Ethics and transparency

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 the framework necessary for compliance, including an organizational structure and basic policies 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. Translated into the local languages of each region, Kyowa Kirin is working to ensure that all employees of the Group around the world are familiar with and understand this Code of Conduct. All executives and employees pledge to comply with the Code of Conduct, and 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, basic policies related to individual business areas that must be observed 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 Policies are continuously reviewed in light of changes in the external environment, including laws and regulations, as well as changes in the internal environment. Any revisions or repeals are approved by the Board of Directors.

The Kyowa Kirin Group Code of Conduct

Kyowa Kirin Group Policies

Under the supervision of the Chief Compliance Officer (CCO), the Kyowa Kirin Group has established a Global Compliance & Risk Management (CR) Head, who is responsible for overall compliance throughout the Group, and a CR Department to assist the Head in their duties. The Global CR Head and the CR Department take the leading role in compliance, formulating and implementing compliance measures on a global and regional basis in collaboration with the Regional CR Heads^*1, who are responsible for compliance in the three regions of JAPAC (Japan and Asia Pacific), North America and EMEA. The Kyowa Kirin Group has established regional Compliance committees in the three regions to discuss compliance-related activities. These committees are held on a regular basis to discuss the status of activities and issues that are specific to each region. In addition, the Group Compliance Committee, which is led by the CCO and the Global CR Head 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 Compliance Committee is chaired by the CCO and important matters discussed in these committees are reported to the Board of Directors.

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. We have established and operate our whistleblowing system in accordance with the guidelines based on Article 11 of the Whistleblower Protection Act and the Corporate Governance Code, referring to the international standard ISO 37002 issued by the International Organization for Standardization (ISO) based in Geneva, Switzerland. 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 CR 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 audit and supervisory committee members. 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, 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 2025, a total of 30 reports in Japan and overseas were received by the Compliance Line at the Group’s head office.

At the Kyowa Kirin Group, the internal audit unit conducts risk-based audits from an independent standpoint at each location, 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 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 audit and supervisory committee members as well as accounting auditors.

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 e-learning and other programs were also held in 2025, including the dissemination of a message from the CCO, and group training for executives and employees.
All executives and employees (including contract, temporary, and part-time employees) of the Group annually attend training to ensure that the Code of Conduct is well understood. Training is conducted globally and held both in person and on an e-learning basis. In 2025, e-learning was conducted with common global content.
Refer to the following for details of other major compliance training conducted during 2025.

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.

To protect public health by ensuring the safe and effective use of our innovative therapies across the world. We are dedicated to providing timely and accurate information to healthcare professionals, regulatory bodies and our patients.

We strive towards the ideal of patient safety by predicting and preventing adverse reactions through innovative pharmacovigilance practices.

As Kyowa Kirin's innovative therapies continue to reach more patients worldwide, the pharmacovigilance organization has further evolved to ensure that patient safety remains a priority across the entire product life cycle, from discovery through maturity in all markets.
The global pharmacovigilance operating model is built on strong global functional pillars—Medical Safety, Operations and Performance Excellence—while clearly defining regional and regulatory accountabilities through dedicated organizations such as the QPPV Office and the JAPAC PV team.
This model enables Kyowa Kirin to maintain globally consistent standards and expertise, while ensuring effective execution and regulatory compliance at the regional level, underscoring our ethos of working collaboratively across boundaries to serve patients worldwide.

To achieve our vision, we must:

Kyowa Kirin places a priority on providing information to promote the proper use of pharmaceutical products. We believe that it is imperative to promptly share accurate information with patients and medical professionals, who are flooded with miscellaneous information on drugs.

In addition to sales activities by medical representatives (MRs), we use multiple channels of communication, including a contact center for fielding inquiries on drugs, medical science liaisons (MSLs) and a website catering to medical professionals, in order to provide timely information in tune with the latest changes in the medical environment. The information collected is passed on to relevant divisions, and measures are taken to “foster” drugs by maximizing their product value while assuring their safety and quality.

