ComplianceHandbook

2021.04

Ⅰ. St atement
Contents
Ⅰ.Statement・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・2
Ⅱ.Top Message ・・・・・・・・・・・・・・・・・・・・・・・・・・・・3
Ⅲ.JCR Compliance Policy・・・・・・・・・・・・・・・・・5

3.Fair Trading and Competition⑫Commitment to Fair Trading and Competition ・・・18⑬Prohibition of Unfair Competition ・・・・・・・・・・・・・・19⑭Entertainment and Gifts・・・・・・・・・・・・・・・・・・・・・・20⑮Prohibition of Corruption and Bribery ・・・・・・・・・・21

4.Business Activities
1.Human Rights and Workplace Environment①Respect for Human Rights・・・・・・・・・・・・・・・・・・・・・7②Prohibition of Harassment ・・・・・・・・・・・・・・・・・・・・・8③Equal Employment Opportunities・・・・・・・・・・・・・・・9④Health and Safety of Workplaces ・・・・・・・・・・・・・・10⑤Safety and Disaster Readiness ・・・・・・・・・・・・・・・・11⑯Drug Discovery Research ・・・・・・・・・・・・・・・・・・・・22⑰Export and Import ・・・・・・・・・・・・・・・・・・・・・・・・・・23⑱Clinical Development ・・・・・・・・・・・・・・・・・・・・・・・・24⑲Product Quality・・・・・・・・・・・・・・・・・・・・・・・・・・・・・25㉑Promotion Activities ・・・・・・・・・・・・・・・・・・・・・・・・・27㉒Evaluation of Business Partners・・・・・・・・・・・・・・・28⑥Disclosure of Corporate Information・・・・・・・・・・・・12

5.Information Management⑦Tax Payments・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・13㉓Respect for Intellectual Property ・・・・・・・・・・・・・・29⑧Response to Criminal Organizations ・・・・・・・・・・・14㉔Handling of Confidential Information ・・・・・・・・・・・30⑨Prohibition of Conflicts of Interest・・・・・・・・・・・・・・15㉕Use of Communication Channels・・・・・・・・・・・・・・31⑪Conserving the Environment・・・・・・・・・・・・・・・・・・17

Contributing towards human healthcare
through pharmaceutical products.
Core Values

Reliability

We strive to establish
a reliable company for all
stakeholders by actions withhigh sense of duty inaddition to compliance.

⑳Management of Information Related to・・・・・・・・・26
Product Efficacy, Safety, and Quality

2.Responsibility to Society and Stakeholders⑩Contributing to Society・・・・・・・・・・・・・・・・・・・・・・・16

Corporate Philosophy㉖Prohibition of Insider Trading ・・・・・・・・・・・・・・・・・32㉗Handling of Personal Information・・・・・・・・・・・・・・33

Conﬁdence

We take a unique approachin advancing our researchand development andprovide high-quality
products and information
with conﬁdence in the aim ofproviding world-classpharmaceuticals.

Belief

We aim for further corporate
growth in the belief of“Think by oneself,
Act by oneself”
under the basic philosophy.

Importance of Compliance
JCR's mission is to deliver therapeutic drugs to patients worldwide suffer from a variety of diseases
through the development of proprietary technologies and creation of innovative products. Motivated bythese challenges, we must continue our business activities for the sake of patients waiting fortherapeutic drugs.
We define compliance as: “All of the Company’s executives and employees acting in accordance withlaws and regulations (including rules, guidelines, voluntary industry standards, JCR’s corporate
philosophy and internal rules, etc.) with an ethical spirit for the Company to fulfill its social mission, meetthe demands of society, realize sound, sincere management, and achieve sustainable development.”
Let us strive to develop and maintain a corporate culture that fosters a high sense of ethics and a sound,high-quality enterprise system and to fulfill our social responsibilities by properly restraining ourselves
and our organization, and seeking for continued improvements and growth day by day.

What is most important in promoting compliance?

About This Handbook
This handbook is provided to all JCR executives and employees of JCR Pharmaceuticals Co., Ltd. andits group companies (“Company” or “JCR”) for use in conducting our business in Japan and worldwide.
Each and every one of us is requested to understand the content of this handbook and put it into
practice daily. When compliance-related problems arise in a workplace, they should be resolved at theworkplace in principle. However, when you feel it difficult to consult or speak up at your workplace, youare encouraged to consult with the hotline desk rather than remaining alone and silent. The hotline deskshall handle all cases in a manner that strictly respects the confidentiality of each individual.

1

It is most important not to turn a blind eye when you encounter situations where you have doubts aboutcompliance related issues. In recent years, the media has reported a series of corporate scandals
showing that a single violation of compliance could threaten the continued existence of ourCompany. We will neither hide our problems, nor try to turn them into a personal responsibility, but shallwork together to resolve them. While there is a tendency to forget about such doubts in the course of
our busy daily operations, we should constantly review what we are doing, what we have done, andwhat we are trying to do in the future from the perspective of "creating a sincere team at JCR." By
resolving problem whenever they arise, we shall realize our vision for the Company. This ComplianceHandbook will serve as our compass for this purpose.

2

Ⅰ. St atement
Contents
Ⅰ.Statement・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・2
Ⅱ.Top Message ・・・・・・・・・・・・・・・・・・・・・・・・・・・・3
Ⅲ.JCR Compliance Policy・・・・・・・・・・・・・・・・・5

3.Fair Trading and Competition⑫Commitment to Fair Trading and Competition ・・・18⑬Prohibition of Unfair Competition ・・・・・・・・・・・・・・19⑭Entertainment and Gifts・・・・・・・・・・・・・・・・・・・・・・20⑮Prohibition of Corruption and Bribery ・・・・・・・・・・21

