Guidance for Employee Code of Conduct Ethical Behavior

Guidance forEthical Behavior: Employee Code of Conduct

We care about our employees, we care about our business partners, we care about our end-users.

2 Guidance for Ethical Behavior



Message from Kazuto Ogawa, President and CEO 5

Introduction: Our Code 6 • What it Means for You 8

• Canon San-Ji Spirit 9

• Using the Code 10

• Canon Americas Audit and Compliance Committee 10

Your Responsibilities 11• You and the Government 12

• You and Canon 13

• You and Other Canon Employees 15

• You and Our Customers 17

• You and Our Competitors 18

• You and Our Suppliers, Contractors,Partners, and Affiliates 19

• You and the Community 20

Asking Questions and Raising Concerns 21

• Getting the Right Answer 22

• Reporting Violations 22

• Canon Americas Business IntegrityHotline 22

• Disciplinary/Corrective Action 23

• Confidentiality and Protectionfrom Retaliation 23

Canon’s Corporate Values 24

Contents


Message from Kazuto “Kevin” Ogawa, President and CEO At Canon, we take great pride in our reputation as a company that provides the highest quality goods and services while maintaining a strong commitment to society and the environment. One reason for this reputation is our dedication to conducting business with the utmost level of integrity. The development of Canon’s standing as an ethical company did not occur by chance, nor did it develop overnight. It is the result of our continuous effort to conduct business in an honest, fair, ethical and accountable manner; an embodiment of Canon’s “San-Ji Spirit”.

Our values and standards are the basis of our success. Maintaining the highest level of business integrity at Canon is dependent upon the actions of us all. Canon employees need to be certain that they are always conducting business in accordance with applicable laws, regulations, and policies, as well as in a manner consistent with the Canon corporate values of communication, fairness, integrity and mutual respect.

The Guidance for Ethical Behavior: Employee Code of Conduct (Code) helps us discern right from wrong when conducting business at Canon, presenting an ethical and behavioral framework to guide us in dealing with the difficult challenges and choices we often face. It must serve as the cornerstone of our business ethic, guiding our actions and shaping our attitudes in the workplace as we represent Canon, both around the office and around the world. Please take a few moments to review the guidance and consider how it applies to you, your staff and your business unit.

I would like to thank you for your continued dedication to our core values, to following this Code and to fulfilling our purpose.

Kazuto “Kevin” Ogawa President and CEO, Canon U.S.A., Inc.

Guidance for Ethical Behavior

INTRODUCTION

Our Code

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Our Code applies to all of usThe Guidance for Ethical Behavior: Employee Code of Conduct (Code) forms the basis of Canon’s Compliance Program. It is designed to help us fulfill our professional responsibilities. We each make decisions in the course of our jobs that have economic, legal and ethical implications for ourselves and for Canon, and we are each responsible for making the right choices. All Canon employees, including officers and directors, and employees of Canon subsidiaries and affiliates, must follow our Code. This includes all business units in government regulated and non-government regulated industries. We also expect all of our suppliers, consultants, agents and others doing business with Canon or acting on our behalf to hold themselves to equally high standards. Simply abiding by the Code is NOT enough. We must also keep in mind our responsibilities towards each other and our communities, customers, suppliers and other partners.

Our Employee Code is a global CodeThe Canon family of companies create a global presence, with employees that service customers all over the world. We comply with the laws of the U.S. and other countries where we do business. The standards and guidance outlined below applies to all Canon Americas employees. While we embrace diversity and respect cultural differences, if a local custom or business practice violates our Code, we must follow the Code. If something permitted or required by our Code violates local law, we must follow the law. In those rare circumstances where it appears that local law may conflict with U.S. law, contact the Legal Division or the Compliance and Privacy Office for guidance.

Refer to the Code and ask questionsPlease read the Code and refer to it often. It isn’t something you read one time and forget about. It’s your guide for making good business decisions of which we can all be proud. Familiarize yourself with the principles, the laws and policies and procedures that apply to you in your role at Canon. You must also take all required ethics and compliance courses in a thoughtful and timely manner. Of course, our Code and policies can’t address every possible situation, so it is up to you to use good judgment and seek help whenever you have questions or aren’t sure about the right course of action. Talk to your manager or contact Human Resources, the Legal Division or the Compliance and Privacy Office, if you still have questions.