Based on professional expertise, our MRs provide medical professionals with information highly useful for treating patients. They especially focus on providing information on the efficacies and safety of new drugs, for which medical professionals have both high hopes and doubts, as well as on the new value added to existing drugs due to their expanded indications and other factors.

In accordance with the policy advocated by the Japan Pharmaceutical Manufacturers Association, we provide appropriate use information regarding our pharmaceutical products. We are committed to addressing inquiries not only from healthcare professionals but also from patients and the general public who reach out to us by phone. However, please understand that we are unable to respond to inquiries pertaining to individual diseases, treatment methods, or health consultations that require a physician's diagnosis.
Additionally, 'Kyowa Kirin Medical Site_©' for healthcare professionals has a 'Product Q&A Chatbot' and 'Frequently Asked Pharmaceutical Product Q&A' available. We aim to provide comprehensive information to assist with the proper use of pharmaceutical products."

Medical Science Liaisons (MSLs) leverage their advanced expertise in their assigned therapeutic areas to engage in medical and scientific information exchange with healthcare professionals and provide information that addresses the needs of patients. They operate independently from the sales department (e.g., Medical Representatives) and work daily to promote the appropriate use of pharmaceutical products.

In each research, development, and production process, the Kyowa Kirin Group is making the following efforts to remain in compliance with domestic and international laws and regulations, internal and external rules and regulations as well as social norms, while fulfilling its legal responsibilities and the ethical responsibilities required by society.

In the drug discovery research and development process, the significance of research utilizing human-derived samples is rising, requiring increased focus on ethical considerations. In addition to complying with relevant laws and regulations including the Pharmaceutical and Medical Device Act, the Kyowa Kirin Group conducts education and training for its employees and creates opportunities to acquire third-party certifications and undergo third-party reviews in order to protect human rights and personal information and ensure the reliability of its research findings in line with the ethical principles of the Declaration of Helsinki.

For employees who are engaged in research, Kyowa Kirin Group conducts education and training on related laws and regulations, bioethics, etc.
When conducting research involving human subjects, we provide opportunities for review by a third-party organization such as a Research Ethics Review Committee or Institution Review Board.

The Kyowa Kirin Group has established the Rule for Animal Experiments in view of laws, regulations such as the Act on Welfare and Management of Animals and international guidelines pertaining to animal testing. Based on this set of rules, we implement a range of initiatives to ensure that the breeding management of laboratory animals and animal testing are properly conducted in consideration of animal welfare and scientific rationality.

Kyowa Kirin conducts proper animal testing and in-house inspection from the perspectives of animal welfare and scientific validity based on the 3Rs principles*. Furthermore, the Tokyo Research Park and Fuji Research park have maintained full certification from the Association for AAALAC International, a global third-party accreditation body, since 2014.

Approaches to Animal Experiments in Accordance with the Rule for Animal Experiments of Kyowa Kirin Co., Ltd. (in Japanese only)

Kyowa Kirin conducts proper animal testing and in-house inspection based on the Ministry of Health, Labour and Welfare’s guidelines and international guidelines. Furthermore, in November 2013, the Association for AAALAC International, a global third-party accreditation body, visited the Tokyo Research Park and Fuji Research Park to conduct surveys, and the two research sites obtained full certification in March 2014.

In creating pharmaceuticals, the Kyowa Kirin Group advances its own research by means of advanced technologies and unique perspectives while developing and providing high-quality products. As a representative life science company of Japan with firm foundations in biotechnology, we will continue to contribute to the health and lives of people around the world.
To use biotechnology techniques that show consideration for environmental and safety aspects, we are complying with the Act on the Conservation and Sustainable Use of Biological Diversity through Regulations on the Use of Living Modified Organisms (Cartagena Act) and, having put in place an internal committee, are managing the situation in an appropriate manner.
So that genetically recombined material is not released into the outside world, we are advancing measures designed to prevent environmental pollution by proper handling and being sure that such material has been inactivated prior to disposal.
To verify whether these initiatives are being implemented in an appropriate manner, we are performing regular monitoring activities at each business site. We are committed to ongoing risk minimization by sharing the results of these activities and any near-miss incidents that have occurred at business sites with the committee and applying them to countermeasures across business sites.

