Continued Operation of the Compliance System
At Daiichi Sankyo Company, Limited (the “Company”), the head of the Corporate Affairs Division serves as Daiichi Sankyo compliance officer, a position that entails managing compliance program in the Company, which includes the 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 (hereafter “Daiichi Sankyo Group”) that in principle 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 Audit and Supervisory Board and the head of the Internal Audit Department also participate as observers.
The Company’s heads of divisions and departments are responsible for promoting the compliance programs of their respective organizations.
In addition, a compliance officer or an equivalent officer who is responsible for overseeing compliance programs is assigned to each Japan Daiichi Sankyo and overseas Group companies to promote compliance programs at their respective companies.
Furthermore, in order to ensure the effectiveness of Daiichi Sankyo 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 the committee, and compliance officers from Daiichi Sankyo Group company subsidiaries in the United States and Europe, and the committee is responsible for examining the global policies and annual compliance objectives of Daiichi Sankyo Group.
Deliberations 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.
Matters Reported to the Board of Directors on Compliance Promotion Activities in Fiscal 2019
- Overview of matters deliberated and reported at the Company’s Corporate Ethics Committee
- Overview of compliance promotional activities (Global/Domestic)
- Compliance violation cases
- Global compliance objectives for fiscal 2020
Implementation of the Daiichi Sankyo Group Employee Code of Conduct
In recent years, global companies are expected to establish broad-ranging global policies regarding the requirements for the behavior of individuals across their respective organizations. Moreover, global policies must be adhered to and disclosed appropriately outside of a company to show that its global business activities are being conducted with integrity. In April 2015, we established the Daiichi Sankyo Group Individual Conduct Principles as a global policy on individual behavior of executives and employees. Replacing the Daiichi Sankyo Group Individual Conduct Principles, we have newly established the Daiichi Sankyo Group Employee Code of Conduct (“ECC”) to provide broader, uniform standards of individual behavior expected of the executives and employees of all Daiichi Sankyo Group companies must comply with in April 2020.
We are conducting training programs regularly to increase awareness of the ECC.
Daiichi Sankyo Group Employee Code of Conduct
Spread of Global Policies Related to Preventing Bribery and Corruption
The laws and regulations against bribery and other forms of corruption in countries around the world are growing stricter with each coming year. Thus, it is becoming increasingly important for companies developing their operations on a global scale to implement initiatives for detecting and preventing bribery and other forms of corruption.
We clearly state the expectation that executives and employees may not engage in any bribery and corruption practices in the ECC. Along with the ECC, the Daiichi Sankyo Group Anti-Bribery & Anti-Corruption Policy, which was established in October 2017, specifically prohibits cash payment to government officials and healthcare professionals.
We also continue to conduct trainings for anti-bribery and anti-corruption regularly and bolster our anti-bribery and anti-corruption structure. We take measures against bribery and other unwanted activities in business in high-risk countries in particular. The measures include regular visits to our Group companies in such countries by the compliance function in the Legal Affairs Department of the Company.
Daiichi Sankyo Group Anti-Bribery & Anti-Corruption Policy (64 KB)
Adherence to Compliance Conduct Standards
Previously, the Codes of Conduct for Compliance were established independently by the Company and each Japan Daiichi Sankyo Group company for executives, employees and other workers to adhere to and practice. However, the Codes of Conduct for Compliance have been aligned to reflect changes in the business environment and to standardize the internal rules for all Japan Daiichi Sankyo Group companies in light of the revised Japan Pharmaceutical Manufacturers Association Compliance Program Guidelines and our revised Daiichi Sankyo Group Corporate Conduct Charter, both of which came into effect on April 1, 2019. In this fiscal year, we are reflecting the newly established ECC in Code of Conduct for Compliance. We will remain committed to continue and further our adherence to this.
Compliance Reporting System
We have established and are operating a compliance reporting system according to the circumstances in each region. We also implement measures to ensure its effectiveness. It is clearly stated in the internal rules that a person who has reported an actual or potential compliance issues, or who has asked for advice, is protected from retaliation.
The Company has compliance reporting systems in place that can be used to report and consult about legal and regulatory violations, harassment, policy violations, or other internal issues at the Company or Japan Daiichi Sankyo Group companies to the applicable internal Legal Affairs Department, Compliance Department, or to an external law firm in certain special cases. We respond promptly and appropriately to prevent damage from occurring or spreading. There are also harassment consultation contact persons for Japan Daiichi Sankyo Group employees in the Human Resources Department, in each business function, and in external organizations.
