The Santen Group complies with laws, regulations, and fair business practices applicable to the countries and territories where we conduct business activities, and work against corruption in all its forms, including extortion and bribery.

Preventive Measures against Corruption

The Santen Group joined the United Nations Global Compact in October 2017 and works against corruption in all its forms, including extortion and bribery. We strictly prohibit employees from committing any act of bribery or corruption by clearly declaring, "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, including those applicable to other countries," in the Santen Code of Practice, which defines the ideal state of each employee's conduct. We maintain sound and normal relationships with political and governmental bodies, and, when making political donations, observe the applicable laws and regulations, such as the Political Funds Control Act, as well as appropriately controlling such donations based on in-house regulations. The Santen Code of Practice also provides that we shall refuse any demands from antisocial entities.

Moreover, the Santen Group provides employees with training by e-learning or other means on a regular basis, to facilitate each employee's understanding of the prevention of corruption in all its forms, including extortion, bribery, and conflicts of interest.

The Santen Group was not involved in any incidents of corruption in FY2017.

Maintaining an Appropriate Relationship with Healthcare Professionals or Patient Organizations and Ensuring Transparency

The Santen Group provides information materials, holds meetings and opinion-exchange opportunities for healthcare professionals or 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. 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.

In Japan, 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.

Appropriate Promotion

The Santen Group declares in the Santen Code of Practice: "We promptly provide accurate and reliable information on quality, efficacy, safety and other matters of pharmaceuticals and related products as part of our fair sales and marketing activities, in order to promote the optimal use of pharmaceuticals and related products." With regard to advertising and promotion, we formulate guidelines, such as promotion codes, by division or by country, and provide employees with education.

In Japan, we have established the Assessment Committee for Prescription Medicine Information Outlines and Advertisements, which assesses whether the product information outlines, advertisements, production promotion materials, and other materials that we use serve the purpose of promoting the appropriate use of the product, and use only those advertisements and materials that receive approval from the Committee. In other countries and territories too, we have defined the necessary procedures in compliance with the legal and voluntary regulations there.

In FY2017, there were no incidents of violations concerning advertising or promotion by the Santen Group.

Supporting the Industry's Voluntarily Established Codes

The Santen Group supports the IFPMA Code of Practice of the International Federation of Pharmaceutical Manufacturers & Associations, to which R&D-oriented pharmaceutical companies belong, and engage in conduct in compliance with codes voluntarily established by the industrial organization in the relevant country or territory, including the Pharmaceutical Research and Manufacturers of America (PhRMA) and the European Federation of Pharmaceutical Industries and Associations (EFPIA).

In Japan, we belong to the Japan Pharmaceutical Manufacturers Association (JPMA), and observe the JPMA Code of Practice (hereinafter "JPMA Code"), which provides the standards of conduct for all executives and employees of member companies with regard to their relationships with researchers, medical experts, patient associations, etc. Every November, which we have defined as the "Month for Facilitating Understanding of the Codes of Practice," the President gives a message to the employees recommending that they reconfirm the background and purposes of laws and regulations, the JPMA Code, and other rules, and engage in honest conduct.