Compliance

Compliance Initiatives

At Taisho Pharmaceutical, our mission, as stated in our management philosophy, is to contribute to society by creating and providing excellent pharmaceuticals, health-related products, information, and services that satisfy consumers who seek health and beauty, in ways that are supported by society. We cherish the founding spirit of "Shinsho^*1 corporate activities," and we strive to conduct our business with sincerity and dedication.

All employees are committed to understanding this philosophy correctly and practicing it in their respective roles. As a company, we are fully dedicated to compliance.

Compliance Structure

As part of our efforts to solidify our compliance initiatives at the company and all domestic and overseas subsidiaries, we are having all executives assist the compliance officer and inform employees about compliance in all companies. We also created the Internal Affairs Department as a dedicated department.
The department heads and group managers are in charge of monitoring, education, and information activities for the sake of thoroughly ensuring compliance at departments and in groups.

Developing Compliance Guidelines

Taisho Pharmaceutical has so far formulated the Taisho Pharmaceutical Group’s Code of Conduct, which serves as a standard for making decision about activities to fulfill our corporate mission as well as basic guidelines for actions at various workplaces, and the Declaration of Corporate Conduct, which contains items to be observed when considering changes in society and when executives and all other employees are doing business. These have also been announced both inside and outside the company.

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.

(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.

(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.

(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.

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

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.

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.

Declaration of Corporate Conduct

In keeping with our long-held tradition of shinsho*, we abide with laws, ordinances, regulations, social standards and business practices; are disciplined in maintaining a highly ethical approach; and pursue our business in accordance with the general principles outlined below.

*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 consumers.

1. We will continue to remain honest and sincere with and strive to gain the trust of the consumers of Taisho products and services.

2. We handle all information gathered in the course of our business with the utmost care and take all possible measures to ensure the protection of personal information, customer data and confidential information.

3. We insert appropriate language in our business transactions and take a fair approach in the course of our dealings with business partners and customers to foster a sense of co-existence and co-prosperity.

4. We respect the human rights, personality, individuality and diversity of each of our employees; establish an appropriate evaluation system and strive to create a healthy and safe workplace, which employees find rewarding.

5. We comply with capital market rules; disclose accurate information in a fair and timely manner to and maintain healthy working relationships with shareholders and investors.

6. We compete in a fair, transparent and open manner and work as a "good corporate citizen" by engaging in an open dialogue with members of society.

7. We reject demands from antisocial influences or groups involved in activities that may threaten the order and safety of civil society.

8. We recognize environmental problems to be an issue shared by humanity and recognize that business activities have a major impact on the environment; we therefore work proactively in a voluntary fashion to pursue environmentally friendly business practices.

9. We respect the unique cultures and practices of each country where we operate our international business by adherence to international laws and applicable regulations, and manage our business to contribute to the development of each country.

10. All executives at Taisho Pharmaceutical, from the most senior levels down, are aware of their personal responsibility to implement this Declaration of Corporate Conduct; they will set an example for others to follow, and will work to ensure that this Declaration is fully understood by Taisho employees and Group companies.

1. We will continue to remain honest and sincere with and strive to gain the trust of the consumers of Taisho products and services.

5. We comply with capital market rules; disclose accurate information in a fair and timely manner to and maintain healthy working relationships with shareholders and investors.

6. We compete in a fair, transparent and open manner and work as a "good corporate citizen" by engaging in an open dialogue with members of society.

7. We reject demands from antisocial influences or groups involved in activities that may threaten the order and safety of civil society.