4.Business Activities
1.Human Rights and Workplace Environment①Respect for Human Rights・・・・・・・・・・・・・・・・・・・・・7②Prohibition of Harassment ・・・・・・・・・・・・・・・・・・・・・8③Equal Employment Opportunities・・・・・・・・・・・・・・・9④Health and Safety of Workplaces ・・・・・・・・・・・・・・10⑤Safety and Disaster Readiness ・・・・・・・・・・・・・・・・11⑯Drug Discovery Research ・・・・・・・・・・・・・・・・・・・・22⑰Export and Import ・・・・・・・・・・・・・・・・・・・・・・・・・・23⑱Clinical Development ・・・・・・・・・・・・・・・・・・・・・・・・24⑲Product Quality・・・・・・・・・・・・・・・・・・・・・・・・・・・・・25㉑Promotion Activities ・・・・・・・・・・・・・・・・・・・・・・・・・27㉒Evaluation of Business Partners・・・・・・・・・・・・・・・28⑥Disclosure of Corporate Information・・・・・・・・・・・・12

5.Information Management⑦Tax Payments・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・13㉓Respect for Intellectual Property ・・・・・・・・・・・・・・29⑧Response to Anti-Social Force ・・・・・・・・・・・・・・・・14㉔Handling of Confidential Information ・・・・・・・・・・・30⑨Prohibition of Conflicts of Interest・・・・・・・・・・・・・・15㉕Use of Communication Channels・・・・・・・・・・・・・・31⑪Conserving the Environment・・・・・・・・・・・・・・・・・・17

Contributing towards human healthcare
through pharmaceutical products.
Core Values

Reliability

We strive to establish
a reliable company for all
stakeholders by actions withhigh sense of duty inaddition to compliance.

⑳Management of Information Related to・・・・・・・・・26
Product Efficacy, Safety, and Quality

2.Responsibility to Society and Stakeholders⑩Contributing to Society・・・・・・・・・・・・・・・・・・・・・・・16

Corporate Philosophy㉖Prohibition of Insider Trading ・・・・・・・・・・・・・・・・・32㉗Handling of Personal Information・・・・・・・・・・・・・・33

Conﬁdence

We take a unique approachin advancing our researchand development andprovide high-quality
products and information
with conﬁdence in the aim ofproviding world-classpharmaceuticals.

Belief

We aim for further corporate
growth in the belief of“Think by oneself,
Act by oneself”
under the basic philosophy.

Importance of Compliance
JCR's mission is to deliver therapeutic drugs to patients worldwide suffer from a variety of diseases
through the development of proprietary technologies and creation of innovative products. Motivated bythese challenges, we must continue our business activities for the sake of patients waiting fortherapeutic drugs.
We define compliance as: “All of the Company’s executives and employees acting in accordance withlaws and regulations (including rules, guidelines, voluntary industry standards, JCR’s corporate
philosophy and internal rules, etc.) with an ethical spirit for the Company to fulfill its social mission, meetthe demands of society, realize sound, sincere management, and achieve sustainable development.”
Let us strive to develop and maintain a corporate culture that fosters a high sense of ethics and a sound,high-quality enterprise system and to fulfill our social responsibilities by properly restraining ourselves
and our organization, and seeking for continued improvements and growth day by day.

What is most important in promoting compliance?

About This Handbook
This handbook is provided to all JCR executives and employees of JCR Pharmaceuticals Co., Ltd. andits group companies (“Company” or “JCR”) for use in conducting our business in Japan and worldwide.
Each and every one of us is requested to understand the content of this handbook and put it into
practice daily. When compliance-related problems arise in a workplace, they should be resolved at theworkplace in principle. However, when you feel it difficult to consult or speak up at your workplace, youare encouraged to consult with the hotline desk rather than remaining alone and silent. The hotline deskshall handle all cases in a manner that strictly respects the confidentiality of each individual.

1

It is most important not to turn a blind eye when you encounter situations where you have doubts aboutcompliance related issues. In recent years, the media has reported a series of corporate scandals
showing that a single violation of compliance could threaten the continued existence of ourCompany. We will neither hide our problems, nor try to turn them into a personal responsibility, but shallwork together to resolve them. While there is a tendency to forget about such doubts in the course of
our busy daily operations, we should constantly review what we are doing, what we have done, andwhat we are trying to do in the future from the perspective of "creating a sincere team at JCR." By
resolving problem whenever they arise, we shall realize our vision for the Company. This ComplianceHandbook will serve as our compass for this purpose.

2

Ⅱ.Top Me s s age

Message from CEO

Message from
Chief Compliance Oﬃcer (CCO)

What do you think about compliance? Do you have a strong awareness that even in your daily life, as amember of JCR engaged in life-related businesses, there are rules that you must observe as members ofsociety? Based on our Corporate Philosophy of "contributing towards people’s healthcare throughpharmaceutical products," our mission is to continuously devote our energetic efforts to research anddevelopment for patients awaiting therapeutic drugs and maintain a high level of quality for drugs

developed over a long period of time, produce drugs in a specified manner, and deliver them without

fail to patients who need them. In all of these processes, no compromise can be tolerated, and we must
conduct our business in accordance with extremely high ethical standards, laws and regulations

applicable to pharmaceuticals, regenerative medicine products and medical devices, corporate ethics,

and corporate regulations. For this reason, it is very important for all employees to understand this. In
particular, managers should always consider how to avoid problems and how to deal with them when
they arise. Our business depends on the trust of patients and society. If you have any questions or
doubts in your daily work, go back to the “Corporate Philosophy” and “The Standard for JCR

Compliance Behavior.” To ensure that we remain a company that will continue to be trusted and growsustainably in the future, please read this Compliance Handbook carefully so that you can fully
understand and act correctly, by understanding not only its text but also its purpose.

