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Our Code of Conduct

1. Legal compliance and ethical approach
In keeping with the tradition of shinsho*, we are disciplined in maintaining a highly ethical approach and in complying with laws and ordinances, internal regulations and other practices.

*shinsho (literally translated as "gentlemanly business") in Japanese means the operation of a business with honesty, diligence and passion; instilling an individual and a company with pride to fairly interact with society and customers.

(1) Legal compliance
We comply with laws, ordinances, regulations, social standards, business practices and internal rules, and strive to understand and respect the purpose and objectives underlying these principles.

(2) As a pharmaceutical company
As a company engaged in the development, manufacture and sale of pharmaceuticals that foster the wellbeing of people, we work earnestly to respect the sanctity of life and promote a commonsense view of pharmaceuticals.

(3) Proper relationship with government officials and healthcare professionals
Particular care must be taken to maintain a proper relationship with government officials and healthcare professionals. We never engage in dealings such as providing illegal payments to public servants and other parties.

(4) Attitude towards antisocial acts
We exercise constant vigilance to legal and social practices, never ignore unlawful or antisocial acts, always behave in a sensible manner, and reject demands of antisocial influences or groups involved in activities that may threaten the order and safety of civil society.

(5) Separation of business and private affairs
We make a clear separation between an individual's work related activities as an employee and those of an individual's private life, and never permit personal affairs into the workplace. We do not allow the mixing of business and personal affairs such as the use of personal property for company business or the private use of company property without permission.

2. Improvement of operations by rational approaches
We are continuously reviewing what rational steps need to be taken to operate effectively and efficiently and make sustained efforts to improve our operations.

(1) Recognition and improvement
In order to operate efficiently, we endeavor to accurately understand the current situation and through deliberate processes, strive to continuously upgrade the situation identified as requiring improvement.

(2) Elimination of waste; profitability
To achieve appropriate profit levels, we make rational decisions to identify what areas are or are not necessary in our entire operational processes and thereby improve the management of our business.

(3) Company-wide perspective, overall optimization
In a changing business environment, we strive to eliminate sectionalism and pursue ways to maximize operational effectiveness and efficiency from a company-wide perspective.

(4) Long-term perspective
We do not make decisions simply based on immediate, short-term benefits, but take into account long-term factors so that we not only continue to grow steadily but we do not disappoint consumers and business partners.

3. Finding the source of a problem and preventing recurrences
We continuously aim in a proactive manner to identify problems and, if a problem occurs that must be resolved, we promptly identify the source of the problem and implement measures to prevent its recurrence.

(1) Problem solving
We are incessant in our analysis of problems and if a situation arises that is not as it should be, we work to clarify the source of the problem.

(2) Preventing problems
We work continuously to fully analyze any risks and their causes that have the potential to impact our business, and actively implement countermeasures to prevent problems from occurring.

(3) Dealing with a problem
We act promptly and in a responsible manner if a problem occurs that must be resolved; the problem shall be immediately reported to the person in charge and appropriate actions shall be decided.

(4) Preventing reoccurrence
We research the underlying source of a problem that has occurred, look into the causes, and implement measures to prevent the problem from reoccurring.

4. Maintaining and protecting company assets and data
We strive to maintain, protect and effectively use company assets and data comprising our business resources in order to provide information and products that satisfy our customers.

(1) Appropriate asset management and maintenance
We work to manage and maintain both tangible assets, such as company finances, facilities and equipment, and intangible assets, such as intellectual property rights, so that they can be used effectively in our business operations.

(2) Prohibition on conflicts of interest
We never engage in acts that may negatively affect our company or our customers, such as the use of company property for personal or third party gain.

(3) Appropriate handling of confidential information
We recognize the importance of confidential information obtained through the course of our business activities and handle such information securely and appropriately.

(4) Protection of personal information
The personal information of consumers, business partners, employees or executives obtained through our operations is only used for the intended business purpose; we are very thorough in all our measures related to the collection, use, archiving and disposal of such information to prevent leakage of such information to third parties.