Further, we have seen an increasing ratio of non-Japanese employees because of our expanding business base through M&A and other means in Indonesia, Vietnam, Malaysia, and elsewhere in Southeast Asia as well as France, so now the majority of our employees are non-Japanese. Amid such developments, we believe it is important for each new employee to value and correctly understand our management principles, which is why we are making the TAISHO WAY.
While there are growing expectations for business activity expansion, there is also a greater need for responsible action in the countries and regions where we are active. Different countries and regions not only have different languages but also religions, societies, institutions, and values, so we need to respect the cultural diversity and change their respective unique attributes into strengths. As such, as part of our efforts to build a stronger management foundation that can continue to grow and develop even amid international conflict, we have formulated the Global Compliance Guideline as action guidelines for all employees of the corporate group.
All of these are made not only in Japanese but also the local language of the overseas subsidiaries, to be distributed either as booklets or through intranets. By creating an environment where our employees can read them at any time, we aim to conduct our activities with an awareness that is shared by all employees, be they in Japan or abroad.

Compliance Education

We hold annual workshops for all employees to deepen their understanding of compliance and understand that it is their own issue to address so that their practices reflect the importance of compliance. Since FY2020, a year dominated by the COVID-19 pandemic, we have established an environment for online training and added to our intranet a video about training which provides advice about the revision and enforcement of laws. Additionally, in Japan, compliance workshops are held every year as part of basic training that is attended by all employees.
We also conduct repeated training sessions, both online and in person, for our overseas subsidiaries on essential legal requirements, such as bribery prevention laws, competition laws, and information security.

In addition to such training, we provide training using the TAISHO WAY and the Global Compliance Guideline to ensure that everyone learns and understands all aspects of compliance, with the aim of sustainable growth for the Taisho Pharmaceutical Group.

Compliance with Laws and Social Standards in Each Country

We will comply with laws, ordinances, regulations, social standards, business practices and internal rules, and clarify our commitment to understand and respect the purpose and objectives underlying these principles in our Global Compliance Guideline, making these known to all employees.

Compliance with Social Standards and Commitment to Corruption Prevention

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.
We continuously collect information concerning the safety of our products in accordance with the relevant laws and regulations in each country and appropriately report the findings to the pertinent authorities as required.
Particular care is taken to maintain a proper relationship with government officials and medical professionals. We never engage in dealings such as providing illegal payments to the public servants, foreign civil servants or other parties of any country.
We exercise constant vigilance to legal and social practices, never ignore unlawful or antisocial acts, always behave in a sensible manner, and reject the demands from antisocial influences or groups involved in activities that may threaten the order and safety of civil society.

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.
We continuously collect information concerning the safety of our products in accordance with the relevant laws and regulations in each country and appropriately report the findings to the pertinent authorities as required.
Particular care is taken to maintain a proper relationship with government officials and medical professionals. We never engage in dealings such as providing illegal payments to the public servants, foreign civil servants or other parties of any country.
We exercise constant vigilance to legal and social practices, never ignore unlawful or antisocial acts, always behave in a sensible manner, and reject the demands from antisocial influences or groups involved in activities that may threaten the order and safety of civil society.

Prevention of Bribery

We do not provide special preferences to certain customers and business partners or abuse our dominant bargaining position, and we comply with applicable laws and regulations and secure contracts and engage in business transactions in an appropriate manner. We prohibit any business transaction deemed to be collusion with a customer or business partner.

With regard to bribery, we thoroughly prohibit our employees in Japan and abroad from providing valuables or treatment that lead to inappropriate relations or may give the wrong impression, acting in other ways that confer advantages, and using their position or relationships to request customers and partners to provide valuables, treatment, and other advantages.

Observing anti-monopoly and national competition laws (relations with other companies in the industry)

We are always committed to sincere, fair, and legal business, so we completely prohibit cartel activities and bid-rigging that are prohibited anti-monopoly and national competition laws or any actions that may violate the same laws. We are also sustaining our competitiveness as a company by appropriately managing our immaterial properties such as patent rights, trademark rights, and know-how on pharmaceutical development technology. We also prohibit any acts that violate the intellectual property rights of other companies.

