GUIDELINES FOR THE PREVENTION OF CORRUPTION/BRIBERY FOR SHIONOGI BUSINESS PARTNERS
GUIDELINES FOR THE PREVENTION OF CORRUPTION/BRIBERY FOR SHIONOGI 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 formulated the “Guidelines for the Prevention of Corruption/Bribery for Shionogi Business Partners,” which was prepared in accordance with the spirit of the Policy and outlined the compliance requirements to be observed by Shionogi 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 business partners with regard to the objectives of these Guidelines.
Guidelines for the Prevention of Corruption/Bribery for Shionogi Business Partners
Purpose of the Guidelines
All business partners that are involved in any of SHIONOGI’s business operations (hereinafter referred to as “Business Partners”) are asked to understand SHIONOGI’s principles and act in accordance with the Guidelines to prevent any act of corruption and/or bribery related to any transactions with SHIONOGI.
“Business Partners” in the Guidelines refer to members that are involved in SHIONOGI’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.
Prohibition of corruption and/or 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:
- Money, cash vouchers, gift cards/coupons, unlisted shares, loans, mortgages, and guarantees
- Entertainments, feasts, gifts, free rent of houses and buildings, or intangible benefits such as compensation, sexual favors, and functional status
- National, regional, and local elected and appointed government officials, members of political parties and candidates for elective office, healthcare professionals employed by a government-owned or government-run entity, and those employed or engaged by a quasi-government entity (such as the World Health Organization or the United Nations).
Investigation and audit
Recording and record storage
Reporting and investigation of violation
Furthermore, Business Partners are asked to fully cooperate with investigations that may be carried out by SHIONOGI or related authorities with respect to such violations or suspected violations.
Dissemination and training
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’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