5. Consumer focus
We prioritize the view point of consumers in our business activities to contribute to their health and wellbeing.

(1) Recognition of consumer needs
We continuously work to identify needs of consumers in all our corporate activities, from research and development through manufacturing and sales in order to make a contribution to their health and a better quality of life.

(2) Delivery of products and services with safety and quality
We provide products and services, which are safer and better in quality, and we diligently improve our products and services in their safety and quality, to gain consumers' trust and satisfaction.

(3) Providing appropriate information and communications
We provide information to ensure that our products are widely used and appropriately administered. Pharmaceuticals are effective and safe to administer only when they are properly used in accordance with their instructions. We conduct communications activities to ensure that accurate information is appropriately communicated and understood.

6. Fair dealings with customers, business partners
We build and maintain fair and reasonable relationships with customers and business partners in keeping with the tradition of shinsho.

(1) Relationships with customers, business partners
We value the trust in our relationships with customers and business partners, and maintain a contractual relationship on an equal footing in order to foster practical and proper relationships and to conduct business in a fair and transparent manner.

(2) Proper dealings with customers, business partners
We neither discriminate against nor provide special preferences to certain customers and business partners or abuse our dominant bargaining position, and we comply with applicable laws and ordinances and secure contracts and engage in business transactions in an appropriate manner.

7. Creation of an optimal workplace
We respect the human rights, personality, individuality and diversity of our employees, and work to create a safe, non-discriminatory workplace suitable for all employees.

(1) Respect of human rights, prohibition of discrimination
We respect the human rights and individuality of employees and do not tolerate in the workplace any discrimination or misbehavior that could infringe an individual's dignity (harassment). We have set up an operational compliance hotline and other helplines, and request effective use of them to ensure a healthy environment in which to work with colleagues and to resolve the problems of each individual employee.

(2) Promoting a good working environment
We work to promote a good working environment where everyone can work securely, taking into consideration a safe and healthy workplace and the welfare of employees.

(3) Personal fulfillment
We strive to create personal fulfillment for employees in their job roles, providing training programs to improve the knowledge and skills required in their positions, and brushing up their specialized, decision-making, and implementation skills.

(4) Fair evaluation
We assess employees fairly on the basis of their individual abilities and performance results, and work to provide an environment where they can grow and achieve personal fulfillment.

(5) Creating a vibrant workplace
We are making sustained efforts to create a positive workplace that is well organized, vibrant, and fosters information sharing and open communication, and that allows each employee to make optimal use of their abilities in the execution of their job responsibilities.

8. Proper disclosure of information to the stock market
We appropriately disclose information in a timely manner to provide a full and accurate understanding of our company to our shareholders and investors.

(1) Timely information disclosure
We appropriately disclose information that accurately reflects our corporate activities to shareholders, investors, and other stakeholders. If problems arise in our corporate activities which may have an unintended impact on society, we will undertake to investigate the facts and promptly handle the situation in a responsible manner.

(2) Accurate financial reporting
We work incessantly to maintain our system of internal controls and to ensure that financial reports and accounting records accurately reflect our business activities.

(3) Ban on insider trading
We never disclose to third parties information about our company, affiliated companies or business partners before it is made public and never engage in insider trading, including the sale or purchase of shares based on such information.

9. Working in partnership with local communities and keeping harmony with global environments
We play an active role tailored to the regions, communities and environments surrounding us.

(1) Communicating with local communities
We actively participate and collaborate in activities that contribute to healthy regional development and to comfortable and safe living conditions; we emphasize engagement with local communities to foster a sense of mutual understanding.

(2) Preserving and protecting the environment
We recognize that our daily operations impact local communities and global environments and strive to pursue environmentally friendly processes and sustainable environmental technologies necessary for the preservation and protection of the environment based on our "Basic Policies, Action Guideline for the Environment".

(3) International business activities
In order to build trust in our relationships with the people in each country where we engage in our international business activities, we will respect their culture and social practices by adhering to laws and regulations, and attainment of a better understanding of social conditions and beliefs in each country.

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