Kyowa Kirin Group has established regulations for dealing with misconduct in research activities, and is working to prevent misconduct in research activities.

Research and development (R&D) are the business foundation of the Kyowa Kirin Group, and therefore, intellectual property (IP) is an important business asset for us. For IP that is an essential part of our R&D and business strategies, we strive to maximize our product value through lifecycle management as well as acquire and maintain effective patent rights through strategic applications. At the same time, we endeavor to ensure freedom in our research and business activities while respecting the rights of other parties and promoting compliance so as not to infringe them, and we will respond promptly and appropriately to any IP dispute that may arise. We believe these activities contribute to maximizing the value of our global business activities, maximizing profits and minimizing risks, resulting in a stable supply of pharmaceuticals.

Intellectual Property Initiatives

In line with the United Nations Guiding Principles on Business and Human Rights, we recognize our responsibility to respect human rights. We have established policies on human rights and to communicate them not only to their own employees but also to a wide range of stakeholders. In the Kyowa Kirin Group, as we expand our business globally to achieve our 2030 vision, the number of our stakeholders has significantly increased, and the scope of 'business and human rights' has broadened. We have established a cross-organizational working team and, with advice from external experts, have formulated the "Kyowa Kirin Group Human Rights Policy" while deepening our understanding of the extensive human rights issues faced by global companies.
This policy applies not only to all executives and employees of our group but also to all individuals working in the value chain related to our group's business, products, and services, and we require compliance with this policy. Upholding one of our core values, "Integrity," and maintaining consistent honesty and ethics, we will continuously advance our human rights due diligence efforts based on this policy. We aim to create smiles for everyone working within our entire value chain.

Human Rights Policy Formulation Process

In July 2017, we established the Kyowa Kirin Group Human Rights Enlightenment Promotion Committee. This committee formulates, promotes, and supports plans for human rights enlightenment. The committee also provides support for investigations and cooperation for the prompt resolution of human rights issues, if and when they arise. The Committee is chaired by the Director of the Human Resources Department of the Company and consists of Directors of the relevant divisions and heads of the organizations in charge of human resources at major subsidiaries. Kyowa Kirin's Human Resources Department serves as the secretariat.
In daily operations, Kyowa Kirin's Human Resources Department oversees general matters concerning human rights, but as human rights issues are wide-ranging, the department conducts its initiatives in cooperation with other departments and Group companies. The status of compliance with all laws and regulations, including those related to human rights, is reported at the Compliance Committee (chaired by the Chief Compliance Officer), which meets twice a year, to check the effectiveness of our measures, and the result is reported to the Board of Directors.

As our business continues to expand globally, the impact of our activities on rights holders around the world is becoming increasingly more far-reaching.

We believe that the creation of Life‑Changing Value requires co‑creation with our stakeholders. Based on this belief, we are committed to respecting human rights as part of our corporate social responsibility, with due consideration not only for our employees but also for all people involved across our business partners and value chain.

In line with this approach, we have been implementing the following human rights due diligence initiatives since 2022.

Kyowa Kirin is endeavoring to ensure human rights throughout its pharmaceutical value chain.

Human rights considerations in research

Kyowa Kirin sets internal rules with the aim of assuring ethical and scientific validity in human genome analysis and research using human tissue as well as preventing the loss of dignity and protecting the human rights of tissue donors.