April 2022

Shin Ashida

Representative Director, Chairman, President and CEO

I believe that all employees are fully aware of the importance of compliance. One of JCR's management
policies is " Management Following Laws and Internal Rules based on Social Commonsense". Althoughcompliance is a simple word and easy to understand at first glance, it is not easy to actually understand andfollow it while conducting business. The laws, regulations, and guidelines that pertain to our businesscover a wide range of areas, and are revised and becoming complicated every year. Furthermore, whilein the past it was sufficient to be aware only of domestic laws and regulations, the scope of compliance thatmust be covered is now extending to global (multi-regional and multi-lingual) as it literally shows, with
globalization of our business. It is no longer sufficient to just keep compliance in the back of our mind as
we go about our work; we must constantly check relevant laws, guidelines, and SOPs.
In FY2021, a number of compliance issues by pharmaceutical companies were reported. Some of them
resulted in a transfer of business license to 3rd party or a long-term suspension of
manufacturing/marketing. In many cases, third-party committee reports were disclosed to the public.
After reading them, I strongly feel that there were few cases of fraud based on pure malicious intent, andthat many of the fraudulent procedures and decisions were made out of a desire to avoid shortage of
products or inconveniencing patients in the clinical practices. For a moment, it may seem
"understandable," but the measures taken are serious and not excusable, such as ignoring procedures anddouble recording, which may invalidate the company's quality system itself.
What I would like to ask you all to do to prevent such incidents from occurring in JCR is to "cultivate aworkplace culture in which it is easy to ask for advice”. I would like to ask you to create a highly
transparent workplace culture in which people can voice their opinions, such as "This sounds strange,""Should it be like this?", or "This must be wrong," and their superiors can take such opinions seriously anddiscuss them. In such an environment, I hope that each of you will carefully read the regulations and SOPs
and promote highly law-abiding business operations. Let's work together to open up the future.
April 2022

Yoshio Hiyama

Senior Executive Director and CCO

34

Ⅱ.Top Me s s age

Message from CEO

Message from
Chief Compliance Oﬃcer (CCO)

What do you think about compliance? Do you have a strong awareness that even in your daily life, as amember of JCR engaged in life-related businesses, there are rules that you must observe as members ofsociety? Based on our Corporate Philosophy of "contributing towards people’s healthcare throughpharmaceutical products," our mission is to continuously devote our energetic efforts to research anddevelopment for patients awaiting therapeutic drugs and maintain a high level of quality for drugs

developed over a long period of time, produce drugs in a specified manner, and deliver them without

fail to patients who need them. In all of these processes, no compromise can be tolerated, and we must
conduct our business in accordance with extremely high ethical standards, laws and regulations

applicable to pharmaceuticals, regenerative medicine products and medical devices, corporate ethics,

and corporate regulations. For this reason, it is very important for all employees to understand this. In
particular, managers should always consider how to avoid problems and how to deal with them when
they arise. Our business depends on the trust of patients and society. If you have any questions or
doubts in your daily work, go back to the “Corporate Philosophy” and “The Standard for JCR

Compliance Behavior.” To ensure that we remain a company that will continue to be trusted and growsustainably in the future, please read this Compliance Handbook carefully so that you can fully
understand and act correctly, by understanding not only its text but also its purpose.

April 2022

Shin Ashida

Representative Director, Chairman, President and CEO

I believe that all employees are fully aware of the importance of compliance. One of JCR's management
policies is " Management Following Laws and Internal Rules based on Social Commonsense". Althoughcompliance is a simple word and easy to understand at first glance, it is not easy to actually understand andfollow it while conducting business. The laws, regulations, and guidelines that pertain to our businesscover a wide range of areas, and are revised and becoming complicated every year. Furthermore, whilein the past it was sufficient to be aware only of domestic laws and regulations, the scope of compliance thatmust be covered is now extending to global (multi-regional and multi-lingual) as it literally shows, with
globalization of our business. It is no longer sufficient to just keep compliance in the back of our mind as
we go about our work; we must constantly check relevant laws, guidelines, and SOPs.
In FY2021, a number of compliance issues by pharmaceutical companies were reported. Some of them
resulted in a transfer of business license to 3rd party or a long-term suspension of
manufacturing/marketing. In many cases, third-party committee reports were disclosed to the public.
After reading them, I strongly feel that there were few cases of fraud based on pure malicious intent, andthat many of the fraudulent procedures and decisions were made out of a desire to avoid shortage of
products or inconveniencing patients in the clinical practices. For a moment, it may seem
"understandable," but the measures taken are serious and not excusable, such as ignoring procedures anddouble recording, which may invalidate the company's quality system itself.
What I would like to ask you all to do to prevent such incidents from occurring in JCR is to "cultivate aworkplace culture in which it is easy to ask for advice”. I would like to ask you to create a highly
transparent workplace culture in which people can voice their opinions, such as "This sounds strange,""Should it be like this?", or "This must be wrong," and their superiors can take such opinions seriously anddiscuss them. In such an environment, I hope that each of you will carefully read the regulations and SOPs
and promote highly law-abiding business operations. Let's work together to open up the future.
April 2022

Yoshio Hiyama

Senior Executive Director and CCO

34

Ⅲ.JCR Compliance Policy
1. Human Rights and Workplace Environment
1

Respect for
Human Rights

We always protect the human rights of every person involved in our businessactivities and respect the dignity and worth of each individual.

16

We do not tolerate acts of harassment in any form (including sexual harassment,harassment associated with pregnancy, childbirth and childcare, elderly careand the like, and workplace bullying).

We actively pursue research activities in accordance with relevant laws,
regulations, and internal rules aiming to eradicate diseases, improve the qualityof human health and daily lives, and contribute to the future of healthcare.

2

Prohibition ofHarassment

Drug Discovery
Research

17 Export and Import3

Equal Employment
Opportunities

We hire and evaluate our employees fairly based on their ability, aptitude andmotivation. We do not tolerate any form of discrimination on the grounds of
ethnicity, origin, gender, etc.

We implement appropriate export and import procedures in compliance with
export- and import-related laws, regulations, international treaties, and otherarrangements.

Health and Safetyof Workplaces

We comply with laws and regulations related to occupational health and safety,
as we strive to maintain and improve our workplace environments so ouremployees can work safely and even more comfortably and productively.

ClinicalDevelopment

In course of conducting clinical trials, we respect the human rights of clinical
trial subjects and secure their safety, along with ensuring the quality andreliability of data, in accordance with relevant laws, regulations, and internal
rules.

Safety and Disaster
Readiness

We will implement various measures to prevent accidents such as fires. If there
is a disaster, we will act rapidly and effectively to stop the spread of the disasterin accordance with operating procedures and manuals on disaster mitigation
measures established for each business site.

