Declaration of Conduct and Compliance Standards

Sumitomo Dainippon Pharma has declared in our publicly announced Declaration of Conduct our commitment to "abide by relevant laws and regulations, and conduct our business in a transparent and fair manner with high ethical standards." To put this declaration into practice and ensure full compliance, we have established our Compliance Standards, based on which we conduct our business.

Framework for compliance implementation

Sumitomo Dainippon Pharma has in place the organizational framework shown below for full implementation of compliance by every company of the Sumitomo Dainippon Pharma Group.

Framework for compliance implementation

One of Sumitomo Dainippon Pharma's executive officers is charged with overseeing all compliance matters of Sumitomo Dainippon Pharma and its group companies around the world.

Three compliance committees have been set up: the Compliance Committee of Sumitomo Dainippon Pharma, the Compliance Committee of the group companies in Japan and the Compliance Committee of the group companies outside Japan. The Sumitomo Dainippon Pharma executive officer in charge of compliance serves as chair of each of the three committees and reports to the Board of Directors on the committee activities.

The Compliance Committee of Sumitomo Dainippon Pharma deliberates on any revisions of the Compliance Standards, discusses compliance education and training programs and verifies their implementation, and reviews compliance implementation. The Compliance Committees of the group companies in and outside Japan each shares information and discusses compliance matters such as compliance policies, programs and activities.

Compliance Hotline

Sumitomo Dainippon Pharma has set up internal and external compliance hotlines through which its officers and employees can make consultations and reports relating to incidents of real or threatened compliance violation. Similar compliance hotlines have been installed in the group companies in and outside Japan. The officers and employees of such group companies may use the Sumitomo Dainippon Pharma hotlines, if the use of their own compliance hotlines is not appropriate.

Compliance education and training

Sumitomo Dainippon Pharma provides all its employees with annual compliance educations and training on a number of topics that include corruption, insider trading, the harmful effects of drugs, and harassment. A booklet about the Compliance Standards is used in compliance workshops held at the workplace level. The group companies in and outside Japan are required to provide similar compliance education and training programs.

Future compliance initiatives

Sumitomo Dainippon Pharma recognizes that the implementation of compliance is a major prerequisite for the continued existence of companies. We will continue to provide our officers and employees with necessary education and training to ensure that their decisions and conduct are in full compliance with relevant laws and regulations as well as our own internal rules, and are consistent with the social responsibilities and corporate ethics. Also, we will continue to improve our compliance implementation regime.