Safeguarding human rights in clinical trials

When conducting a clinical trial involving human subjects, Kyowa Kirin, pursuant to the Declaration of Helsinki, gives top priority to protecting the human rights and personal information of patients participating in the trial, securing their safety, and giving consideration to their welfare, and complies with the laws and regulations and Good Clinical Practices (GCP) guidelines of the applicable countries.

Ensuring human rights in purchasing activities

We have formulated the "Kyowa Kirin Group Procurement Policy" and the "Kyowa Kirin Group Supplier Code of Conduct" to help us ensure human rights throughout the supply chain in collaboration with our suppliers.

Quality assurance and a stable supply of products: Sustainable Procurement (Specific Initiatives)

Ensuring human rights in engaging with medical institutions and patient organizations

Pursuant to Kyowa Kirin Group Policy for the Promotion of Pharmaceuticals and Interactions with Healthcare Professionals, Healthcare Organizations and Patient Organizations, we act with high ethical standards and in the best interest of patients when we engage with medical institutions and patient organizations.

Kyowa Kirin International plc, an subsidiary of Kyowa Kirin with business operations in the United Kingdom, discloses information on its initiatives to address modern slavery risks in its business activities and supply chain in accordance with the UK Modern Slavery Act.

Guided by the Kyowa Kirin Group Code of Conduct, we respect the human rights of all individuals and do not tolerate any form of discrimination or harassment. In any violation of the Code of Conduct or other misconduct is identified, we will promptly investigate the facts and take appropriate measures. Such actions may include corrective measures, guidance, and disciplinary action for those involved, as the implementation of thorough measures to prevent recurrence.

We have an internal reporting contact in place, to which employees can turn when they face human rights issues. When a report is filed, Human Resources Department and the CSR Management Department investigate the facts and take appropriate measures while protecting the informant and the confidentiality of the report. Furthermore, we have also established various contacts for other issues (including harassment, mental health, disabilities, and LGBTQ issues) to support those who face them.

For whistleblowing through JaCER, information will be disclosed anonymously on JaCER's website on a regular basis.

JaCER whistleblower report form

Commitment to Respect for Human Rights

Guided by our Human Rights Policy, Our Group is committed to respecting human rights and embedding this commitment across all business activities. We promote organization-wide understanding through continuous education and awareness initiatives,reinforcing behavior at every level of the Group.

Monitoring Effectiveness and Continuous Improvement

In cooperation with the Kirin Group, we conduct an annual Compliance and Human Rights Awareness Survey. The survey enables us to monitor changes in employee awareness, identify emerging human rights risks and challenges, and reflect these insights in the continuous improvement of our initiatives.

Human Rights Education

We provide structured human rights education programs for executives and employees to strengthen their understanding.

Preventing Harassment and Promoting Respectful Workplaces

We recognize harassment as a material human rights issue and are committed to fostering safe, inclusive, and respectful workplaces.

Ongoing, Role-Based Education

In 2025, the number of lost-time injuries at the Kyowa Kirin Group was zero. The frequency rate^*2 and severity rate^*3 of occupational injuries were also both zero.

In September 2024, we implemented a safety culture assessment across the entire Kyowa Kirin Group in Japan. The results of this assessment, which was performed by an external consultant, indicated that the Group’s overall safety culture level had improved through voluntary initiatives at production and research sites compared to 2021, when the previous assessment was conducted. Going forward, the Group will continue to implement safety initiatives at each site, further enhancing the development of its safety culture.

Since 2007, Kyowa Kirin has been conducting safety management training for newly appointed managers, as stipulated by the Industrial Safety and Health Act. This training targets newly appointed managers of plants and research centers, annually providing programs that cover the Group’s occupational health and safety policy and safety education as well as specific methods of safety activities, among others. To date, a total of 668 managers have received the certification and are now taking the lead in promoting safety activities to help create an environment where employees can work in a secure place.

