GUIDELINES FOR THE PREVENTION OF CORRUPTION/BRIBERY FOR SHIONOGI GROUP BUSINESS PARTNERS

With the cooperation of business partners, every SHIONOGI Group company strives to observe compliance such that no part of the SHIONOGI Group would ever participate in any act of corruption and/or bribery.

 

The “SHIONOGI Group Anti-Corruption/Anti-Bribery Policy” was enacted in April 2014 with a clear statement of our intention that no part of the SHIONOGI Group would ever participate in any act of corruption and/or bribery. Additionally, we have strived to help all of the SHIONOGI Group’s business partners to fully understand this policy, its intentions, and its underlying principles, and sought their cooperation in taking the steps and implementing the procedures necessary to prevent such acts.

 

According to the increasingly strict laws and penalties against corruption and/or bribery worldwide, SHIONOGI Group formulated the “Guidelines for the Prevention of Corruption/Bribery for SHIONOGI Group Business Partners,” which was prepared in accordance with the spirit of the Policy and outlined the compliance requirements to be observed by SHIONOGI Group’s business partners, in the hope of further strengthening our concrete management systems required for preventing any act of corruption and/or bribery.

 

We highly appreciate the understanding and cooperation of all SHIONOGI Group’s business partners with regard to the objectives of these Guidelines.

SHIONOGI Group shall carry out fair transactions through observing the SHIONOGI Group Anti-Corruption/Anti-Bribery Policy and all laws and regulations prohibiting corruption and/or bribery in any of the countries and regions in which SHIONOGI Group operates business.

All business partners that are involved in any of SHIONOGI Group’s business operations (hereinafter referred to as “Business Partners”) are asked to understand SHIONOGI Group’s principles and act in accordance with the Guidelines to prevent any act of corruption and/or bribery related to any transactions with SHIONOGI Group.

“Business Partners” in the Guidelines refer to members that are involved in SHIONOGI Group’s business operations including wholesalers, distributors, agents, licensors, licensees, intermediaries, consultants, joint venture partners, contractors, and suppliers.

Please note that the Guidelines may be revised at any time.

In dealing with SHIONOGI Group’s business operations, Business Partners shall not offer, request, or promise to offer any benefits such as money or any other initiatives (hereinafter referred to as “Bribery”) to the parties, including government officials and other third parties, or authorize any Bribery, irrespective of whether domestically or internationally, directly or indirectly. Meanwhile, Business Partners shall not receive, demand, or promise to receive any Bribery.

“Bribery” refers to money or any other value items or benefits provided, irrespective of pretext, for the purpose of obtaining or retaining business, or for an improper business advantage.

“Money or other value items or benefits” refer to those that satisfy one’s demands or desire, such as:

“Government officials” refer to any individual employed by or under contact with a government of any country, such as:

SHIONOGI Group may ask all Business Partners that are involved in SHIONOGI Group’s business operations to disclose the relevant information and materials related to the forms of transactions or business records regarding SHIONOGI Group’s business operations. Furthermore, SHIONOGI Group may conduct investigations or audits regarding the compliance status of the Guidelines and any applicable domestic or foreign laws and regulations prohibiting corruption and/or bribery. The full understanding and cooperation of Business Partners on this matter are appreciated.

Business Partners shall prepare and properly store accounting records that accurately and fairly reflect the payments and receipts related to SHIONOGI Group’s business operations.

Please immediately report to SHIONOGI Group in the case that any violation or suspected violation of the Guidelines or any applicable domestic or foreign laws and regulations prohibiting corruption and/or bribery related to SHIONOGI Group’s business operations is recognized, or any indications from related authorities are received.
Furthermore, Business Partners are asked to fully cooperate with investigations that may be carried out by SHIONOGI Group or related authorities with respect to such violations or suspected violations.

Business Partners shall disseminate the details and provide training on the Guidelines and any applicable domestic or foreign laws and regulations prohibiting corruption and/or bribery related to SHIONOGI Group’s business operations to the directors and employees of their own company, as well as to third parties such as subcontractors.

 

 

Established as of the 1st day of April, 2017