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 Policy for Anti-Bribery Measures 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 Policy for Anti-Bribery Measures

Established on December 13, 2013

Revised on March 14, 2019

We at the Kyowa Kirin Group recognize that bribery is a major barrier for sustainable development of society. We believe that it is important for us to engage in fair, transparent and free competition and transactions maintaining legal and ethical relationships with parties concerned with our business.

To prevent bribery, we behave based on the following principles.

  • 1.
    We strive to be fully aware of and to strictly observe all anti-bribery laws and to comply with the spirit of anti-bribery guidelines in every country and region where we do business.
  • 2.
    We prohibit any form of bribery with anyone, including unjustly providing or receiving money, goods,entertainment or other benefits in excess of the scope recognized to be appropriate under laws and guidelines of the countries and regions where we do business.
  • 3.
    We urge business partners or agents not to conduct bribery.
  • 4.
    We will refuse further dealings with any business partner or agent if we learn of any incident of bribery by them in connection with our business.
  • 5.
    We require that all officers and employees report any violation known to them.
Kyowa Kirin Group Code of ConductPDF file

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 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 risk of bribery and acts of corruption 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.

Compliance>Internal Reporting System

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.

Kyowa Kirin CSR Procurement GuidebookPDF file

In 2020, no fines, penalties, or settlements were imposed on the Group for the violation of anti-bribery or 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.