At the Fuji Site, an in-house safety application has been developed to enable the prompt reflection of on-site research conditions and researchers’ feedback into safety measures. Designed for ease of use by all employees, the application allows users to report unsafe conditions and near-miss incidents, as well as to record and share positive observations and good practices directly from the workplace. By visualizing daily observations, the initiative enhances safety awareness among each individual employee. Furthermore, by analyzing the accumulated data, trends in unsafe behaviors and hazardous conditions can be identified, contributing to the prevention of incidents before they occur. This initiative is being rolled out to other sites and is helping to foster a strong safety culture across the entire organization.

The Ube Plant conducted a risk experience training program using VR technology, aiming to raise individual employees’ sensitivity to danger. In addition to watching videos about tripping, slipping, and falling caused by smartphone use while walking, the technology allowed the users to experience these accidents in a more realistic way through physical sensations such as tilting, shaking, and impact synchronized with the videos.

Around 80 employees, including the plant manager, have experienced the physical feedback provided through the training, which has helped improve their safety awareness in their daily work. We proactively incorporate the latest technology and information into our safety programs, and continue to promote a strong safety culture.

At Tokyo Research Park, various training programs are conducted to prepare for unforeseen events such as disasters. By acquiring the correct knowledge and response skills, employees can increase their ability to protect their own lives as well as those of their colleagues. In first-aid training for cardiac arrest situations, more than 70 staff members—including the Head of the Research Park—participated and learned cardiopulmonary resuscitation (CPR), how to seek assistance from those nearby, and how to operate automated external defibrillators (AEDs).In addition, to enhance disaster preparedness awareness, participants experienced evacuation in a tent filled with artificial smoke, simulating conditions during a fire.

The Kyowa Kirin Group commends sites that have had no occupational or commuting-related accidents throughout the year with the Accident-Free Operations Award. In 2024, 10 out of 18 sites received the award. Each of the Group’s sites works to prevent accidents through consistent health and safety activities, contributing to stable daily operations.

Kyowa Kirin has an internal safety system to promote traffic safety, under which traffic accidents and violations by employees are analyzed and compiled as reference materials by the head office administrative department. Each sales office has designated Traffic Safety Promotion Committee members who promote traffic safety awareness while supporting Safe Drive Managers. The results of these activities are reported to the head office administrative department, which helps facilitate safe driving initiatives through mutual communication between the department and the offices.

Meanwhile, all leased company vehicles have been replaced with models equipped with an autonomous emergency braking system (AEBS). In addition, the fleet is transitioning to models featuring around-view monitors to help prevent accidents in parking lots and other locations. Furthermore, we require all drivers to undergo alcohol detection checks before and after work, thereby ensuring compliance with traffic laws and protecting employees.

We also commend sales offices that have had no accidents or violations throughout the year as Outstanding Offices in Traffic Safety. In 2025, 41 sales offices have been awarded the commendation nationwide.

Human Rights Due Diligence, Human Rights Considerations Across the Value Chain

Complaints and reports related to human rights (Whistleblower contact for a wide range of stakeholders)

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. Meanwhile, Facilitation Payments are prohibited under the Group Policy and Rule, even if permitted under the applicable laws, regulations, guidelines or relevant industry codes in the country where the Group company operates. Furthermore, acts of corruption includes economic crimes such as fraud and money laundering, and the Group has made it clear that we will not tolerate any form of misconduct.

The Code of Conduct has been translated into languages of the regions in which the Group conducts business and is disseminated across the entire Group together with the Group Policy. The Code of Conduct and the Group Policy are posted on internal and external websites so that they can be viewed by all employees in Japan and overseas.

