• Operation of the Compliance System
• Compliance with the Daiichi Sankyo Group Employee Code of Conduct and Related to Internal Policies and Regulations
• Compliance with Global Policies Related to Preventing Bribery and Corruption
• Compliance Reporting System
• Compliance Training and Educational Activities
• Employee Survey on Ethical Culture  in Japan

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 s Daiichi Sankyo Group Compliance Management Policy, the  Global Ethics & Compliance Committee will serve as a deliberation and decision-making body for compliance across the Group , effective from the current fiscal year. Its aim is to review and evaluate compliance-related matters, promoting management that complies with domestic and international laws and regulations, corporate ethics and corporate social responsibility. 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.  The discussions of the  Global Compliance Committee are reported to the Company’s CEO and Board of Directors as part of the compliance promotion activities for the fiscal year.

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 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 as planned 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 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 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 (CCO) when a compliance officer of any Group company worldwide suspects significant misconduct involving specific Senior Executives (Senior Executive Misconduct Reporting Procedure: SEMRP).
The Company and the Group companies in Japan are constantly updating internal regulations on whistleblowing system to keep up with changes in laws, regulations, and the environment. 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): 363
• 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 FY2024 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.

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 dialogue 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 (every two years) 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. The survey results will be used to enhance our compliance programs at the Company and the Group companies in Japan.