What it Means for You

Always obey the lawand Canon’s policies But that’s just the minimum. Strive to live up to our values and ethical principles as well.

Never compromise on integrity

Turn down business if you can’t do it legally and ethically. Don’t let the pressure to succeed make you do things you know are wrong.

Just say, “No”

It’s not only OK to refuse to follow directions that you know are illegal or unethical, it’s required. No Canon leader has the authority to make you violate the law, our Code, policies or ethical principles.

Make good choices

Use our values and ethical principles as decision filters. When you aren’t sure of the right course, ask for help.

Select business partners carefully

Choose those who share our values and high standards for legal and ethical business practices. Don’t let anyone damage our reputation and our brand by acting illegally or unethically in Canon’s name.

Speak up

If you suspect someone –a team member, leader, business partner or customer – is acting illegally or unethically, help us maintain our values and culture by reporting it immediately.

Similarly, should you ever have concerns about your own behavior, as it relates to Canon’s policies and values, discuss them with your manager, or contact Human Resources, the Legal Division, or the Compliance and Privacy Office. Admitting mistakes and being proactive in preventing or correcting them is the responsible thing to do.


Ji-hatsu (Self-Motivation): Take the initiative and be proactive in everything you do.

Ji-chi (Self-Management): Conduct yourself responsibly and be accountable for all your actions.

Ji-kaku (Self-Awareness): Understand the situation you find yourself in and your role in that situation.

Our commitment under the “San-Ji” Spirit:

> We must observe and act in accordance with all applicable laws and rules.

> We must always conduct ourselves in a fair, honest, and ethical manner.

Canon San-Ji Spirit

If you are ever unsure of what to do, ask yourself these questions. Would your actions:

When in doubt, consult with your manager, Human Resources, the Legal Division, the Compliance and

Privacy Office, or call the Business Integrity Hotline at 1-(866)-9COMPLY or 1-866-926-6759.

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violate any laws or rules? leave you feeling guilty? disappoint your family, friends, or coworkers? embarrass you if reported publicly in the news?

cause trouble for the community? harm the Canon Brand?

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Using the Code The Canon Corporate Values—Communication, Fairness, Integrity, Mutual Respect—should act as a compass for every employee. If each of us demonstrates the Values consistently, together we will build and maintain an ethical culture in our individual departments and throughout the company.

Canon’s Code provides practical guidance for putting the Canon values into practice, including in some areas where there are important company or legal restrictions. We view it as the foundation of the Canon family ethical business practices worldwide. Within this guide, you’ll also see references to additional Canon policies that provide more specific direction. No single document can cover all circumstances or anticipate every situation. If you face a situation that’s not explicitly covered by the Code or another policy, apply the general Code philosophy and ask yourself which ethical standards apply. If you still have questions, consult with your manager, Human Resources, the Legal Division, the Compliance and Privacy Office, or call the Business Integrity Hotline at 1-(866)- 9COMPLY or 1-866-926-6759.

If you witness or learn about a Code violation or perceive something you believe to be a violation, you must report it. Doing this helps us live up to our values. We’ll seeconcerns in more detail in a later section.

Canon Americas Audit and Compliance CommitteeCanon U.S.A., Inc. has established an Audit and Compliance Committee. This group:

Monitors compliance with the law, government regulations, business policies and practices for the Canon Americas Group

Provides guidance regarding business practice issues Oversees the system for raising questions and reporting concerns, ensuring questions are answered and concerns are investigated and addressed as appropriate

The Audit and Compliance Committee is also responsible for making sure that the business of the Canon Americas companies is conducted in accordance with the behavioral principles outlined in this guide.

Audit and Compliance Committee Kazuto Ogawa, President and Chief Executive Officer, Canon U.S.A., Inc. Tatsuro Kano, Executive Vice President and General Manager, Imaging Technologies & Communications Group, Canon U.S.A., Inc. Seymour Liebman, Executive Vice President, Chief Administrative

Officer, and General Counsel, Canon U.S.A., Inc.

Scott Millar Senior Vice President and General Manager, Human Resources Division and Audit, Ethics, and Business Consultation Division, Canon U.S.A. Inc.

Yoshinori Shimono, Senior Vice President and General Manager, Finance and Accounting Division, Chief Financial Officer and Treasurer, Canon U.S.A., Inc. Shinichi Yoshida, Executive Vice President and General Manager, Business Information Communications Group, Canon U.S.A., Inc., Chairman and Chief Executive Officer, Canon Solutions America, Inc.