Kyowa Kirin Group Code of Conduct

Kyowa Kirin’s Chief Compliance Officer (CCO) supervises the Group’s initiatives to prevent bribery and corruption. Under the CCO’s leadership, the Group Compliance Committee and its secretariat, the Compliance & Risk Management (CR) Department, play a central role in executing the initiatives with managers assigned to the task at each Group company. In addition, the audit unit, which is independent from the business execution lines, audits the activities undertaken to mitigate the risks associated with bribery and corruption. The results of these audits are reported to the Audit & Supervisory Committee members and the Chief Executive Officer (CEO). The Board of Directors oversees the status of implementation of the Code of Conduct and Global Policy including the prevention of bribery and corruption, and their revision is subject to approval of the Board of Directors.

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. We recognize that bribery and corruption poses risks that could impact our business management. As far as transferring value to healthcare professionals and others is concerned, we have established a pre-screening and approval process to ensure that an honorarium is set at fair market value and the provision of such benefits as food and beverages is in accordance with industry rules. In addition, we conduct regular risk assessments, and for subsidiaries and departments with a high risk of bribery and corruption, we put in place specific measures in our business plan and monitor progress of initiatives. The CR Department reports updates on risk management at periodic Group Risk Management Committee and Group Compliance Committee, checks its effectiveness, and reports the result to the Board of Directors.

In 2025, 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.

All executive 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 8 languages. In addition to the president's message and the contents of the Global Policy and internal regulations, the program includes social trends such as the latest case studies, legal and regulatory developments, and after completing the program, participants commit to comply with the rules. In 2025, 5,395 executives and employees participated in the program.

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.

The Group sets forth the Supplier Code of Conduct, which stipulates the actions and behavior that suppliers (including intermediaries) are expected to adhere to, including those concerning bribery and corruption. We hold briefing sessions for suppliers^*1 as an opportunity to regularly explain this "Supplier Code of Conduct" and other guidelines as a part of efforts to promote communication. We conduct 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^*2 and strive to reduce the risks related to bribery and corruption.

As a corporate group undertaking business that is deeply connected to people’s lives and health, the Kyowa Kirin Group must strive to engage in promotional activities by consistently upholding a high standard of ethics.

To articulate its commitment to ethical promotional activities, the Group has established the Kyowa Kirin Group Policy for the Promotion of Pharmaceuticals and Interactions with Healthcare Professionals, Healthcare Organizations and Patient Organizations in line with relevant laws and regulations of each country in which it conducts business, codes of conduct and guidance set by the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) and regional industry associations.

Kyowa Kirin provides information materials, including product information summaries for its pharmaceuticals, advertisements, patient materials, and disease-awareness materials related to those pharmaceuticals, only after confirming that they fully comply with relevant laws and regulations of applicable countries and standards established by industry associations.

In Japan, in response to the Guidelines on Sales Information Provision for Prescription Drugs set forth by the Ministry of Health, Labour and Welfare (hereinafter, "Guidelines")^*1, we have established a division overseeing sales information provision. Information materials are reviewed by multiple relevant divisions separate from the implementation division, as well as by the Information Materials Review Committee, which includes external third parties. In conducting the review, we confirm that the information materials are scientifically valid and comply with the JPMA Code of Practice, the preparation guidelines for product information summaries for prescription drugs, and social norms, thereby establishing a review system to ensure appropriate information provision.

Moreover, we have established a system to monitor whether our activities for providing sales information are being carried out appropriately and to provide necessary supervision and guidance.

Furthermore, we have in place a committee for supervising our sales information provision activities, whose members include third parties, to oversee and guide such activities. The supervisory department for information material review periodically reports to the committee and seeks advice.

Employee training is a key factor in ensuring ethical promotional activities.
Training is offered periodically to employees who create information materials and those who engage in promotional activities. Programs include in-person classes given by sales office managers and members of the Compliance & Risk Management Department, as well as online-based and e-learning courses.

An annual Compliance Promotion Month has been established, with all employees required to undergo a training program to learn about and better understand the JPMA code of practice. In the event of any violation of the rules, additional training is promptly conducted to prevent recurrence.

Information on tax payments by country, etc. (summary of Country-by-Country Reporting)