Anti-Bribery and Anti-Corruption
Acts of corruption hinder the sustainable development of society. The United Nations and the Organisation for Economic Co-operation and Development (OECD) as well as national governments around the world have urged global companies to strengthen their measures to prevent such conduct. Acts of corruption are not tolerated under any circumstances at the Kyowa Kirin Group.
To clarify its strong determination to prevent bribery and corruption, the Kyowa Kirin Group explicitly states in the Kyowa Kirin Group Code of Conduct, which serves as the guiding principles for all who work for the Group, that it prohibits bribery, unjust provision of benefits, illegal political donations, and other acts of corruption. In addition, the Kyowa Kirin Group Anti-Bribery and Anti-Corruption Policy has been put in place to complement the Code of Conduct, along with internal regulations that set forth concrete operational procedures.
The Code of Conduct and the Policy have been translated into languages of the regions in which the Group conducts business so as to ensure their dissemination across the entire Group. They are also posted on the intranet so that they can be viewed worldwide.
The Board of Directors oversees the status of implementation of the Code of Conduct and the Policy including the prevention of bribery and corruption, and their revision is subject to approval of the Board of Directors.
Kyowa Kirin Group Anti-Bribery and Anti-Corruption Policy
Established on December 13, 2013
Revised on June 9, 2022
The Kyowa Kirin Group (the "Group") aims to be a corporate group that society can trust, while operating in line with its Management Philosophy, Core Values and Vision and through its strict adherence to high ethical standards. As part of this effort, with full recognition of the fact that bribery and corruption are major obstacles to sustainable development of society, we maintain business relationships with stakeholders in compliance with laws and regulations and also in accordance with high ethical standards, and at the same time, engage in fair, transparent and free competition and appropriate transactions. The Group’s position on anti-bribery and anti-corruption is described in the Kyowa Kirin Group Code of Conduct, and we hereby specify our anti-bribery and anti-corruption guiding principles.
This Group Policy applies to everyone working in the Group, regardless of country or region, position or title, such as officer, employee, fixed-term employee or temporary staff, or full time or part time (the “Employees of the Group”). We will also require all of our business partners or agents to act in accordance with the underlying principles set forth in this Group Policy.
- 1.“Bribery and Corruption” means (i) offering, promising, providing, authorizing, accepting or requesting anything of value, including improper payments, goods, entertainment, or other improper financial advantages that exceed what is considered appropriate under the applicable laws, regulations, guidelines or relevant industry codes in the country or region where the Group company operates and (ii) making Facilitation Payments (as defined hereinafter).
- 2.“Facilitation Payments” means small payments made to a government official, etc. to expedite or secure a routine governmental action.
- IV.GUIDING PRINCIPLES
We will abide by the following anti-Bribery and anti-Corruption guiding principles:
- 1.We will fully understand the underlying principles of and comply with applicable anti-Bribery and anti-Corruption laws, regulations, guidelines or relevant industry codes in the countries where we operate and do business.
- 2.We maintain a zero tolerance policy against all forms of Bribery and Corruption.
- 3.We strictly prohibit any form of Bribery and Corruption against any party. All Facilitation Payments, even if permitted under the applicable laws, regulations, guidelines or relevant industry codes in the country where the Group company operates, are prohibited under this group policy.
- 4.We require our business partners or agents not to engage in any Bribery and Corruption.
- 5.We will refuse to continue doing business with any business partner or agent if we become aware of any Bribery and Corruption committed by such business partner or agent in connection with the Group’s business.
- 6.The Employees of the Group are required to report immediately any known violations of this Group Policy, including those of applicable laws, regulations, guidelines or relevant industry codes.
- 7.The President and CEO of Kyowa Kirin Co., Ltd. is responsible for the Group's anti-Bribery and anti-Corruption program, and will appoint anti-Bribery and anti-Corruption officers at each Group company for the execution of necessary anti-Bribery and anti-Corruption measures.
- 8.We will keep accurate records of all payments made to and business transactions with the parties concerned.
Responsible Department: CSR Management Department
Established on December 13, 2013
Revised on October 1, 2018
Revised on March 14, 2019
Revised on June 9, 2022
Kyowa Kirin’s Chief Compliance Officer (CCO; Representative Director and Executive Vice President) supervises the Group’s initiatives to prevent bribery and corruption. Under the CCO’s leadership, the Group CSR Committee and its secretariat, the Corporate Social Responsibility Management Department, play a central role in executing the initiatives with managers assigned to the task at each Group company.
All executives and employees, including contract, part-time, and temporary employees, annually undertake a mandatory anti-bribery and anti-corruption e-learning program, which is available in 10 languages. The program contains the president’s message, and elaborates on the Policy and internal regulations as well as covering social trends including the latest exemplary cases and updates on laws and regulations.
The Group implements a series of ongoing risk management activities, which comprise identifying, analyzing, and evaluating risks, taking measures against risks, checking how risks are addressed, and improving the measures. Recognizing that the bribery and corruption risk is one of the risks that could impact our business management, it is among those that we assess. Based on the assessment result, managers assigned at each Group company or division at high risk of becoming involved in bribery/corruption set concrete preventive measures as part of their business plan, and monitor their progress. The Corporate Social Responsibility Management Department reports updates on risk management at periodic CSR Committee meetings, checks its effectiveness, and reports the result to the Board of Directors. The audit unit, which is independent from the business execution lines, audits the activities pertaining to risk management and control, and reports the results to the Audit & Supervisory Board and the Board of Directors.
The Group offers multiple consultation hotlines to enable any executive or employee to voice any doubts or concerns regarding bribery or corruption with a sense of security. One of them is the Compliance Line, which serves as a contact point for discussing or reporting compliance matters in general including bribery and corruption. Executives and employees can remain anonymous when contacting the Line, their reporting will be kept confidential, and whistleblowers will not suffer any disadvantages as a result of their action. For further details about the Compliance Line, refer to the link below.
The Group sets forth the Supplier Code of Conduct, which stipulates the actions and behavior that suppliers are expected to adhere to, including those concerning bribery and corruption. We conduct CSR questionnaire surveys of new suppliers, as well as of existing suppliers, before entering into transactions with them to assess their adherence to the Supplier Code of Conduct. In view of the survey results, we perform due diligence*1 and strive to reduce the risks related to bribery and corruption.
In 2021, no fines, penalties, or settlements were imposed on the Group for the violation of anti-bribery or anti-corruption laws, and no disciplinary dismissal resulted from the violation of such laws.
- *1:Duty of care and effort that companies are required to exercise as a matter of course. In this case, due diligence indicates investigating suppliers’ risk of becoming involved in bribery or corruption.