Please note, subsidiary companies may have their own compliance committee to cover local issues.

As you go through this Code, you’ll

encounter some of these terms.

Harassment: Creation of an unpleasant

or hostile situation, especially by

uninvited and unwelcomed verbal or

physical conduct.

Discrimination:: Prejudiced or

prejudicial outlook, action, or

treatment.

Disparage: To discredit, denigrate, or

belittle someone.

Felony: A grave crime that usually

involves an imposition of a more

serious punishment, as opposed to

a misdemeanor, or lesser violation of

an applicable law or regulation.

Integrity: Firm adherence to a

code of especially moral or

ethical values.


2 Your Responsibilities

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The Guidance for Ethical Behavior: Employee Code of Conduct

is like the constitution of a country, establishing standards and principles that must guide our conduct.

Beyond the guidance in this Code, the Corporate Compliance Program and the Canon Americas Policies provide additional details as to how the principles in the Code are to be implemented. If you ever face a situation where there are conflicting or inconsistent policies, look to the Corporate Compliance Program and the Canon Americas Policies for guidance. If you still have questions, consult with your manager, Human Resources, the Legal Division, the Compliance and Privacy Office, or call the Business Integrity Hotline at 1-(866)- 9COMPLY or 1-866-926-6759.

The laws, rules and regulations affecting our businesses change from time to time, so the compliance materials and policies are periodically reviewed and updated. Make sure you review the Code, as well as the other Compliance Program policies and Canon Americas policies, procedures and guidelines to make sure that you are familiar with current expectations.

You and the GovernmentCanon complies with the laws of the United States and the laws of the countries in which a Canon company does business. You must always follow the applicable laws, regulations, rules, and regulatory orders of these jurisdictions.

This means:

You have a responsibility to know and follow the laws and Canon policies that apply in the regions or jurisdictions where you work. This is specifically important if you are an employee of a highly regulated industry, such as Healthcare and Life Sciences.

You must know these well enough to watch for potential dangers and risks. Don’t be afraid to raise concerns or ask questions if something doesn’t seem right.

You can be held personally responsible for violations of the law or Canon policy. In some cases, civil or criminal penalties may apply.

Canon can be held liable for the actions of its employees. Always consider whether your actions are ethical and in keeping with our policies and internal standards.

Related Policies

Government ContractsGovernment Inquiries and Interviews of EmployeesGovernment Relations - Dealing with Government Employees Anti-Boycott Law and RegulationForeign Corrupt Practices ActU.S. Law Compliance for Foreign Affiliates/AgentsSecurity Trade Control

ONE IMPORTANT RESTRICTION

IN YOUR WORK WITH THE

GOVERNMENT: You are prohibited

from bribing government officials,

whether on your own or through

an agent or other third party. This

is true even if other companies

are paying bribes to obtain or to

facilitate business.

Remember, Canon prohibits bribery

of any kind. This applies in every

country where a Canon company

does business, regardless of local

common practices within the country.

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Canon employees should devote their full energies to their work. Employees who engage in other business activities during non–working hours should be sure that those activities do not interfere with or conflict with their work at Canon.

Help protect Canon’s assets from theft and misuse. This includes everything from properly reporting expenses to protecting access to buildings and networks. Use Canon assets only for their appropriate business purposes. Do not use them or give them to someone else to use for non-Canon business.

Use electronic communication technology responsibly, including e-mail, the Internet, and social media.

Avoid excessive personal use of e-mail and the Internet at work. To the extent permitted by law, because these use Canon networks, you should not expect that your communications are private. Canon reserves the right to review e-mails or Internet use as necessary.

E-mail sent from your Canon e-mail account should beprofessional and should never contain objectionablecontent.

Use social media appropriately and responsibly. If you participate in social media, know and follow Canon guidelines for mentioning Canon. This also applies to certain aspects of your personal use of social media sites.

Avoid representing yourself, in public or in writing, as

an agent of Canon, unless you have been specifically authorized to speak on the company’s behalf.

There are a number of situations where an employee’s personal interests conflict, actually or in appearance, with Canon’s interests or the employee’s loyalty to Canon. Such situations can interfere with your ability to make judgments solely in Canon’s best interests. Always avoid situations that could result in even the appearance of a conflict. If you have a question about a situation you’re involved in, consult the Conflict of Interest Policy and then ask your supervisor, the Legal Division or the Compliance and Privacy office for guidance.