19 Product Quality

Our top priority is to steadily supply high-quality products with an emphasis on
efficacy and safety to patients around the world. We provide a timely andappropriate supply of products in accordance with relevant laws, regulations,and internal rules.

45

2. Responsibility to Society and Stakeholders
Disclosure of
6 Corporate
Information

We provide timely and accurate disclosure of corporate information on matterssuch as management policies and the status of business activities inaccordance with relevant laws and regulations. In addition, we listen closely tothe requests and opinions we receive from society and reflect such feedback inour business activities.

7

Tax Payments

We comply with tax laws and regulations applicable in the countries where we
operate and pay taxes appropriately.

8

Response to
Criminal Organizations

We never have relationships with criminal organizations or groups andresolutely stand up to such entities.

Prohibition of
9
Conflicts of Interest

We never use our positions in the Company or any information obtained in thecourse of our duties for personal gain or commit any acts conflicting with theinterests of the Company.

Contributing toSociety

We remain aware of our role as a good corporate citizen as we seek to realize asustainable society. With this in mind, we actively interact with society andconduct activities that contribute to society.

Conserving theEnvironment

We always remain mindful of how we impact the global environment and local
communities as we conduct our business activities, contribute to thesustainable development of society, and fulfill our responsibilities to future
generations.

1011

3. Fair Trading and Competition
Commitment to Fair
12
Trading and Competition

5

4. Business Activities

18

Management of Information

20 Related to Product Efficacy,

Safety, and Quality

21

Promotion
Activities

When providing medical or pharmaceutical information to healthcare
professionals, we provide, gather, and communicate accurate information
based on solid medical and pharmaceutical evidence in accordance with
relevant laws, regulations, our industry’s Code of Practice, and internal rules.

22

Evaluation ofBusiness Partners

We are required to appropriately evaluate suppliers and other third parties withwhom we trade.

5. Information Management
23

Unfair Competition

We do not engage in the unauthorized acquisition or use of the trade secrets ofother companies or act in a manner which would impair the business reputationof other companies.

14

Entertainment
and Gifts

We maintain sound and fair relationships with our suppliers and other business
partners, without providing or receiving entertainment or gifts in excess of
accepted social norms and comply with relevant laws and regulations.

15

Prohibition of
Corruption and Bribery

We are aware that we are subject to regulations stipulated by publicorganizations and are required to establish proper relationships with publicorganizations.

Respect forIntellectual Property

Recognizing that intellectual property is an important asset of the Company, wetake appropriate steps to protect our intellectual property. In addition, we
respect the intellectual property rights of others and will not engage ininfringement or unauthorized usage.

Handling ofInformation

We recognize that confidential information, such as non-public information,
know-how and customer information, is an important asset of the Company.
Therefore, we use and control such confidential information appropriately inaccordance with relevant laws, regulations, and internal rules.

Use ofCommunication Channels

We take responsibility for the outcome and impact on social reputation arisingfrom the use of communication channels, including social media, regardless ofwhether it is for business or personal use.

24 Confidential

25

26 Prohibition of

Insider Trading

We conduct fair and legitimate corporate activities in compliance with laws andregulations for maintaining competition and fair trading in the market.

13 Prohibition of

We provide timely and accurate information related to product efficacy, safety,
and quality in accordance with relevant laws, regulations, and internal rules withthe aim of ensuring proper use of the products manufactured and sold by theCompany.

27

Handling of Personal
Information

We do not commit acts that violate insider trading regulations or acts that could
be suspected of violating such regulations.
To protect the interests of individuals, we appropriately handle the personal
information of customers, patients, clinical trial subjects, donors of human cells,
tissue and other biological samples, shareholders, and employees inaccordance with relevant laws, regulations, and internal rules.

6Ⅲ.JCR Compliance Policy
1. Human Rights and Workplace Environment
1

Respect for
Human Rights

We always protect the human rights of every person involved in our businessactivities and respect the dignity and worth of each individual.

16

We do not tolerate acts of harassment in any form (including sexual harassment,harassment associated with pregnancy, childbirth and childcare, elderly careand the like, and workplace bullying).

We actively pursue research activities in accordance with relevant laws,
regulations, and internal rules aiming to eradicate diseases, improve the qualityof human health and daily lives, and contribute to the future of healthcare.

2

Prohibition ofHarassment

Drug Discovery
Research

17 Export and Import3

Equal Employment
Opportunities

We hire and evaluate our employees fairly based on their ability, aptitude andmotivation. We do not tolerate any form of discrimination on the grounds of
ethnicity, origin, gender, etc.

We implement appropriate export and import procedures in compliance with
export- and import-related laws, regulations, international treaties, and otherarrangements.

Health and Safetyof Workplaces

We comply with laws and regulations related to occupational health and safety,
as we strive to maintain and improve our workplace environments so ouremployees can work safely and even more comfortably and productively.

ClinicalDevelopment

In course of conducting clinical trials, we respect the human rights of clinical
trial subjects and secure their safety, along with ensuring the quality andreliability of data, in accordance with relevant laws, regulations, and internal
rules.

Safety and Disaster
Readiness

We will implement various measures to prevent accidents such as fires. If there
is a disaster, we will act rapidly and effectively to stop the spread of the disasterin accordance with operating procedures and manuals on disaster mitigation
measures established for each business site.

19 Product Quality

Our top priority is to steadily supply high-quality products with an emphasis on
efficacy and safety to patients around the world. We provide a timely andappropriate supply of products in accordance with relevant laws, regulations,and internal rules.

45

2. Responsibility to Society and Stakeholders
Disclosure of
6 Corporate
Information

We provide timely and accurate disclosure of corporate information on matterssuch as management policies and the status of business activities inaccordance with relevant laws and regulations. In addition, we listen closely tothe requests and opinions we receive from society and reflect such feedback inour business activities.

7

Tax Payments

We comply with tax laws and regulations applicable in the countries where we
operate and pay taxes appropriately.

8

Response to
Anti-Social Forces

We never have relationships with anti-social forces or groups and resolutely
stand up to such entities.

