Operation of the Compliance System

At Daiichi Sankyo Group (the “Group”), the CEO has appointed a Chief Compliance Officer (CCO), to oversee and manage the global compliance and risk management unit.
In accordance with the Compliance Promotion Rules, the Company's Corporate Ethics Committee serves as a deliberation and decision-making body for compliance across the Group. The Committee is chaired by Daiichi Sankyo Company, Limited (the “Company”)’s compliance officer and consists of 13 members, including 12 internal representatives and an appointed external attorney who ensures that the committee operates in a transparent and reliable manner (as of the fiscal year 2023). The committee convenes twice per year, and full-time members of the Company's Audit and Supervisory Board and the heads of the Company's Internal Audit Department and the Business Management Department also participate as observers. Each Group Company has a designated compliance officer or an equivalent staff who is responsible for overseeing the compliance programs and promoting compliance programs within their respective companies. Furthermore, to ensure the effectiveness of the Group's global compliance system, the Global Compliance Advisory Committee has been established as an advisory board to the Company’s Corporate Ethics Committee. This Committee, chaired by the Chief Compliance Officer (CCO), includes compliance officers from the Group company subsidiaries in Japan, the United States and Europe. Its responsibilities include examining the global policies, annual compliance objectives of the Group and proposing global compliance initiatives. The discussions of the Company’s Corporate Ethics Committee and the Global Compliance Advisory Committee are reported to the Company’s CEO and Board of Directors as part of the compliance promotion activities for the fiscal year.

Matters to be Reported to the Board of Directors Regarding Compliance Promotion Activities in FY2023

  • Summary of Matters Discussed and Reported by the Corporate Ethics Committee
  • Overview of Compliance Promotion Activities (Global and in Japan)
  • Responding to Compliance Incidents
  • Global Compliance Targets for FY2024

Compliance with the Daiichi Sankyo Group Employee Code of Conduct and Related Internal Policies and Regulations

In recent years, companies with global operations have been required to develop broad policies regarding the code of conduct for individuals in their respective organizations. In April 2015, the Group established the Daiichi Sankyo Group Individual Conduct Principles as a common group policy on the individual behavior of executives and employees of the Group. In April 2020, the Daiichi Sankyo Group Employee Code of Conduct (the ECC) was established to provide broader and clearer global uniform standards of the individual behavior expected of the Group’s executives and employees. We conduct training programs regularly to increase awareness of the ECC.
In accordance with the Daiichi Sankyo Group Corporate Conduct Charter and the ECC, the Company and the Group companies in Japan have established their own local Codes of Conducts. In Japan, the Codes of Conduct also take into account the contents of the JPMA Compliance Program Guidelines of the Japan Pharmaceutical Manufacturers Association. Group companies outside of Japan have established internal rules,local codes of conduct, policies, and procedures that are tailored to the laws, regulations, and characteristics of their respective countries and regions as necessary. We will continue to make efforts to enforce compliance with our internal rules, codes of conduct, policies and procedures and continue compliance with applicable laws and regulations. 

Daiichi Sankyo Group Employee Code of Conduct

Compliance with Global Policies Related to Preventing Bribery and Corruption

Laws and regulations against bribery and other forms of corruption in countries around the world continue to be strengthened each year. Thus, it is becoming increasingly important for global companies to implement initiatives for detecting and preventing bribery and other forms of corruption.
The Group has specified the prevention of bribery and corruption in the ECC. In order to further ensure compliance particularly in this regard, we have also established the Daiichi Sankyo Group Anti-Bribery & Anti-Corruption Policy, which sets forth more detailed rules on the prevention of bribery and corruption, including the prohibition of cash payments to government officials and healthcare professionals.
The Group also continues to conduct training for anti-bribery and anti-corruption to further bolster our anti-bribery and anti-corruption structure. We will continue to take measures for our business, especially in countries with high risks of bribery and corruption, through cooperation with Group companies. In addition, we have implemented at each Group Company a due diligence monitoring process for bribery and corruption risks of our 3rd party suppliers.