Employees should avoid any outside financial interest that might influence decisions or actions of the company such as:

A personal or family interest in an enterprise that has business relations with Canon.

An investment in another business that competes directly with Canon.

It’s important to protect our confidential information. This includes all information, whether scientific, technical, business, financial, or otherwise, concerning Canon, that we treat as confidential or is not generally available in the marketplace. This information must not be divulged, except in accordance with established Canon policy and applicable laws.

You and Canon

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Every Canon employee has an obligation to enhance and protect Canon’s assets. That means

you must be vigilant to protect Canon’s physical property, as well as intangible assets, such

use Company computers and networks appropriately.

as intellectual property, confidential information, financial records and trade secrets. You must also


All information that is disclosed to the public must

be accurate. Disclosure of such information must only be made by Canon personnel, who are authorized to do so. Fraud (including wrongful or criminal deception) and intentional misstatements of any kind are strictly prohibited.

Confidential information must not be used for any employee’s personal gain. You also can’t allow a third party to use or obtain such information. This is true regardless of the information or the manner in which the information is obtained.

Never trade stocks or securities based on information about Canon’s business—or any other business— that is not publicly known.

Never discuss non-public information about Canon’s business with family, friends or other outsiders, so that they may trade.

Always report transactions honestly and truthfully, in keeping with applicable laws, regulations, and accounting best practices. Canon is required by law to keep books and records that accurately and fairly reflect the business and results of operations.

Never falsely report a transaction or certify records, vouchers, or bills that you know are incorrect. If you become aware of false or misleading information in our accounting or other records, report it immediately.

If we are subject to an internal or external audit, you should cooperate fully.

Know and follow all Canon contracting practices and financial controls.

If you are convicted of a felony, you must report it to Human Resources. This is true whether or not the offense was related to the provisions in the Code.

Related policies

Conflict of Interest Policy Social Media Policy Corporate Disclosure Policy Insider Trading Policy Intellectual Property of Others

Drugs and Alcohol Policy Compliance Program Discipline Compliance Program Education and Certification Reporting and Investigation Violations Employee Retirement Income Security Act Background Verification of Employees Exit Interviews Accurate Books and Records Legal Documents - Receipt by Employees

Company Property - Use by Employees Records Information Management (RIM) Program

Q & AQ: I was on the official Canon Facebook page, and I noticed that someone had posted comments that were very critical of Canon. Several of their statements were factually incorrect. Can I write a post that explains why they’re wrong?

A: No. Unless you are officially authorized to speak for Canon (most employees are not), please do not respond to negative comments on Facebook or anywhere else. If you believe something damaging or inaccurate about Canon is being said, you can report it to the Social Media Team at [email protected] ,but do not provide your own response. You also shouldn’t comment on social media about our competitors or any of their activities, or reveal information about Canon’s business activities.

Protection of Trade Secrets

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Every Canon employee has a right to a work environment free of harassment or discrimination because of sex, sexual orientation, race, creed, national origin, religion, age, disability, veteran status. To meet this commitment, we must all treat each other with courtesy, fairness and respect for the dignity of the other person.

Canon policy prohibits sexual harassment and other types of harassment, as well as discrimination. Canon’s policy, without regard to the existence of such laws, is that discrimination or harassment against any person by another will not be tolerated. We recruit, hire, promote, and discipline without regard to protected characteristics like age, race, religion, ethnicity, or national background. Additionally, the company will provide reasonable accommodation to an employee with a disability, so that the employee can fulfill his/her job duties.

Employees have a right to work in a safe environment. It is Canon’s policy to take steps to help ensure that our workplace is safe and that working conditions comply with all applicable laws and regulations. Every employee is responsible for helping to ensure the safety of the Canon workplace through personal action. These actions include having Canon employee identification with you at all times, wearing appropriate protective equipment, avoiding actions that may be unsafe and taking training related to workplace safety. If you become aware of unsafe conditions, report them immediately to General Affairs or other appropriate division.

Violence in the workplace is absolutely prohibited. If someone behaves in a threatening manner, or if you believe that someone is planning to take violent actions, report it immediately to Security or your local Human Resources Representative.

Security, data protection and information privacy are central to our culture and operations. Locking our vehicles, alarming our facilities and encrypting sensitive information are just a few ways we maintain security.