Prohibition of
9
Conflicts of Interest

We never use our positions in the Company or any information obtained in thecourse of our duties for personal gain or commit any acts conflicting with theinterests of the Company.

Contributing toSociety

We remain aware of our role as a good corporate citizen as we seek to realize asustainable society. With this in mind, we actively interact with society andconduct activities that contribute to society.

Conserving theEnvironment

We always remain mindful of how we impact the global environment and local
communities as we conduct our business activities, contribute to thesustainable development of society, and fulfill our responsibilities to future
generations.

1011

3. Fair Trading and Competition
Commitment to Fair
12
Trading and Competition

5

4. Business Activities

18

Management of Information

20 Related to Product Efficacy,

Safety, and Quality

21

Promotion
Activities

When providing medical or pharmaceutical information to healthcare
professionals, we provide, gather, and communicate accurate information
based on solid medical and pharmaceutical evidence in accordance with
relevant laws, regulations, our industry’s Code of Practice, and internal rules.

22

Evaluation ofBusiness Partners

We are required to appropriately evaluate suppliers and other third parties withwhom we trade.

5. Information Management
23

Unfair Competition

We do not engage in the unauthorized acquisition or use of the trade secrets ofother companies or act in a manner which would impair the business reputationof other companies.

14

Entertainment
and Gifts

We maintain sound and fair relationships with our suppliers and other business
partners, without providing or receiving entertainment or gifts in excess of
accepted social norms and comply with relevant laws and regulations.

15

Prohibition of
Corruption and Bribery

We are aware that we are subject to regulations stipulated by publicorganizations and are required to establish proper relationships with publicorganizations.

Respect forIntellectual Property

Recognizing that intellectual property is an important asset of the Company, wetake appropriate steps to protect our intellectual property. In addition, we
respect the intellectual property rights of others and will not engage ininfringement or unauthorized usage.

Handling ofInformation

We recognize that confidential information, such as non-public information,
know-how and customer information, is an important asset of the Company.
Therefore, we use and control such confidential information appropriately inaccordance with relevant laws, regulations, and internal rules.

Use ofCommunication Channels

We take responsibility for the outcome and impact on social reputation arisingfrom the use of communication channels, including social media, regardless ofwhether it is for business or personal use.

24 Confidential

25

26 Prohibition of

Insider Trading

We conduct fair and legitimate corporate activities in compliance with laws andregulations for maintaining competition and fair trading in the market.

13 Prohibition of

We provide timely and accurate information related to product efficacy, safety,
and quality in accordance with relevant laws, regulations, and internal rules withthe aim of ensuring proper use of the products manufactured and sold by theCompany.

27

Handling of Personal
Information

We do not commit acts that violate insider trading regulations or acts that could
be suspected of violating such regulations.
To protect the interests of individuals, we appropriately handle the personal
information of customers, patients, clinical trial subjects, donors of human cells,
tissue and other biological samples, shareholders, and employees inaccordance with relevant laws, regulations, and internal rules.

61. Human Rights and Workplace Environment

1

Respect for
Human Rights

We always protect the human rights of every person involvedin our business activities and respect the dignity and worth ofeach individual.

We respect the human rights of all people who come into contact with us
through our work and do not behave in any way that would harm the dignity of
individuals. We strictly refrain from behavior that would disrespect others andwill not tolerate any acts of harassment. We treat others with respect ascolleagues working together.

2

Prohibition ofHarassment

We do not tolerate acts of harassment in any form (including
sexual harassment, harassment associated with pregnancy,
childbirth and childcare, elderly care and the like, andworkplace bullying).

We strive to create a workplace environment free from harassment, where
everything can be discussed openly.
We do not commit acts of harassment. If you see any incident that would
negatively affect the workplace environment or improperly interfere withbusiness operations, you should report it to your supervisor or to the internalreporting office with the assurance that your reporting will remain confidential.

●In order to realize a fair and sound workplace free fromdiscrimination, we strive to understand various human rights
issues (ethnicity, nationality, gender discrimination, etc.) andrespect diversity.

●We do not tolerate any actions which disrespects the dignityof others, intimidating or aggressive remarks or behavior, or
sexual harassment in the workplace or in extended places ofbusiness, such as outings, banquets, etc.

●We make every effort to improve mutual communication,
respect each other's fundamental rights and recognize
individual differences and personalities.

●We regard each of our colleagues as business partners,
always consider things from the other's point of view, and try
to eliminate communication gaps between colleagues.

●We take appropriate corrective measures when we recognizethat human rights have been infringed.

78

1. Human Rights and Workplace Environment

1

Respect for
Human Rights

We always protect the human rights of every person involvedin our business activities and respect the dignity and worth ofeach individual.

We respect the human rights of all people who come into contact with us
through our work and do not behave in any way that would harm the dignity of
individuals. We strictly refrain from behavior that would disrespect others andwill not tolerate any acts of harassment. We treat others with respect ascolleagues working together.

2

Prohibition ofHarassment

We do not tolerate acts of harassment in any form (including
sexual harassment, harassment associated with pregnancy,
childbirth and childcare, elderly care and the like, andworkplace bullying).

We strive to create a workplace environment free from harassment, where
everything can be discussed openly.
We do not commit acts of harassment. If you see any incident that would
negatively affect the workplace environment or improperly interfere withbusiness operations, you should report it to your supervisor or to the internalreporting office with the assurance that your reporting will remain confidential.

●In order to realize a fair and sound workplace free fromdiscrimination, we strive to understand various human rights
issues (ethnicity, nationality, gender discrimination, etc.) andrespect diversity.

●We do not tolerate any actions which disrespects the dignityof others, intimidating or aggressive remarks or behavior, or
sexual harassment in the workplace or in extended places ofbusiness, such as outings, banquets, etc.

●We make every effort to improve mutual communication,
respect each other's fundamental rights and recognize
individual differences and personalities.

●We regard each of our colleagues as business partners,
always consider things from the other's point of view, and try
to eliminate communication gaps between colleagues.

●We take appropriate corrective measures when we recognizethat human rights have been infringed.

