

Article 5: Contact Window for Whistleblowing

The contact window for whistle-blowing is Internal Audit Office, which accepts whistleblowing via dedicated e-mail address (whistle_blowing@cvn.com.vn), in writing (internal mail or letter), or interview.

Article 6: Targets of Whistleblowing System

1. The whistleblower system shall cover the following acts.
1) Actions suspected to be illegal.
2) Actions suspected of violating “Canon Code of Conduct”..
3) Actions suspected of violating “Company Working Regulation”, other company regulations and rules.
4) Actions suspected of violating corporate ethics and compliance.
5) Illegal transactions or unfair acts such as collusion, cartels, against subcontractors, insider trading and so on.
6) Misrepresentation on the website, including false acts.
7) Misappropriation and personal use of company assets and improper accounting treatment of reception fee and so on.
8) Unauthorized information management such as unauthorized removal or leakage of confidential information.
9) Collusion with public officials and business partners.
10) Harassment.

2. The following matters shall not be covered and even if a report is received, it will not be investigated or dealt with by whistleblowing system.
1) Complaints about personnel transfers and evaluations.
2) Complaints against superiors, colleagues and subordinates.
3) Purpose of harming others, such as personal grudges and slander.

Article 7: Whistleblowing Investigation Group and Investigation Report

1. Whistleblowing will be handled according to the attached "Whistleblowing system correspondence flow".

2. Internal Audit Office shall organize an investigation group at least two members, and immediately initiate an investigation to confirm the facts regarding the whistleblower’s report.

3. GM of Internal audit Office may, if necessary, request the cooperation of the whistleblower or third parties and add them to the investigation group.

4. The investigation group may conduct investigations using external services such as law firms.

5. As soon as the investigation results are finalized, GM of Internal Audit Office will report to GD and provide feedback to the whistleblower to the extent possible.

6. Internal Audit Office may terminate the investigation or refuse to provide feedback to the whistleblower if the whistleblower is unreachable or uncooperative, or for any other reason that hinders the investigation from proceeding

Article 8: Corrective Action

As a result of the investigation, when the contents of the illegal acts reported by the whistleblower are found to be true, consulting with the GD and relevant parties, GM of Internal Audit Office will immediately take necessary measures and implement corrective measures and measures to prevent recurrence of the illegal acts.

Article 9: Disciplinary Action

1. As a result of the investigation, when it is found that the illegal acts by the whistleblower is true and that our employee is involved in such illegal acts intentionally or through gross negligence, such employee may be subject to action in accordance with “Company Working Regulation”.

Article 10: Prohibition of Disadvantageous Treatment (Retaliation)

1. The company shall not treat whistleblowers disadvantageously (retaliation) by dismissal or other methods.

2. The company shall take appropriate measures to prevent the whistleblower's working environment from deteriorating. If the whistleblower is threatened, harassed, or any other disadvantageous act, the company may subject the person who committed the such acts to disciplinary action in accordance with “Company Working Regulation”.

Article 11: Confidentiality of Whistleblowing

1. All information related to whistleblowing shall be treated as company confidential information. Such confidential information shall not be disclosed or leaked to third parties except when used for investigation purposes or when requested to be presented by a competent administrative agency or a law enforcement agency (in the case of illegal acts related to criminal liability).

2. Information that can be used identify the whistleblower may not be disclosed to third parties.

3. When using for educational purposes for employees, process it so that the whistleblower cannot be guessed.

4. Internal Audit Office shall manage reports of whistleblowing and investigation materials in folders or in lockable cabinets accessible only to GD and person in charge of whistleblowing system.

Article 12: Reporting to the Head Office

Whistleblowing received by Internal Audit Office shall be reported in accordance with head office guidelines. (Compliance Office in Canon Inc. Global Legal Administration Center).

Chapter 3 Supplementing Provisions

Article 13: Enforcement

This regulation is enforced from the date of GD approval signature.

Article 14: Enactment & Revision Date

Version 01: Enacted : 11th Nov, 2013.
Version 02: Rivised : 10th Sep, 2022.

Article 15: Attached

Appendix “Whistleblowing system correspondence flow”