You and Other Canon EmployeesEvery Canon employee deserves honest and respectful treatment. We are each expected

to contribute to a positive and professional environment.

Personal Characteristics

At Canon, we welcome the variety

of viewpoints that our employees

contribute. When hiring or making any

other employment-related decisions,

we consider the skills and talents

that each candidate brings. Certain

personal characteristics are irrelevant to

our decisions, including:

> race, ethnicity, color, or national origin

> religion

> age

> sex

> disability

> marital status

> veteran status

> sexual orientation

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Security extends beyond physically protecting information. It includes the protection of our personal health and safety at work by:

Providing a safe and healthy work environment for ourselves and our coworkers.

Protecting the physical security of our facilities and their contents.

Maintaining the security of customer information and personal information about employees in our possession.

Keeping confidential and proprietary company information out of the wrong hands.

Following all relevant laws and policies regarding the protection of personal information.

Promptly reporting any incident that might impact Canon’s security or your own health and safety, such as the loss of your Canon identification badge, laptop, Blackberry/smartphone, or any other electronic mobile communication or storage device.

Related policies

Whistle-Blowers PolicyNon-Discrimination Workplace PolicySexual Harassment and Other Prohibited HarassmentOccupational Safety and HealthCompliance Program Implementation and Interpretation

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When dealing with customers, you represent not only Canon, but all other Canon employees as well. Canon and its employees have provided services for many years and have built up brand loyalty over that time. Brand loyalty is one of our most important assets, and Canon employees must act to preserve and enhance Canon’s positive reputation.

You must not misrepresent Canon products or services. Where silence about a fact could be misleading to a customer, you must clearly disclose important or material information. Stretching or hiding the truth is unethical and is not good business.

If you collect, store, work with, or manage personal information about Canon’s customers or business partners, you are responsible for safeguarding this information in keeping with Canon requirements. Failure to follow our policies related to protecting information can lead to disciplinary action and sometimes legal action, both civil lawsuits and criminal prosecutions, against the company and the individuals responsible for the failure to comply with Canon policies and the law.

Know and follow Canon’s policy on appropriate gifts, entertainment, and hospitality. Canon competes on the merits of its products and services and does not offer customers or potential customers anything of value, such as gifts or entertainment, as an attempt to gain an unfair business advantage.

We have a responsibility to safeguard any private or confidential information that is entrusted to us. This includes confidential information that belongs to suppliers and other business partners, as well as private or personal data about our customers.

Related policies

You and Our Customers If your job puts you in contact with customers or potential customers, it is critical for you

to remember that to these people, you are Canon.

Conflict of Interest PolicyIntellectual Property of OthersInterference with Business RelationshipsGovernment ContractsGovernment Inquiries and Interviews of EmployeesGovernment Relations - Dealing with Government Employees Antitrust Law and Competitive Practices

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Canon must and will comply with all applicable antitrust laws and requirements relating to unfair competition. Failure to do so can lead to serious legal consequences, both for the company and the individual involved, including potential criminal liability.

Competing fairly means competing based on the value of the services we offer to our customers. It is the high quality of what Canon offers that succeeds in the marketplace—not collusion with competitors, misuse of competitive information, or misrepresentation of our products or our competitors’ products.

Never make false, misleading, or disparaging remarks about individuals or organizations or their products and services.

If someone offers you non-public or sensitive information about a competitor, don’t accept it. Never actively seek out confidential information or trade secrets that belong to a competitor.

Always protect sensitive and proprietary Canon information from unauthorized disclosure outside of the company—including to Canon affiliates where such disclosure would unfairly disadvantage competitors.

Avoid discussions with competitors that involve competitive issues, such as trade secrets, price, or issues that affect price, like changes in the cost of raw materials. Because the antitrust and trade regulation laws are complex, it’s best not to engage in direct or indirect discussions with actual or potential competitors about competitive issues without prior legal review. This is true even when the situation involves a joint venture, trade association meeting, or other legitimate activity.

The Corporate Compliance Program and the Canon Americas Policies provide details as to how employees should deal with particular situations. Whenever in doubt about the legality of any action, employees should consult with the Canon Legal Division before taking that action.

Related policies

Antitrust Law and Competitive Practices Interference with Business Relationships

You and Our Competitors Q & AQ: I recently participated in an industry benchmarking exercise. May I contact a member of that working group to ask about further clarification on a point she raised about raw material costs?