78

1. Human Rights and Workplace Environment

3

Equal Employment
Opportunities
We hire and evaluate our employees fairly based on theirability, aptitude and motivation. We do not tolerate any form of
discrimination on the grounds of ethnicity, origin, gender, etc.

We maintain fairness and impartiality in hiring, evaluating and training our
employees based on their ability and aptitude for their duties, as well as theirperformance and motivation.

●We encourage our employees to exercise their rights tomaternity or paternity leave, childcare leave and elderly careleave for their precious family members. We do not treat
employees exercising such rights unfairly with respect topersonnel evaluations or promotions.
●Our hiring and personnel evaluations are based on the ability,
aptitude and motivation of applicants and employees. We do
not discriminate against applicants or employees in hiring andpersonnel evaluation for the reasons below:- Matters for which individuals are not personally responsible(birth and family related matters, etc.), and4

Health and Safety ofWorkplaces
We comply with laws and regulations related to occupational
health and safety, as we strive to maintain and improve ourworkplace environment so our employees can work safely andcomfortably.

We strive to create a comfortable work environment that eliminates occupational
accidents and enables employees to work in a safe and healthy manner. We comply
with laws and regulations related to workplace safety and health and promote
occupational health and safety management systems to prevent occupational
accidents. In addition, every one of us endeavors to maintain a high level ofawareness for occupational safety and health, always striving to conduct our workin good mental and physical health. If you feel unease, irritation, or job-related
stress, please consult with your supervisor or an internal specialist or counselor.

●Each employee strives to maintain a good work environment,
to ensure thorough implementation of safety activities, and to
identify and improve problems. If you become injured in thecourse of performing your duties, you should report even a
minor injury to your supervisor and relevant personnel incharge of occupational safety and health.
●We comply with local laws and regulations regarding
occupational health checks, if any.
●You should make efforts to promote your health byconsciously taking exercise and refreshing yourself.

- Matters of personal freedom (religion, ideology, belief, etc.).

910

1. Human Rights and Workplace Environment

3

Equal Employment
Opportunities
We hire and evaluate our employees fairly based on theirability, aptitude and motivation. We do not tolerate any form of
discrimination on the grounds of ethnicity, origin, gender, etc.

We maintain fairness and impartiality in hiring, evaluating and training our
employees based on their ability and aptitude for their duties, as well as theirperformance and motivation.

●We encourage our employees to exercise their rights tomaternity or paternity leave, childcare leave and elderly careleave for their precious family members. We do not treat
employees exercising such rights unfairly with respect topersonnel evaluations or promotions.
●Our hiring and personnel evaluations are based on the ability,
aptitude and motivation of applicants and employees. We do
not discriminate against applicants or employees in hiring andpersonnel evaluation for the reasons below:- Matters for which individuals are not personally responsible(birth and family related matters, etc.), and4

Health and Safety ofWorkplaces
We comply with laws and regulations related to occupational
health and safety, as we strive to maintain and improve ourworkplace environment so our employees can work safely andcomfortably.

We strive to create a comfortable work environment that eliminates occupational
accidents and enables employees to work in a safe and healthy manner. We comply
with laws and regulations related to workplace safety and health and promote
occupational health and safety management systems to prevent occupational
accidents. In addition, every one of us endeavors to maintain a high level ofawareness for occupational safety and health, always striving to conduct our workin good mental and physical health. If you feel unease, irritation, or job-related
stress, please consult with your supervisor or an internal specialist or counselor.

●Each employee strives to maintain a good work environment,
to ensure thorough implementation of safety activities, and to
identify and improve problems. If you become injured in thecourse of performing your duties, you should report even a
minor injury to your supervisor and relevant personnel incharge of occupational safety and health.
●We comply with local laws and regulations regarding
occupational health checks, if any.
●You should make efforts to promote your health byconsciously taking exercise and refreshing yourself.

- Matters of personal freedom (religion, ideology, belief, etc.).

910

1. Human Rights and Workplace Environment

5

Safety andDisaster ReadinessWe will implement various measures to prevent accidents
such as fires. If there is a disaster, we will act rapidly andeffectively to stop the spread of the disaster in accordancewith operating procedures and manuals on disaster mitigation
measures established for each business site.

Fires, chemical leaks, and other serious disasters not only have a significant
impact on business operations, but can also cause anxiety, harm, and healthdamage to nearby residents and impact the community. Above all, it isimportant to prevent such disasters from occurring. In addition to complying
with relevant laws and regulations, we conduct education and training inaccordance with internal operating procedures and disaster response manuals.

●We strictly comply with laws and regulations related to safetyand disaster prevention.
●When introducing new equipment or using new chemical
substances, we evaluate them from the viewpoint of safetyand disaster prevention and take appropriate measures toprevent accidents and disasters.
●In the event of an accident or a large-scale natural disaster at
any of our business sites, we will mobilize all our resources toprevent the damage from spreading and promptly contact
and report matters to the relevant authorities. In addition,
employees are required to report the status of their safety
using the established safety confirmation system.

11

2. Responsibility to Society and Stakeholders

6

Disclosure of
Corporate Information
We provide timely and accurate disclosure of corporate information
on matters such as management policies and the status of businessactivities in accordance with relevant laws and regulations. In
addition, we listen closely to the requests and opinions we receivefrom society and reflect such feedback in our business activities.

We provide appropriate explanations of our activities to all stakeholders. Above
all, as a listed company, we disclose information required for investor decisions
promptly, accurately, and fairly in accordance with applicable laws, regulations
and the rules of the securities market. In the event that a benefit to the public ora need for urgency is recognized, we will proactively disclose relevant
information on our own initiative to fulfill our corporate social responsibilities.

●We disclose information appropriately in accordance with
relevant laws and regulations. We also emphasize ourrelationship with society and strive to voluntarily disclose
information expected by society.
●To ensure accurate data collection, which serves as the basis
for information disclosure, we conduct business reporting andaccounting processes accurately based on the actual facts.
●We take requests and opinions from outside the Company
seriously and strive to reflect them in our corporate activities.

