• 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 Company, Limited (the “Company”), the Head of Global Compliance & Risk serves as a compliance officer, a position responsible for managing the compliance program, including the Company’s Code of Conduct for Compliance and related policies and annual objectives, in accordance with the Compliance Promotion Rules. This compliance officer also serves as the chairperson of the Company's Corporate Ethics Committee. This committee is a deliberation and decision-making body for compliance across the Daiichi Sankyo Group of companies (the Group) that meets twice per year and is made up of 15 members, including 14 internal representatives and an appointed external attorney who ensures that the committee operates in a transparent and reliable manner. 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 in meetings of this committee as observers. The heads of divisions and departments at the Company are responsible for promoting the compliance programs within their respective organizations. Additionally, a compliance officer or an equivalent officer responsible for overseeing the compliance programs is assigned to each Group company to promote compliance programs at their respective companies. Furthermore, in order to ensure the effectiveness of the Group's global compliance system, we have established the Global Compliance Advisory Committee as an advisory board to the Company’s Corporate Ethics Committee. Full-time members of the global committee include the head of the Legal Affairs Department of the Company, who chairs this committee, and compliance officers from the Group company subsidiaries in the United States and Europe. The committee is responsible for examining the global policies and annual compliance objectives of the Group . 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 compliance promotional activities for the fiscal year.

Compliance with the Daiichi Sankyo Group Employee Code of Conduct and Related to 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) replaced the Daiichi Sankyo Group Individual Conduct Principles 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, policies, and procedures that are tailored to the laws, regulations, and characteristics of their respective countries and regions as necessary. We will continue to take efforts to enforce compliance with our internal rules, 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 a high risk of bribery and corruption, through periodic interviews with the heads of Compliance and/or Legal Affairs at Group companies by the person in charge of compliance at the Company’s Legal Affairs Department.

Daiichi Sankyo Group Anti-Bribery & Anti-Corruption Policy

Compliance Reporting System

In May 2021, the Group introduced a new external global whistleblowing hotline (Global Hotline) for compliance reporting. Before May 2021, we had built and operated reporting systems in each region. This newly 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 open 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 Company's General Counsel when a compliance officer of any Group company worldwide suspects significant misconduct by 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 FY2021 (Global consolidated)

• Number of allegations received (excluding through our compliance monitoring processes): 157
• Measures: On the basis of the reports that we received, we conducted appropriate investigations for cases determined to require investigation. In case allegations have been found substantiated, we took appropriate measures, including disciplinary actions against any infringer.

Note: The results included in this information for FY2021 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 high ethical standards, and cultivate an open workplace environment, the Company and the Group companies in Japan conduct small group discussion training (interactive training) 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 various employees of Group companies in Japan, such as presidents and compliance officers. The Group companies in Japan also conduct compliance training annually for new employees and managers. 
Group companies outside of Japan conduct compliance training through case studies, e-learning or other methods, as appropriate to each region.
Furthermore, we are striving to further raise compliance awareness within the Group by conducting Senior Executive driven activities, such as periodic messages from our CEO to the Group regarding the importance of compliance.

Employee Survey on Ethical Culture in Japan

The Company and the Group companies in Japan conduct periodic employee surveys on ethical culture for executives and employees. Most recently, in fiscal year 2020, approximately 9,500 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.