Compliance

In order to put the 2030 Vision into practice under our philosophy, the Kyowa Kirin Group acts in accordance with its Core Values and with high ethical standards while aiming to become a corporate group trusted by society. Considering compliance as the foundation of all our corporate activities, we have established an organizational structure to comply with all laws and regulations, internal and external guidelines and rules and social norms.

The Kyowa Kirin Group Code of Conduct sets forth the actions that should be taken by everyone working in the Kyowa Kirin Group. The Code of Conduct is translated into local languages and disseminated to everyone working in the Group around the world and their pledge to comply with the Code of Conduct is obtained. Their understanding and compliance is monitored through employee awareness surveys and other means. We also encourage all partners in our supply chain to comply with the Code of Conduct. In addition, action policies related to individual business areas have been established as the Kyowa Kirin Group Policies.

The Code of Conduct and the Group Policies have been established with the approval of the Board of Directors. The code and the policies are continuously reviewed in light of changes in the external environment, such as laws and regulations, as well as changes in the internal environment and any revisions must be approved by the Board of Directors.

The Kyowa Kirin Group Code of Conduct

Kyowa Kirin Group Policies

Under the supervision of the Representative Director and Executive Vice President, the Kyowa Kirin Group has established a Global CSR Head, who is responsible for overall compliance throughout the Group, and a Corporate Social Responsibility Management Department to assist the Head in their duties. The Global CSR Head and the Corporate Social Responsibility Management Department take the leading role in compliance, formulating and implementing compliance measures on a global and regional basis in collaboration with the Regional CSR Heads,^*1 who are responsible for compliance in the four regions of Japan, North America, EMEA, and Asia/Oceania.

The Kyowa Kirin Group has established regional CSR committees in the four regions to discuss compliance-related activities. These committees are held on a regular basis to discuss the status of activities and issues that are global or specific to each region. In addition, a joint Group CSR Committee meeting encompassing the four regions is held twice a year to deliberate on compliance strategies and actions plans for the entire Group, and to report on the progress of activities during the year. The Group CSR Committee is chaired by the Company’s Representative Director and Executive Vice President. Important matters discussed in these committees are reported to the Board of Directors.^*2

The Kyowa Kirin Group has put in place the Compliance Line, whistleblowing system, in order to prevent, detect at an early stage and correct acts that are against the Kyowa Kirin Group Code of Conduct（bribery, improper profit sharing, illegal political contributions, other corrupt acts, harassment, and various human rights violations), as well as acts that seriously damage the brand value of the Kyowa Kirin Group. On top of the strict adherence to confidentiality and a rule that those reporting an incident will not be subjected to any retaliation, steps have been taken to establish an internal and external point of contact for reporting that can be accessed by telephone, electronic and postal mail as well as online tools. Reports can also be filed anonymously. In this manner, every effort is being made to create a simple and easy reporting environment. In the case of the internal contact point, the Human Resources Department receives reports. In the case of the external contact point, reports are forwarded from the outsourced external contact point to the Audit & Supervisory Board members and the Corporate Social Responsibility Management Department, etc., of the Kyowa Kirin Group in accordance with predetermined rules to initiate an investigation and respond to the matter. We have also introduced a process under which reports concerning directors are passed directly to company auditors. If the reported matter is found to be true by an investigation, corrective measures and recurrence prevention measures will be taken. In some cases, the matter may be referred to the Award and Disciplinary Committee, which will consider whether disciplinary action should be taken. The results of the company’s response to whistleblowing are reported to the Board of Directors and management on a regular basis. Moreover, messages from the CEO on such topics as the importance of the Compliance Line, confidentiality and non-retaliation are sent out on a continuous basis. The point here is to ensure that employees gain a better understanding of the system through group training and e-learning and while maintaining a continuous awareness toward each point of contact for reporting. Details of the Compliance Line are readily available on the Company’s website and posters displayed throughout the workplace. In response to Japan’s revised Whistleblower Protection Act, which takes effect from June 2022, we were confirming the design and operation of our system, revising internal rules, and making continuous improvements.
Overseas subsidiaries operate local whistleblowing systems in each region. We also established and operate a global line that enables overseas subsidiaries’ employees to report directly to the Group’s head office in Japan in their local language.
In 2021, the Compliance Line received a total of 24 reports in Japan and overseas.

For opinions from external stakeholders, including local residents and suppliers, several contact points are available on the Company’s website to respond to various inquiries.

At the Kyowa Kirin Group, the internal audit unit conducts risk-based audits from an independent standpoint at approximately 100 locations, including subsidiaries in Japan and overseas. Internal audits verify and evaluate the status of compliance framework establishment and implementation at each site. In addition to pointing out issues and proposing recommendations for improvement, internal audits also help monitor conduct to ensure that appropriate corrective measures are taken. The results of internal audits are presented to the Representative Director and President, Executive Vice President and the Board of Directors. At the same time, efforts are directed toward strengthening collaboration and improving governance to enhance the effectiveness of audits within the Group by sharing details of the information discussed at regular meetings with company auditors as well as accounting auditors.

The Kyowa Kirin Group provides a variety of training programs, including group training and e-learning, on topics such as codes of conduct, anti-bribery and anti-corruption, personal information protection, compliance standards specific to the pharmaceutical industry, human rights, and anti-harassment. These courses are mandatory for all directors and employees, or assigned according to rank or duties.

Each region of the Kyowa Kirin Group designates a compliance week or month each year to provide an opportunity to reaffirm the importance of compliance. In Japan, various programs were held in 2021, including the dissemination of a message from the Representative Director and Executive Vice President, training for executives, and group training for executives and employees.

All executives and employees of the Group regularly attend training to ensure that the Code of Conduct is well understood. In 2021, 6,631 executives, employees, contract employees and temporary employees in Japan and overseas took the training related to the Code of Conduct. Also, global e-learning was conducted in the areas of anti-bribery and anti-corruption. The details of the training are designed to provide participants with a variety of knowledge about corruption, including bribery and commercial bribery. As of the end of 2021, 6,193 executives and employees in Japan and overseas took the course. Refer to the following for other major compliance trainings conducted during 2021.

The Company participates in the annual Compliance・Human Rights Awareness Survey implemented by the Kirin Group. The results of the survey help to identify changes in employee awareness and issues that need to be addressed, and are utilized in formulating the Group’s initiatives.