The Santen Group develops and operates a system for complying with laws and regulations as well as the business practices of the countries/regions in which we operate for every employee to act according to a high standard of ethics.

Establishing a Global Compliance System

In October 2016, Santen appointed a Chief Compliance Officer, a Compliance Committee, etc., to establish a system for promoting globalization-compatible compliance activities. Santen also holds a Meeting of the Global Compliance Committee, which brings together executives in charge of regions and functional organizations, and a Global Compliance Working Committee, which is attended by in-house compliance administrators in charge of regions and functional organizations, twice a year. Based on the decision made at the committee, we promote global compliance activities. Previously, we have set compliance-related consultation/complaint systems in each region/country, and we launched worldwide campaigns to promote understanding of the "Santen Code of Practice" among all Santen employees in both February and July, 2017.

Compliance Education

Santen makes efforts to raise compliance awareness, by clarifying desirable conduct, as well as the necessity of compliance, in the Santen Code of Practice as a concrete Code of Conduct in our business activities; providing employees with training; and other measures.

In Japan, to facilitate employees' understanding of compliance, Santen provides training for all new employees and all newly appointed managerial staff members. Additionally, Santen checks the levels of employees' understanding of and compliance with relevant regulations through regular employee opinion survey and internal audits. Santen provided training on "Understanding of regulations on bribery prevention" in December 2015, and "Security export control" in March 2016, to deepen employees' understanding of the rules and procedures to be followed. Santen also provides training for each division or section, on "Avoidance of conflict of interest," "Prevention of insider trading," the "Act against Delay in Payment of Subcontract Proceeds, etc. to Subcontractors," the "Act against Unjustifiable Premiums and Misleading Representations" and other topics, according to the contents of the participants' duties.

Preventive Measures against Corruption

Our Code of Conduct as part of the Santen Code of Practice, which defines how every Santen employee should act, strictly prohibits bribery, clearly stating, "We do not engage in any conduct regarded as bribery or corruption, whether directly or through a third party, that would violate the applicable laws and regulations of the relevant country." The Code of Conduct also provides that we maintain sound and normal relationships with political and governmental bodies.

There were no corruption cases in FY2016.

Maintaining an Appropriate Relationship with Healthcare Professionals and Patient Organizations to Ensure Transparency

Santen presents meetings and opinion-exchange opportunities to healthcare professionals and patient organizations, with the aim of promoting the appropriate use of pharmaceuticals among users and accurately understanding medical needs. We also provide assistance for research conducted at institutions including university hospitals as well as for patient organizations, for the purpose of promoting medical and pharmaceutical development.

In Japan, we not only comply with laws and regulations and self-imposed regulations of the industry, but also establish in-house guidelines and perform continual training and inspection, to ensure that our activities are conducted based on high ethical standards. Concerning donations, we have established a donation committee led by our corporate officer in charge of CSR, with the aim of reviewing the validity of donations made. Furthermore, whenever donations are made, our organization independent of our sales and R&D departments checks and records the details of the donations and discloses these annual results on our website.

There were no incidents of non-compliance concerning marketing communications in FY2016

Efforts to Spread Knowledge about the Industry's Self-Regulations

In April 2013, the Japan Pharmaceutical Manufacturers Association (JPMA), an association of research and development-based pharmaceutical companies, including Santen, formulated the JPMA Code of Practice (hereinafter "JPMA Code") as the pharmaceutical industry's self-regulations, which require all executives and employees of all member companies to act based on a high standard of ethics. JPMA also promotes its activities by defining November as the "month for facilitating understanding of the Code of Practice."

The President of Santen has given a message that employees are required to review the background and objectives of relevant laws and regulations, the industry's self-regulations, etc., and act sincerely.

Ensuring Protection of Personal Information

In Japan, to appropriately treat and protect the personal information of patients, general consumers and employees, Santen has devised a Policy toward the Protection of Personal Information and a compliance program on the protection of personal information, and strives to spread necessary knowledge to all Santen Group executives and employees through training and to operate the policy and program appropriately.

In Japan, In response to the launch of the Social Security and Tax Number System (commonly known as the "My Number" system) in January 2016, Santen has formulated our Basic Policy and Regulations on the treatment of specific personal information, etc., and strives to enact the policy and regulations more strictly.

There were no privacy violation cases in FY2016.

Information Security Measures and Education

Santen implements measures against the risks of information leakage, including formulating internal regulations, including the Basic Policy for Information Security and Information Security Corporate Principles and Rules, and developing and operating a system for information security based on these regulations, in order to properly protect and manage information. In response to the globalization of our businesses, Santen reformulated the Regulations on Information Security in May 2015 by expanding their scope to overseas group companies.

Santen also offers all employees information security education using e-learning and other means, and conducts internal audits on a regular basis.