Daiichi Sankyo Group Anti-Bribery & Anti-Corruption Policy

Compliance Reporting System

The Group has introduced a global unified whistleblowing hotline (Global Hotline) for compliance reporting. This unified global approach better enables the Group to understand compliance violations in a timely manner throughout the Group operations, and nurture a more open workplace environment.
The Global Hotline is available 24 hours a day, 365 days a year, for compliance reporting and consultation. It is available in the languages of all countries and regions where the Group companies are located. The Group also accepts reports and consultations from people outside the Group on the Company and Group websites.
In addition to the Global Hotline, the Company and the Group companies in Japan have established and operate internal hotlines for whistleblowing via dedicated telephone lines and e-mail addresses. The Company and the Group companies in Japan also run a harassment reporting and consultation service within the Company’s Human Resources Departments and outside the Company.
Furthermore, the Group maintains a procedure requiring a direct report to the chief compliance officer of the Group when a compliance officer of any Group company worldwide suspects significant misconduct involving specific Senior Executives (Senior Executive Misconduct Reporting Procedure: SEMRP).
In accordance with the revision of the Whistleblower Protection Act in Japan, which took effect on June 1, 2022, the Company and the Group companies in Japan are revising their rules for handling whistleblowing and related matters in a timely manner. We will continue to communicate not only the significance and importance of the reporting system but also the confidentiality, to the extent possible, of reporters and individuals seeking consultation, in order to ensure its effective operation.

Compliance Data for FY2023 (Global consolidated)

  • Number of allegations received (excluding through our compliance monitoring processes): 315
  • Measures: On the basis of the reports that we received, we conducted appropriate investigations for cases determined to require investigation. In cases in which allegations were found to be substantiated, we took appropriate measures, including disciplinary actions against any infringer.

Note: The results included in this information for FY2023 were calculated by each Group company based on the individual criteria; as such, the calculation of the number of allegations may be impacted by regional differences in laws, employment practices, and local policies and procedures.

【VOICE】Fostering an open workplace culture


Seeum Jeong
Ethics & Compliance Group,
Compliance & Risk Management Department

In the Ethics & Compliance Group of the Compliance & Risk Management Department, we engage in various activities to promote compliance, such as training, policy management and supporting the reporting system within the Daiichi Sankyo Group. One of our key objectives is to foster an open workplace culture. In fiscal year 2023, I participated invarious events held at the Shinagawa RD Center, Hiratsuka Pharmaceutical Technology DevelopmentCenter, headquarters, and the Japanese Business Unit’s conference. At each venue, we set up compliance booths where employees could share their thoughts and ideas about compliance, which were then displayed. Through this initiative, I had the opportunity to gain insight into employees’ awareness and commitment to compliance. The comments expressed a range of sentiments, from “acting in a manner that would make their families proud” to “listening to others’ opinions,” “expressing opinions without hesitation,” and “maintaining effective communication with others.” The common thread among all the comments was the employees’ desire to contribute to the success of the Daiichi Sankyo Group by utilizing their skills in a workplace culture where they can work with peace of mind every day. As a member of the Ethics & Compliance Group, I will continue to strive towards fostering a better workplace culture where employees listen to each other and have the freedom to express their thoughts and ideas.This will enable us to fulfill the purpose of the Daiichi Sankyo Group, which is to “Contribute to the enrichment of quality of life around the world.”

Compliance Booth at Technology Meeting in FY2023

Compliance Training and Educational Activities

Ongoing compliance training and educational activities are an indispensable part of promoting the Group compliance programs.
In order to promote the awareness of compliance, encourage the highest ethical standards, and cultivate an open workplace environment, the Company and the Group companies in Japan conduct small group discussion periodically (Compliance Communication Meeting) using training materials developed in-house.
Furthermore, the Company conducts compliance training by external specialists on a regular basis for the Company’s Board Members, members of the Audit and Supervisory Board, corporate officers of the Company, and Presidents and Auditors in Group companies in Japan. The Group companies in Japan also conduct compliance training annually for new employees and managers. Group companies outside of Japan conduct compliance training through the face-to-face conversation, e-learning or other methods, as appropriate to each region.
Furthermore, we are striving to further raise compliance awareness within the Group by conducting activities, such as periodic messages (twice a year) from our CEO to the Group regarding the importance of compliance.

Employee Survey on Ethical Culture

As part of our efforts to promote "compliance management" as a materiality in the business foundation, the Company conducts an annual global compliance survey on corporate culture, targeting all executives and employees of domestic and overseas Group companies. This initiative will be measured as a Key Performance Indicator (KPI) until fiscal year 2025.The Company also conducts periodic employee surveys on ethical culture for executives and employees of all domestic Group companies. Most recently, in fiscal year 2023, approximately 9,800 individuals participated in the survey. The Company and the Group companies in Japan identified strengths and areas for improvement through this survey by analyzing factors such as the level of comprehension of their mission, compliance-related policies, compliance implementation, and development of internal systems. Surveys will be conducted on a regular basis and based on the results, will be used to enhance our compliance programs at the Company and the Group companies in Japan.