121. Human Rights and Workplace Environment

5

Safety andDisaster ReadinessWe will implement various measures to prevent accidents
such as fires. If there is a disaster, we will act rapidly andeffectively to stop the spread of the disaster in accordancewith operating procedures and manuals on disaster mitigation
measures established for each business site.

Fires, chemical leaks, and other serious disasters not only have a significant
impact on business operations, but can also cause anxiety, harm, and healthdamage to nearby residents and impact the community. Above all, it isimportant to prevent such disasters from occurring. In addition to complying
with relevant laws and regulations, we conduct education and training inaccordance with internal operating procedures and disaster response manuals.

●We strictly comply with laws and regulations related to safetyand disaster prevention.
●When introducing new equipment or using new chemical
substances, we evaluate them from the viewpoint of safetyand disaster prevention and take appropriate measures toprevent accidents and disasters.
●In the event of an accident or a large-scale natural disaster at
any of our business sites, we will mobilize all our resources toprevent the damage from spreading and promptly contact
and report matters to the relevant authorities. In addition,
employees are required to report the status of their safety
using the established safety confirmation system.

11

2. Responsibility to Society and Stakeholders

6

Disclosure of
Corporate Information
We provide timely and accurate disclosure of corporate information
on matters such as management policies and the status of businessactivities in accordance with relevant laws and regulations. In
addition, we listen closely to the requests and opinions we receivefrom society and reflect such feedback in our business activities.

We provide appropriate explanations of our activities to all stakeholders. Above
all, as a listed company, we disclose information required for investor decisions
promptly, accurately, and fairly in accordance with applicable laws, regulations
and the rules of the securities market. In the event that a benefit to the public ora need for urgency is recognized, we will proactively disclose relevant
information on our own initiative to fulfill our corporate social responsibilities.

●We disclose information appropriately in accordance with
relevant laws and regulations. We also emphasize ourrelationship with society and strive to voluntarily disclose
information expected by society.
●To ensure accurate data collection, which serves as the basis
for information disclosure, we conduct business reporting andaccounting processes accurately based on the actual facts.
●We take requests and opinions from outside the Company
seriously and strive to reflect them in our corporate activities.

122. Responsibility to Society and Stakeholders

7

Tax Payments

We comply with tax laws and regulations applicable in the
countries where we operate and pay taxes appropriately.

We comply with applicable tax laws and regulations, file tax returns and pay
taxes appropriately in the countries where we engage in business activities. By
meeting these obligations, we fulfill our important corporate social
responsibilities to contribute to the economic development of the countries
where we operate.

8

Response to
Anti-Social Forces

We never have relationships with anti-social forces or groups
and resolutely stand up to such entities.

We have taken a resolute stance of "having no relationship at all" with any
anti-social forces and organizations that pose a threat to the order and safetyof society. We shall not deal with any anti-social forces, nor provide money orother benefits to any anti-social forces, even when faced with acts of extortion,
coercion, or harassment by them.

●We do not implement tax planning, utilize tax havens, or
engage in the transactions via tax havens for tax evasion
purposes.

●We shall not provide any benefit to anti-social forces for any
reason, based on the three “No” principles of "no fear," "nomoney," and "no use."●We conduct our intragroup transactions appropriately inaccordance with the Transfer Pricing Guidelines forMultinational Enterprises and Tax Administrations (the OECD
Transfer Pricing Guidelines) and other applicable local
transfer pricing taxation laws and regulations.

●We do not provide direct benefits such as money or goods toanti-social forces, engage in money laundering or provide any
indirect benefits aiding the activities of anti-social forces.

●We disclose information appropriately in accordance with
relevant laws and regulations to ensure the transparency andreliability of tax reporting to the tax authorities of eachjurisdiction.

●In the event of an improper request from anti-social forces orcontact from a suspicious organization, you should report it toyour supervisor and act in cooperation with the related
departments, and not make any judgment or try to respondon your own..

●When uncertain tax situations arise, we will consult with tax
authorities in advance as necessary, and strive to resolve
such uncertain tax matters.

13

14

2. Responsibility to Society and Stakeholders

7

Tax Payments

We comply with tax laws and regulations applicable in the
countries where we operate and pay taxes appropriately.

We comply with applicable tax laws and regulations, file tax returns and pay
taxes appropriately in the countries where we engage in business activities. By
meeting these obligations, we fulfill our important corporate social
responsibilities to contribute to the economic development of the countries
where we operate.

8

Response to
Criminal Organizations
We never have relationships with criminal organizations orgroups and resolutely stand up to such entities.

We have taken a resolute stance of "having no relationship at all" with any
criminal organizations that pose a threat to the order and safety of society.
We shall not deal with any criminal organizations, nor provide money or otherbenefits to any criminal organizations, even when faced with acts of extortion,
coercion, or harassment by them.

●We do not implement tax planning, utilize tax havens, or
engage in the transactions via tax havens for tax evasion
purposes.

●We shall not provide any benefit to criminal organizations forany reason, based on the three “No” principles of "no fear,""no money," and "no use."●We conduct our intragroup transactions appropriately inaccordance with the Transfer Pricing Guidelines forMultinational Enterprises and Tax Administrations (the OECD
Transfer Pricing Guidelines) and other applicable local
transfer pricing taxation laws and regulations.

●We do not provide direct benefits such as money or goods tocriminal organizations, engage in money laundering or provide
any indirect benefits aiding the activities of criminalorganizations.

●We disclose information appropriately in accordance with
relevant laws and regulations to ensure the transparency andreliability of tax reporting to the tax authorities of eachjurisdiction.

●In the event of an improper request from criminalorganizations or contact from a suspicious organization, you
should report it to your supervisor and act in cooperation withthe related departments, and not make any judgment or try to
respond on your own..

●When uncertain tax situations arise, we will consult with tax
authorities in advance as necessary, and strive to resolve
such uncertain tax matters.

13

14

2. Responsibility to Society and Stakeholders

9

Prohibition ofConflicts of Interest
We never use our positions in the Company or any information
obtained in the course of our duties for personal gain orcommit any acts conflicting with the interests of the Company.