Furthermore, each Japan Daiichi Sankyo Group company provides reporting channels such as a hotline and/or e-mail system.
In addition, the Company also receives reports or consultation from outside of the Company through the Company’s website. In fiscal 2019, the Company and Japan Daiichi Sankyo Group companies conducted group discussion-type, interactive trainings or online trainings for compliance reporting targeted toward all employees.
Each Daiichi Sankyo Group company outside of Japan also provides reporting channels. For example, Daiichi Sankyo, Inc. (“DSI”) provides a hotline and web-based channels, managed by an outside vendor, for accepting reports of compliance-related matters 24-hours a day, 7-days a week and consultation about such reports. In addition, Daiichi Sankyo Europe GmbH (“DSE”) provides external channels for accepting reports and consultation from European subsidiaries in each language. DSI and DSE also receive reports and consultation from outside of the companies on their websites as well.
Furthermore, we have a system to directly report to the Company’s General Counsel when a compliance officer of each company finds a suspicion of a significant misconduct by their Senior Executive (Senior Executive Misconduct Reporting Procedure: SEMRP).
Compliance Reporting System in Japan
Compliance Data for FY2019 (Global)
- Number of allegations received (excluding through monitoring): 222
- Categories of allegations: Financial and Competitive Integrity, Workplace Standards, Marketing and Promotional Activities, Conflicts of Interest, Other
- Measures: Out of the reports that we received, we conducted appropriate investigations for cases that we determined as requiring investigation. For cases that were recognized as compliance violations among them, we took necessary disciplinary actions including dismissing the violators.
Note: The results included in this information for FY2019 were calculated by each Daiichi Sankyo Group company outside of Japan based on the individual criteria, as impacted by regional differences in laws, employment practices, and local policies and procedures.
Accordingly, this information has been aggregated and the discrepancies impact the overall meaning and categorization of the figures
【VOICE】Establishment of Ethics & Compliance Group
Daiichi Sankyo Co., Ltd.
Corporate Affairs Division,
Legal Affairs Department,
Ethics & Compliance Group,
Established in April 2020, the Ethics & Compliance Group of the Company’s Legal Affairs Department plays a central role in the compliance promotional activities of the entire Daiichi Sankyo Group. Specifically, the Ethics & Compliance Group serves as the administrative office for the Corporate Ethics Committee and the Global Compliance Advisory Committee in the Company, examines global policies on compliance, conducts Compliance Awareness Surveys, provides compliance trainings, and responds to hotline reports (and other reporting channels), among other activities. In recent years, it is becoming increasingly important for companies not only to comply with laws, regulations, and other requirements but also to act ethically. In addition to thorough compliance with applicable laws, regulations, and other requirements, our Group companies implement a range of compliance promotional activities to encourage all executives and employees to make ethical decisions based on “Integrity.” New compliance-related challenges are also emerging as our Group companies' businesses changes. The Ethics & Compliance Group will work closely with relevant departments across the Company to resolve these challenges and minimize compliance risks.
Compliance Training and Educational Activities
Ongoing compliance trainings and educational activities are an indispensable part of promoting our compliance programs.
In order to promote understanding of compliance, encourage strong corporate ethics, and cultivate an open workplace environment, we have been conducting small group discussion-type trainings (interactive training) using original training materials in the Company and Japan Daiichi Sankyo Group companies since fiscal 2016.
Furthermore, we conduct compliance trainings by external specialists on a regular basis for the board members, Members of the Audit and Supervisory Board, Corporate Officers of the Company, and various employees of Japan Daiichi Sankyo Group companies, such as presidents and compliance officers. We also conduct compliance training annually for new employees of the Company and Japan Daiichi Sankyo Group companies and newly-appointed managers for each respective position.
Employee at overseas Daiichi Sankyo Group companies are also conducting compliance trainings using case studies and e-learning programs, depending on the circumstances in each region.
Furthermore, we are also working on raising compliance awareness throughout Daiichi Sankyo Group, as part of educational activities in Daiichi Sankyo Group. For example, we periodically send messages from the Company’s CEO regarding the importance of compliance globally in order to further raise awareness of compliance.
Employ Survey on Ethical Culture
We conduct Employee Survey on Ethical Culture for executives and employees in the Company and Japan Daiichi Sankyo Group companies periodically. In fiscal year 2020, approximately 9,500 individuals participated in the survey. We were able to identify the Company and Japan Daiichi Sankyo Group companies' 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. We will be conducting such employee survey on a regular basis, and based on the results, we aim to enhance our compliance programs at the Company and Japan Daiichi Sankyo Group companies.