Basic Ideas on Ethical Marketing Practices

In addition to establishing Daiichi Sankyo Group Marketing Code of Conduct in accordance with the industry code of each country and territory in which we operate based on the International Federation of Pharmaceutical Manufacturers & Associations Code of Practice (“IFPMA Code”), we established the “Daiichi Sankyo Group Global Marketing Code of Conduct” on October 1, 2016 and as of April 1, 2024, we revised the title to "Daiichi Sankyo Group Policy on Interactions with Healthcare Professionals and Healthcare Organizations", added new provisions and updated the contents. This document serves as the Group’s common global policy with the aim of maintaining a high standard of ethics when interacting with healthcare professionals, medical institutions, and patient organizations, as well as when promoting pharmaceutical products.

In this global policy, we clearly state that relationships between each Group company and healthcare professionals must be maintained for the purpose of improving the quality of healthcare, with a focus on providing information on pharmaceutical products to healthcare professionals, providing scientific and educational information, and supporting medical research and education.

In line with the revision of the IFPMA Code in January 2019, we revised the policy, prohibiting the provision of gifts and promotional aids to healthcare professionals, etc. We also prohibit the provision of entertainment, cash, and other personal gifts and stipulate stricter terms and conditions of contract in cases where we pay remuneration to healthcare professionals, as well as consider the appropriateness of the remuneration. In this way, we promote appropriate marketing practices in accordance with the IFPMA Code.

Strengthening of the Review System for Sales Promotion Materials

We conduct strict reviews of sales promotion materials for our pharmaceutical products in accordance with laws, regulations, and industry codes of the countries in which we operate.

Globally, Product Material Review Process (“PMRP”) has been established to create globally common product-related materials and disease awareness materials, mainly in the field of oncology, which are reviewed by reviewers in Japan, the United States and Europe. When materials are to be used as country-specific versions based on the approved global common materials, they must be separately reviewed and approved locally in the relevant country to ensure compliance with the laws, regulations and industry codes of that country. Through this process, we strictly manage the creation of global materials.

In Japan, the Medical Drug Information Review Meeting, which includes third-party external committee members independent from the Company’s Sales & Marketing Division and Medical Affairs Division, reviews all materials for provision of sales information and such for domestic products within Japan, while the Direct to Consumer (“DTC”) Advertisement Review Meeting reviews all DTC materials. Materials that have been reviewed expire in two years, and to extend the period, they need to be reviewed again. The Review Meeting Secretariat also checks the content of in-house trainings provided to sales representatives, etc. At the Review Meeting Secretariat, in addition to reviewing sales promotion materials, we also provide training to those in Japan who are responsible for creating such materials, those who are responsible for the products, those who are responsible for training materials, etc., on the material creation procedure several times each year (or as required) to further increase their awareness and improve their expertise.

Compliance with the Guidelines for Provision of Sales Information on Prescription Drugs

In compliance with the “Guidelines for Provision of Sales Information on Prescription Drugs” that came into effect on April 1, 2019 in Japan (issued by the Ministry of Health, Labour and Welfare), the Company has appointed the Legal Affairs Department in Japan as the department responsible for supervising the activities to provide sales information and established the Supervisory Committee on provision of sales information on prescription drugs. This Supervisory Committee supervises and provides guidance on the statuses of reviewing materials, preparing and storing operational records, implementing monitoring actions, and addressing inappropriate provision of sales information on prescription drugs at the Company. We periodically provide training to the Company’s employees so they are fully aware of the precautions when providing information on investigational and off-label products, and they may carry out provision of sales information on prescription drugs properly. In Japan, we have also posted a contact point for inquiries and complaint reporting regarding provision of sales information on prescription drugs on our website.