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Compliance

Compliance System

At Terumo, the Internal Control Committee, which is responsible for enacting the Internal Control System within the Terumo Group in accordance with the "Internal Control System Design Basic Policy" approved by the Board of Directors, shall deliberate and make decisions regarding important policies related to compliance, and regularly report the status of these activities to the Board of Directors and Audit/Supervisory Committee. The Chief Legal Officer (CLO) shall be the primary entity implementing the compliance system across the Terumo Group, and under the leadership of the CLO, promote a variety of measures by creating related rules, performing training and education, collecting employee oaths, and coordinating with the compliance officers of the Terumo Group companies who are in charge of promoting compliance related activities to quickly discover and ascertain problems. In the event that significant compliance violations, etc. occur, a handling team shall be immediately organized under the direction of the chairperson of the Internal Control Committee, and that team shall, in addition to handling and resolving the occurrence, report or make proposals to the Internal Control Committee regarding the cause and recurrence prevention measures.

Compliance with the Code of Conduct of the Terumo Group

Terumo's corporate mission, "Contributing to Society through Healthcare," is the goal not only of the company but of all associates who work for Terumo. We will continue to conduct honest and fair business practices based on strict legal compliance and corporate ethics in order to maintain our position as an ethical healthcare company.

To go further toward meeting these social expectations, we established the "Code of Conduct of the Terumo Group" in April 2008 to set standards for the conduct of daily business activities for the entire group, including overseas entities. In accordance with this Code, we are striving throughout the Terumo Group to base our actions on social ethics, as well as on compliance with relevant laws and regulations.

The Code of Conduct of the Terumo Group states that "Each Associate must conduct business activities honestly, take responsible action for environmental conservation and make consistent efforts to enable the company to become a role model reliable corporate citizen." We carry out training on the Code of Conduct tailored to each site and encourage associates to recognize the importance of corporate ethics. As a global company, we also clearly state and promote the need to respect human rights and eliminate discrimination in our Code of Conduct.

Appropriate Relationships with Public Officials

All Terumo associates observe the "Code of Conduct of the Terumo Group" and the "Terumo Group Global Anti-bribery Policy" in all dealings with public institutions, related officials and the employees of public medical institutions. These codes aim to ensure that all business is conducted in a transparent, fair, and honest manner. Full compliance is expected under Japan's Unfair Competition Prevention Act, the US Foreign Corrupt Practices Act, and other anti-bribery laws within the countries and regions where Terumo Group operates.

Prohibition of Collusion and Cartels

There have been many cases throughout the world in which collusion, action as a cartel, or other kinds of violations of competition laws have been uncovered and subjected to strict punishment. To help ensure that it does not contribute to such activities, Terumo established the Terumo Group Global Antitrust Policy in January 2015. In addition, the Terumo Group conducts cartel prevention e-Learning-based training for associates in Japan and overseas in a Group-wide effort to maintain free and fair competition.

Combating Anti-Social Forces

Avoiding relationships with anti-social forces is one of Terumo's corporate responsibilities. We, therefore, strictly refuse to become involved in any relationship with anti-social forces and engage in no transactions with companies, other organizations, or individuals with ties to anti-social forces. Furthermore, we work with law enforcement authorities and other agencies to combat anti-social forces.

Status of Efforts to Combat Anti-Social Forces

  • The General Affairs Department coordinates responses to inappropriate demands by anti-social forces, and the prevention of such inappropriate demands has been made the specific responsibility of a designated associate within the General Affairs Department.
  • We have established a system for cooperating with law enforcement authorities, Tokubouren (NPO assisting companies in combating corporate blackmailers), legal advisers, and others, and acting on their advice and guidance.
  • We have established a system for properly sharing information on anti-social forces with the groups mentioned above, and centrally managing it in the General Affairs Department.
  • We have prepared the Manual for Combating Anti-Social Forces and are promoting thorough understanding of its contents among everyone working at Terumo.
  • We provide executives and associates with relevant information in a timely manner, conduct training, and take the steps, as well, to promote awareness of the importance of combating anti-social forces.

Whistle-blowing system

Terumo builds and operates a whistle-blowing system in which Group Employees can, upon discovering compliance violations, etc., can report problems out of their usual line of authority and have the assurance that employees making reports will not be treated disadvantageously. Further, the divisions operating the whistle-blowing system shall report on its status to the Audit/Supervisory Committee as necessary.

Abiding by Industry Rules

Terumo abides by the Fair Competition Code, Code of Practice, Promotion Code, and other industrial regulations to ensure that it follows appropriate promotion practices for medical devices and pharmaceuticals. We have also established the Terumo Code of Practice and conduct continuous in-house education for associates in order to promote awareness and thorough understanding of compliance. Going forward, we will continue to abide by these guidelines and practices.

Making the Relationship between Corporate Activities and Medical Institutions Transparent

To communicate Terumo's contribution to life science and the high ethical standards with which we conduct our business activities, we formulated our "Transparency Guideline for the Relationships between Corporate Activities and Medical Institutions" and "Transparency Guideline for the Relationships between Corporate Activities and Patient Organizations."


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