A: You should speak with the Legal Division before contacting anyone at a competing company to collect information. In many cases, competitors are not allowed by law to share information about competitive topics. While benchmarking exercises tend to be tightly controlled to ensure adherence to the law, you might not be able to ensure the same for your casual conversation. For this reason, almost any conversation with a competitor can be problematic, if not dangerous. So before you contact this person, seek advice from the Legal Division.

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require high standards of ethical conduct in all relationships and interactions with our competitors.

Canon competes vigorously, effectively, and fairly, in compliance with all laws and regulations. We


At Canon, we purchase supplies based on quality, service, and price, following applicable legal requirements.

Never ask for or accept gifts, entertainment, hospitality or anything of value that could compromise or appear to compromise your judgment in a business relationship. Never promise a business advantage in exchange for a personal benefit.

Under no circumstances should any Canon employee attempt to coerce suppliers into purchasing our products.

Distributors and affiliates should be treated fairly compared to one another. Never share information unevenly, or take actions that could be considered favoritism toward a particular company.

Consultants and agents retained by Canon must follow the guidance provided in this Code and all applicable Corporate Legal and Compliance Policies in the course of their work on behalf of Canon. This includes our prohibitions against bribery and corruption.

It is part of your responsibility, as a Canon employee, to make sure that our agents behave appropriately. Consultants and agents shall not be retained or otherwise permitted to do anything illegal or improper.

Remember, we can be held liable for any actions an agent, contractor, consultant or other third party takes on our behalf. If the law or Canon policy prevents us from a certain action, we are also prohibited from hiring a third party to do it.

Pay attention to export restrictions, especially to prohibited countries, individuals, and organizations. Never export to an individual or country in violation of our policies or legal prohibitions.

For more details on the types of actions that constitute unfair treatment of suppliers, contractors, partners, and affiliates, employees should refer to the Corporate Compliance Program and the Canon Americas Policies.

Related policies:

Conflict of Interest Foreign Corrupt Practices Act (FCPA) Antitrust Law and Competitive Practices U.S. Law Compliance for Foreign Affiliates / Agents Procurement Security Trade Control

Q & AQ: I need to hire a supplier, and my brother-in-law is the primary salesperson at a company that has submitted a bid. Would it be appropriate for me to interact with him in this way, or should I remove myself from the decision making process?

A: You’re right to recognize that it could cause problems if you have a family connection to one of the companies you are evaluating. You should disclose this relationship. We will then evaluate the situation and decide on the course of action that best protects both you and Canon.

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Our suppliers, contractors, partners, and affiliates make significant contributions to our success. To create an environment in which they have an incentive to work with Canon, they must be confident that they will be treated fairly.

You and Our Suppliers, Contractors, Partners, and Affiliates


Preserving and protecting the air, water, and land is one of the most important obligations Canon has to our world and to our community. Every Canon employee must assist in these efforts. Within Canon, we support recycling.

We must all know and follow applicable environmental laws and Canon practices and procedures. You should be particularly aware of any environmental reporting requirements specific to your role. If you have questions or concerns on the environmental impact of our operations, you should consult the relevant Corporate Compliance Program and the Canon Americas Policies.

Canon encourages employees to be good citizens and to fully participate in the political process. In return, employees who participate in partisan political activities must make every effort to ensure that they do not create the impression that they speak or act on behalf of Canon.

Never make a political contribution on Canon’s behalf. U.S. state and federal law, like the laws and regulations in most countries, prohibit Canon from contributing to political candidates, political parties, or party officials, except through the means of approved vehicles such as Political Action Committees.

Never use your position within Canon to solicit political contributions from other employees. You may make your own contributions, but these will not be reimbursed by Canon.

You may always support political parties and candidates, but you should do so on your own time and with your own resources. If you are visiting or doing business on Canon’s behalf in a country other than your home country, you should avoid participating in any political activities associated with that country.

Related policies

Environmental Laws and Regulations Policy Conflict of Interest

You and the Community

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Canon is committed to being a responsible corporate citizen in the worldwide communities where we

operate. We think about the footprint our products and activities have on the environment.


Asking Questions and Raising Concerns

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Canon Americas Business Integrity Hotline

Getting the Right AnswerThere may be times when you review the Code, Corporate Compliance Program and the Canon Americas Policies and still have questions about the right course of action in a given situation. Not every situation will be addressed in these documents, and it’s important to get the right advice if you’re unsure what to do or how the Code applies.

