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.

Santen Code of Practice as a Code of Conduct

The Santen Group believes it is important for our employees to not only comply with laws and regulations, but also to act in accordance with a high standard of ethics befitting workers at Santen, and to truly earn customers' trust, based on an understanding of the spirit behind Santen's Values. We have established the Santen Code of Practice as our code of conduct for all directors and employees, including contract and temporary staff.

Expanding understanding of the Santen Code of Practice

The Santen Group has published translations of the Santen Code of Practice, a concrete Code of Conduct in business activities, in 13 languages, to spread knowledge of the code to all Santen Group corporate executives and employees, who are becoming increasingly diverse in line with the progression of globalization. Every year, with the aim of promoting the "Santen Code of Practice," our president or chief compliance officer provides a message to all Santen executives and employees, and awareness activities are conducted in each country and region. We promote compliance activities to cope with globalization, such as conducting a worldwide campaign which we set February and July in 2017 as Santen Code of Practice familiarization month, to promote understanding of the code among all Santen employees, including contract and temporary staff.

Global Compliance System

In October 2016, Santen appointed a Chief Compliance Officer (CCO), 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.

Compliance Consulting & Reporting Desk

The Santen Group has made it easier for all employees, including contract and temporary staff to consult and report on suspicious actions and questions related to compliance by establishing in-house consulting and reporting desks that respond in various languages in its operating countries and regional bases. Additionally, Santen has established external helplines that receive reports anonymously in nearly all of the countries where it conducts business with the cooperation of external third-parties, such as lawyers. Incoming consultations and reports are appropriately investigated and addressed in a sincere manner, and reports are relayed to the Board of Directors regularly.
Santen also has a system in place that reports directly to the CCO.

Protection of Internal Whistle-Blowers

The Santen Group Compliance Rules provide that the Group must take appropriate measures to protect internal whistle-blowers in each area where it operates.

Extract from "Compliance Rules -Whistleblowing System-"

Corporate Officers in charge of regions, for the purpose of preventing the occurrence of any penalty, act of retaliation including discriminatory treatment, or disadvantageous treatment including adverse impact on personnel performance evaluation, upon any whistleblower on the ground of his/her whistleblowing, shall take all necessary measures including the establishment of necessary internal rules and their dissemination among employees.

For example, in Japan, the Procedure Manual for Compliance Consultations and Reporting provides that internal whistle-blowers must not be treated in a disadvantageous manner, that if internal whistle-blowers are treated in a disadvantageous manner, such disadvantageous treatment must be ended, and that cooperators in reporting or investigations must also be protected in the same manner as whistle-blowers.

Protection of Personal Information

To appropriately treat and protect the personal information of patients, general consumers and employees, the Santen Group 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 operates the policy and program appropriately.

In FY2017, to appropriately respond to the revised Act on Protection of Personal Information, which came into effect in Japan in May in the same year, we revised our in-house regulations, and drew contracts for legitimate transfers of personal information among our group companies both in Japan and abroad. In addition, to comply with the General Data Protection Regulation (GDPR), a new regulation on the protection of personal information in the EU, which became effective in May 2018, we also formulated in-house regulations for our group companies in Europe, revised our privacy policy, and drew contracts among our group companies for legitimate transfers of personal data from Europe to outside Europe.

There were no privacy violation cases by the Santen Group in FY2017.

Information Security Measures

The Santen Group implements measures against the risks of information leakage, including formulating internal regulations, such as the "Basic Policy for Information Security" and the "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 2016 by expanding their scope to overseas group companies. In May 2018, we established a section dedicated to information security in a global scope, and put the section into operation. We also implement other information security measures, such as providing our employees with information security education, and carrying out assessment of physical security.

Compliance Education

The Santen Group makes efforts to raise compliance awareness, by designating November as the Santen Code of Practice familiarization month, by providing employees with training and other measures.

As part of the awareness activity, we offer employees e-learning-based training in 13 languages on 16 topics relating to the theme of the "Basic criteria and Action principles," including bribery prevention, conflict of interest, protection of personal information, discrimination, and workplace harassment.

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 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.

In FY2017 there were no cases of major law violation by the Santen Group and no suits against the Group.