I. Preamble (Purpose)

Shionogi & Co., Ltd. (“Shionogi”) is globalizing its corporate policy as it expands its operations into additional countries. The company’s diverse international activities should function as an integrated whole (the “Shionogi Group”). The Shionogi Group must operate in a controlled, ethical and compliant manner.
Therefore, Shionogi hereby declares its compliance policy.

II. Compliance in Shionogi Group

Compliance in the Shionogi Group does not mean only compliance with Laws, Rules and/or Regulations but also with Social Standards as well as Ethical Behavior.
Concept Chart

III. Promotion of Compliance in Shionogi Group

Shionogi faithfully promote compliance in the Shionogi Group having in mind and through the following:


  • a. Shionogi becomes a company respected from the society.
  • b. The employees who are the constituent members of Shionogi Group also act in an ethically appropriate way.
  • c. The employees of Shionogi Group will take the ways and steps to make a right judgment and take a right action in securing compliance as described in section V (Approaches to Secure Compliance).
  • d. Every group company develops and maintains its own compliance handbook, code of conducts or the like respecting and reflecting the spirit and concept of this compliance policy and considering the social, regulatory and legal situation surrounding the group company.

IV. Policy Statements

Shionogi’s compliance policy is constituted of 2 Fundamentals & 5 Essentials.

a. Fundamentals

1.Integrity based on Ethics (Essential Aspect for Global Operation for a Life Science Company):
Shionogi regards integrity of the company based upon ethics as the essential and most important element to continue to grow further as a global enterprise in the life science industry, and make continued efforts to maintain and improve it.
2.Behavior of Individuals (Foundation of Compliance):

Shionogi recognizes that behavior of its individual members is the foundation of compliance and directs them to take appropriate actions at all times.


b. Essentials

1.Compliance with Laws and Rules (Basis of Compliance):
Shionogi observes all laws and rules relevant to its operations and business activities.
2.Assurance of Quality (Basis of Reliance and Safety):
Shionogi sets forth and complies with the quality standards‚ quality control rules and standard operating procedures that are globally acceptable to assure the quality of its products and the services associated therewith.
3.Fair Dealing and Fair Competition (Practices of Reliance):
Shionogi, in its operations and business activities, deals with customers and suppliers appropriately and fairly competes with competitors.
4.Proper Disclosure and Proper Handling of Information (Basis of Trust):
Shionogi recognizes that the accuracy of information it discloses is the basis of trust by all stakeholders including communities, and makes proper disclosure thereof. Shionogi recognizes that information is one of the critical business assets and handles its own proprietary information as well as the proprietary information of others appropriately.
5.Security of Sound Workplace (Ban on Discrimination and Respect of Diversity):
Shionogi respects the human rights and diversity of its members and eliminates any discrimination in any manner, and secures and maintains for its members the work environment appropriate to perform their duties.
Concept Image

V. Approaches to Secure Compliance

The ways and steps for Shionogi Group members to make a right judgment and take a right action in securing compliance are shown below:

a. Self Assessment

As a first step, stop and think for yourself! When you are about to do something, or when you see someone in Shionogi about to do something, ask yourself the 5 questions below if you are in doubt as to whether it would be an ethical thing to do. 5 questions to ask yourself the following:
  1. 1
    If you have doubts about whether this “something” is something right to do, would you go ahead and do it anyway (because it’s just one of those things that needs to get done) or let others go ahead and do it anyway (and overlook what they’re doing)?
  2. 2
    If you do this “something”, wouldn’t that be going against your conscience?
  3. 3
    Can you tell your family about this “something” in good conscience?
  4. 4
    If you see other people doing this “something”, how would you feel?
  5. 5
    Wouldn’t this “something” cause embarrassment for Shionogi?

b. Consultation with Supervisors/Managers (Superiors)

Second, members should consult with supervisors/managers (superiors) when self assessment is difficult or inappropriate.

c. Consultation with Experts and/or Department/Section in Charge

Members should consult with experts and/or department/section in charge (i.e. Legal Dept., Human Resources Dept. or others as appropriate) when self assessment is difficult or inappropriate and/or consultation with supervisors/managers (superiors) is not sufficient.


Established as of April, 1, 2012