Regulation of whistle-blowing system

REGULATION OF WHISTLE-BLOWING SYSTEM

Basic Policy on Establishment of the Whistle-blowing System

This regulation stipulates the basic concept and procedures for establishing and operating of the whistle-blowing system that have a function of receiving or dealing with voluntary reports from an employee and an organization, individual outside Canon Vietnam Co., Ltd (hereafter called “Business partner”) which is related to a business activity of Canon Vietnam Co., Ltd (hereafter called “Company”) on an illegal activity, wrongdoing , fraudulent activity or other misconduct (hereafter called “Misconduct”) which is observed in our workplace; business activity of Company. The whistle-blowing system also has a consulting function, which gives employee an advice as to whether certain action is illegal / unethical or not in accordance with laws and regulations, or company rules. This regulation is for the purpose of promoting early detection and correction of the Misconduct and contributing to the reinforcement of compliance management of Company.

1. Designation of a Department/Person That Receive a Whistle-blowing Report from “Employee”, “Business partner”:

The Company shall set up the CVN COMPLIANCE COMMITTEE that receives a Whistleblowing Report from its employee & Business partner. The Whistle-blowing Reports shall mean a voluntary notification of the Misconduct made or are going to be made by management or employee of the company that is observed in workplaces or business activities of Company.

2. Measures for sending the Whistle-blowing Report

- E-mail: whistle_blowing@cvn.com.vn

- Facsimile:024-3881-1284

- Face-to-face interview

※ Only nominal information is accepted (no anonymous information)

3. Scope of Persons, Organizations Who May Submit the Whistle-blowing Report:

All employees and order contract employee, who work for Company and Business partner.

4. Investigation

In the event that a Whistle-blowing Report is submitted to CVN COMPLIANCE COMMITTEE, CVN COMPLIANCE COMMITTEE shall immediately investigate the reported Misconduct in the Whistle-blowing Report and obtain information on whether such Misconduct is real or not, etc. CVN COMPLIANCE COMMITTEE shall not leave the reported Misconduct unsolved.

At least more than 2 members will confirm the report, report to General Director and organize investigation group, who have no concern in the contents of report, if necessarily. The investigation group will exploit interview with employee, Business partner and external service like law firm and make final report to Chairman of Committee.

5. Correction

As a result of the investigation, if Company has found that the Misconduct reported in the
Whistle-blowing Report are real, Company shall immediately take necessary steps to correct
such Misconduct and to prevent similar Misconduct in future.

6. Disciplinary Actions

As a result of the investigation, if Company has found that the Misconduct reported in the
Whistle-blowing Report are real and some of the management/employees of Company have
been involved in such Misconduct intentionally or with gross negligence, such
management/employee shall be subject to disciplinary actions in accordance with the
provisions of the Employment Agreement, other related employment rules of Company, or
applicable laws and regulations.

7. Protection of employees, Business partners who submitted the Whistle – blowing Report:

Company may not discharge, threaten, harass, or in any other manner discriminate against employee, Business partner who submits the Whistle-blowing Report.

All information related to Whistle – blowing Report shall be treated as confidential information of Company. Such confidential information shall not be disclosed or leaked to any third parties, except using for investigation purposes of Company; reporting to competent agencies of Vietnam (in case Misconduct related to criminal responsibilities) and using for propaganda purpose of Company under anonymous form.

8. Reports

Whistle-blowing Reports, which Company actually received for certain period, submits to
Compliance Administration Office of Canon Inc. four times a year (in January, April, July and
October).

Hanoi, 1st April 2018

Approved by:

 

 

Niimura Minoru

General Director