Seikagaku Corporation (“Seikagaku”) sees compliance as a fundamental principle for conducting corporate activities and defines compliance as “respecting ethics (social norms) and complying with laws and regulations, external standards, internal regulations and other rules in the conduct of business.” Based on this understanding, Seikagaku implements a Compliance Program, including a Compliance Code of Conduct and various compliance-related systems.

We (the Directors, Corporate Auditors, Executive Officers and Employees of Seikagaku Corporation (“SKK”) and its subsidiaries/group companies) shall conduct our respective corporate activities in compliance with this SKK Group Compliance Code of Conduct. “Employees” as used herein shall mean all employees, including full-time part-time, and temporary staff.

　1.    Basic Policy
　　　As a life-sciences company, we will always maintain the highest respect for the health and safety of our customers
　　　worldwide and display high corporate ethics that will earn the trust of our global customers, commercial partners and
　　　investors.
 

　2.    Business Activities
　　　We will research, develop, manufacture, and market pharmaceuticals, clinical diagnostic and laboratory reagents and
　　　other products that are safe, effective and useful for their intended purpose and of high quality (hereinafter referred
　　　to as "Pharmaceutical and Other Products"), and provide them in a professional manner with complete and accurate
　　   product information, all under the control of an appropriate Quality Management System.We shall also promote
　　　their proper use of our Pharmaceutical and Other Products.
 

　3.    Relationship with Patients, Consumers, Medical Professionals, Business Partners, etc.
　　　We will strive to improve mutual understanding and trust among patients, consumers, medical professionals,
　　　business partners, etc., and will maintain fair and balanced relationships.
 

　4.    Relationship with Shareholders and Investors
　　　We will strive to build honest and transparent relationships with our shareholders and investors through timely
　　　and complete communication and constructive dialogue.
 

　5.    Relationship with Employees, etc.
　　　We will respect the human rights and individuality of each Employee and will strive to maintain a safe and
　　　respectful work environment.
 

　6.    Relationship with Regulators and Government Entities
　　　We will appreciate the mission and responsibility of regulators and government entities, and maintain fair,
　　　transparent and healthy relationships with them.
 

　7.    Relationship with Global Environment and Civil Society
　　　We will value coexistence with society, engage voluntarily and actively in social contribution and global
　　　environmental conservation, contribute to the realization of a sustainable society, and act as a good corporate citizen.
 

　8.    Relationship with Company's Property and Information
　　　We will use the company’s property and information properly and manage personal and confidential information
　　　in an appropriate manner.

In other measures to promote compliance, Seikagaku provides internal training on specific compliance-related themes every fiscal year to constantly raise compliance awareness. In fiscal 2021,
Seikagaku made “Reaffirming the importance of compliance throughout the company and strengthening and putting into practice the compliance promotion structure” an action policy and engaged in compliance promotion activities centered on online training and e-learning.
 

*Overseas subsidiaries Associates of Cape Cod, Inc. and Dalton Chemical Laboratories, Inc. have developed their own compliance frameworks that conform to their local environments, laws, and regulations and have instituted a system of reporting important compliance-related incidents to Seikagaku following reporting to their respective boards of directors.

<Role of Compliance Promotion Committee>
The Compliance Promotion Committee is chaired by the President & CEO and made up of members of the Management Committee. The committee approves measures to promote compliance in accordance with the Compliance Program and supervises the status of their implementation.

<Role of Compliance Promotion Officers>
General managers of headquarter, general managers of labs and plants, and presidents of Seikagaku’s affiliates are appointed as Compliance Promotion Officers. They are responsible for implementing the Compliance Program in their respective divisions, carrying out self-inspections, and also implementing the resolutions of the Compliance Promotion Committee.

The Compliance Program is closely connected to appropriate business execution as well as maintenance of a worker-friendly workplace environment for employees.

In the interest of early detection of Compliance Program violations and suspected violations and the resolution of problems, Seikagaku has instituted hotline operation standards and has also set up a communications counseling system (male and female staff appointed at each business site) to respond to internal communication issues. Furthermore, by establishing multiple internal and external consultation contact points, such as utilization of an external whistleblowing channel, Seikagaku has put in place an environment that enables persons seeking advice to use the contact point that makes them feel most at ease, depending on the problems they face or individual circumstances.

Seikagaku has also put in place the necessary mechanisms to comply with the amended Whistleblower Protection Act, and have ensured that all employees are aware of the whistleblower system’s process and its importance.
 

[Protection of employees who seek advice and whistleblowers]
Seikagaku gives the highest priority to protecting the confidentiality and privacy of employees who seek advice and to whistleblowers. Information about employees who seek advice, whistleblowers, and those involved shall be disclosed on a need-to-know basis and their privacy and anonymity shall be protected. Seikagaku stipulates in its internal regulations that sufficient care must be taken to ensure that whistleblowers and those who have cooperated with investigations do not suffer any detriment as a result of speaking out.
 

In other measures to promote compliance, Seikagaku provides internal training on specific compliance-related themes every fiscal year to constantly raise compliance awareness. In fiscal 2021, Seikagaku made “Reaffirming the importance of compliance throughout the company and strengthening and putting into practice the compliance promotion structure” an action policy and engaged in compliance promotion activities centered on online training and e-learning.