Information Integrity and Protection

We recognized the importance of the confidential information that we acquire through our business activities, so we manage them strictly and appropriately. Internal sharing of confidential information is only done among employees with a real need for that information. Where such information needs to be disclosed to a third party, the necessary procedures are followed, such as concluding a non-disclosure agreement with that party according to internal regulations, and we confirm that this disclosure does not violate any laws or agreements. Employees who have resigned are also prohibited from sharing confidential information that they learned during their employment. Personal information about consumers, employees, and partners that was acquired in the line of work may only be used for relevant work purposes, while meticulous care is taken with the process of information gathering, use, storage, and disposal to ensure strict management for the prevention of leaks to third parties. Personal information is stored with thorough safety management to avoid damage and improper access. Moreover, when outsourcing work that may require storage of customers' personal information, we select a partner that can handle that information appropriately, conclude an agreement to ensure its appropriate handling, and provide them with necessary and suitable supervision for the safe management of that information. Some countries have strict regulations on transferring personal information abroad. We always make sure there is no issue with sharing the information, even when it is between group companies.

Internal Reporting Hotlines

Based on the Company’s Internal Reporting Regulations, we have a range of corporate resources where you can direct inquiries about behavior that violates laws, ethics, and internal regulations, including the Compliance Management Section Hotline, the Harassment Hotline, an external hotline known as the External Attorney Hotline. We are planning to strengthen our internal reporting system by unifying our internal reporting hotlines for overseas subsidiaries as well as increasing employees' awareness of their existence. Further, these internal reporting hotlines are open widely, not just to employees of the Taisho Pharmaceutical Group but also to contract, part-time, and temporary employees. The privacy of persons making inquiries is protected and all involved staff members have a duty of confidentiality in accordance with the Whistleblower Protection Act and our internal regulations in the form of the Company’s Internal Reporting Regulations.

Questionnaires

We conduct questionnaires to check that overseas subsidiary employees are practicing the desired ethics and the necessary laws and ordinances from their compliance education in their everyday work and that they correctly understand the existence and workings of the internal reporting hotlines, as well as to check general compliance topics, such as whether there is harassment or not. The results of these questionnaires are shared with the compliance officers at each overseas subsidiary for the sake of improving the compliance education further.

Required Considerations in Pharmaceutical Research and Development

Research involving human-derived samples is conducted only after fair and impartial deliberation by the Ethics Committee, which includes external experts, in accordance with internal regulations^*2. These internal regulations were formulated after ample consideration of such issues as respect for human rights, commitment to safety, the protection of personal information, and bioethics, pursuant to the Declaration of Helsinki and other relevant guidelines.

We handle all chemical substances, genetically modified organisms, and infectious agents/pathogens with the utmost care in order to protect the environment, safeguard biodiversity, and maintain human life and health. This is done based on internal regulations^*3 that stipulate appropriate storage and management systems, pursuant to applicable laws, regulations, and other guidelines.

When conducting animal research, plans are reviewed by the Institutional Animal Care and Use Committee (IACUC) in accordance with internal regulations^*4, which are based on the 3Rs^*5—an ethical framework for animal welfare—and comply with the Act on Welfare and Management of Animals and other relevant laws and regulations.

Our animal research facilities have been certified by the Japan Pharmaceutical Information Center, and our pathogen and genetically modified organism facilities are subject to inspections by the Certified Non-Profit Organization Biomedical Science Association to ensure proper operations.

Notes and Additional Information
*1 This refers to be ethical, for example by not breaking laws, keeping promises, not telling lies, and not bullying those who are weaker than you. It also means sharing profits with partners and society. We make a point of always meeting the expectations of society in all countries and regions where we are active.
*2 Ethical regulations regarding the use of human samples and information
*3 Safety management regulations for legally mandated substances, radiation injury prevention rules, genetic modification testing safety management rules, and safety management regulations for pathogens
*4 Regulations regarding animal research
*5 Refers to replacement (the use of alternatives to animal testing), reduction (reduction of the number of animals used) and refinement (minimizing animal pain and distress)