Start by reaching out to your manager. If you don’t find the answers you need there, consult another compliance resource. These include:

other members of senior management Human Resources the Legal Division the Compliance and Privacy Office the Business Integrity Hotline at 1-(866)-9COMPLY or 1-866-926-6759

You will not be penalized for asking questions in good faith. The laws and regulations we have to follow are complex and not always obvious. We expect to receive questions, which is why there are resources to help.

Reporting Violations All Canon employees are required to properly report all known or suspected violations of the law or company policies and procedures. The Canon Business Integrity Hotline is a resource for you to report your concerns. In addition to being able to report concerns by phone, you can also report concerns securely via the internet. Canon has contracted with a well-recognized company to provide this service. The people staffing the hotline are not affiliated with Canon, which allows employees the ability to file anonymous reports. You may report matters anonymously and be assured that those reports will be treated confidentially, to the extent possible. Concerns reported to the Hotline are investigated, and feedback is available to the reporter.

The Canon Business Integrity Hotline is available to you 24 hours a day, seven days a week. The Business Integrity Hotline phone number is: 1-(866)-9COMPLY (1-866-926-6759). Reports can be made in English, French, Spanish or Portuguese. You may access the Hotline website directly at https://secure.ethicspoint.com/lrn/en/report_custom.asp?clientid=16295 or by accessing the link to the Business Integrity Program / Hotline located on your local company intranet homepage.

EVERY CANON EMPLOYEE is responsible for demonstrating high ethical standards in their daily work,

which includes following the principles and guidelines outlined in the Code, Corporate Compliance

Program and the Canon Americas Policies. Managers especially have a responsibility to consistently

demonstrate these standards, and to hire, retain, and promote employees who make ethical conduct

a priority.Phone: 1-866-9COMPLY or (1-866-926-6759)

Business Integrity Hotline Website: https://secure.ethicspoint.com/lrn/en/

report_custom.asp?clientid=16295

E-mail:[email protected]

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In addition to the Canon Business Integrity Hotline, you can rely on your supervisors and managers, as well as your Human Resource representative, to proactively work with you to resolve issues and concerns. Your supervisors and managers are accountable for creating a supportive work environment and positive associate experience, which also starts with you.

Related Policies:

Whistle-Blowers Policy Reporting and Investigating Violations

Disciplinary/Corrective ActionCanon reserves the right to take disciplinary/corrective action in response to Code violations, up to and including termination of employment. Disciplinary action may also be taken against managers or officers who knew about the improper conduct and either encouraged it or allowed it to continue. Canon may seek restitution from any employee for losses resulting from that employee’s violations.

Canon has a responsibility to report all alleged criminal violations to the proper authorities. We may refer matters to law enforcement authorities for possible investigation and prosecution. Corrective action provides us the opportunity to transform inappropriate behavior and, instead, promote an ethical culture for all employees.

from RetaliationCanon will not tolerate retaliation against an employee, who in good faith, seeks advice, raises a concern, or reports actual or suspected misconduct. It is absolutely forbidden for any employee to punish or conduct reprisals against another employee who has conscientiously reported perceived or actual violations in good faith. Canon encourages its employees to make good faith reports of both possible and actual violations.

To the maximum extent possible, we will maintain the confidentiality of those individuals who report known or suspected violations of the law or of the Code. This includes both the confidentiality of the person making the report, as well as, the person about whom the report is made. To the extent that you make a report, are involved in any investigations, or learn about any investigations, please honor this commitment to confidentiality.

Participation in InvestigationsYou are expected to cooperate in any investigation including, but not limited to, providing any documentation or other information that you may have related to the issue or concern under review.

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I recognize and reward people based on their performance.

I listen to employees and give them a voice in decisions that a�ect them.

I always enforce company standards.

I recognize and understand the di�erences among people.

I believe everyone has something to bring to the table.

I listen to the concerns of others.

I don’t make excuses and I hold myself accountable for my actions.

I do the right thing, even when no one is looking.

I know my strengths and weaknesses, adapt to change and grow accordingly.

FAIRNESS MUTUAL RESPECT INTEGRITYCOMMUNICATION

I proactively seek out both positive and negative information regarding my business.

I have honest conversations and share knowledge with others.

I say what I mean and I mean what I say.

Canon’s Corporate Values

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