We strictly distinguish between our professional duties in the Company and our
private activities and will not use the Company's assets for private gain or
engage in any conduct that conflicts with the interests of the Company. We do
not abuse our positions in the Company or use for personal purposes any
property entrusted to us or any information obtained in the course of ourduties. We properly use and manage the Company's assets, whether tangible
or intangible, and do not use them for personal purposes.

●We do not use any information obtained in the course of our duties in
the Company for private gains or for the benefit of any third party.
●We do not engage in transactions that compete with the Company's
business, or commit any acts that compete with the Company, suchas becoming an executive or major investor of a competing
enterprise.
●If you or your related party (such as a relative, or a company ororganization managed by you or your relative) have any dealings with
the Company, you will not use your position in the Company to gain
any benefit for yourself or your related party, and will not engage inany acts that may harm the interests of the Company.
●We do not provide improper benefits to specific suppliers or
customers (such as conducting business on terms that deviate fromreasonable limits for the Company) or receive improper benefits (suchas receiving money from a supplier or customer).

10

Contributing toSociety

We remain aware of our role as a good corporate citizen as weseek to realize a sustainable society. With this in mind, we
actively interact with society and conduct activities that
contribute to society.

We aim to contribute to human health through sustainable development, and asa corporate citizen, we actively interact with local communities and engage inactivities that contribute to society. We support a variety of activities, making
the most of our unique characteristics as a company involved in an industry
that supports human life.

●We conduct sustainable activities that help solve social
problems and contribute to the development of local
communities where our businesses are located.
●We collect and disseminate information inside and outside theCompany to deepen the understanding of rare diseases, andpromote cooperation and support activities with patientassociations and rare disease support organizations.
●In collaborating with patient groups, we maintain high ethicalstandards, transparency and respect for the independence ofeach group.

●We properly use and manage the Company's assets, whether tangible
or intangible, and do not use them for any purpose other thanbusiness, and do not appropriate them for private purposes. We do
not improperly use the Company’s IT systems or use the Company’s
properties or business expenses for private purposes.

1516

2. Responsibility to Society and Stakeholders

9

Prohibition ofConflicts of Interest
We never use our positions in the Company or any information
obtained in the course of our duties for personal gain orcommit any acts conflicting with the interests of the Company.

We strictly distinguish between our professional duties in the Company and our
private activities and will not use the Company's assets for private gain or
engage in any conduct that conflicts with the interests of the Company. We do
not abuse our positions in the Company or use for personal purposes any
property entrusted to us or any information obtained in the course of ourduties. We properly use and manage the Company's assets, whether tangible
or intangible, and do not use them for personal purposes.

●We do not use any information obtained in the course of our duties in
the Company for private gains or for the benefit of any third party.
●We do not engage in transactions that compete with the Company's
business, or commit any acts that compete with the Company, suchas becoming an executive or major investor of a competing
enterprise.
●If you or your related party (such as a relative, or a company ororganization managed by you or your relative) have any dealings with
the Company, you will not use your position in the Company to gain
any benefit for yourself or your related party, and will not engage inany acts that may harm the interests of the Company.
●We do not provide improper benefits to specific suppliers or
customers (such as conducting business on terms that deviate fromreasonable limits for the Company) or receive improper benefits (suchas receiving money from a supplier or customer).

10

Contributing toSociety

We remain aware of our role as a good corporate citizen as weseek to realize a sustainable society. With this in mind, we
actively interact with society and conduct activities that
contribute to society.

We aim to contribute to human health through sustainable development, and asa corporate citizen, we actively interact with local communities and engage inactivities that contribute to society. We support a variety of activities, making
the most of our unique characteristics as a company involved in an industry
that supports human life.

●We conduct sustainable activities that help solve social
problems and contribute to the development of local
communities where our businesses are located.
●We collect and disseminate information inside and outside theCompany to deepen the understanding of rare diseases, andpromote cooperation and support activities with patientassociations and rare disease support organizations.
●In collaborating with patient groups, we maintain high ethicalstandards, transparency and respect for the independence ofeach group.

●We properly use and manage the Company's assets, whether tangible
or intangible, and do not use them for any purpose other thanbusiness, and do not appropriate them for private purposes. We do
not improperly use the Company’s IT systems or use the Company’s
properties or business expenses for private purposes.

1516

2. Responsibility to Society and Stakeholders

11

Conserving
the Environment

We always remain mindful of how we impact the global
environment and local communities as we conduct ourbusiness activities, contribute to the sustainable developmentof society, and fulfill our responsibilities to future generations.

We use genetically-modified organisms and various other materials, which may
have a significant impact on our environment in case of accident or otherincident. To preserve our environment, we proactively cooperate with various
measures and initiatives while understanding the importance of environmental
issues as well as complying with environmental laws and regulations in oursustainable corporate activities.

●We comply with all laws, regulations, ordinances, andagreements related to conservation of our environment,
including biodiversity.
●We establish proper metrics related to environmental
conservation, measure progress accurately, and report theresults appropriately.
●To promote environmental conservation activities, we work
seriously at every stage of our business activities to saveresources, conserve energy, reduce waste, recycle, properly
manage chemical substances, and create
environmentally-friendly products with the aim of reducing
environmental impact.

17

3. Fair Trading and Competition

12

Commitment to Fair Trading
and Competition
We conduct fair and legitimate corporate activities incompliance with laws and regulations for maintaining
competition and fair trading in the market.

Restricting free corporate activities and competition, and business
transactions using unfair means are strictly prohibited by the relevant
regulations of each jurisdiction. In the event of a violation, serious penalties
are imposed on not only the Company but also the person in charge.
We engage in fair and free competition in the market and do not commit any
violations, such as cartels, bid rigging, restrictions on resale prices orpurchasers, exclusion of certain business operators, abuse of a dominantbargaining position, or unfair discriminatory treatment.

●We do not use unfair means to exclude competitors in orderto monopolize the market.
●We do not restrict competition by agreeing with ourcompetitors on prices, production volumes, sales volumes,
sales territories, or customers (including agreements withindustry associations).
●We do not engage in contact with our competitors or exchange
information or opinions within industry associations in a manner
which would raise suspicion of involvement in a cartel.
●We do not restrict customers and the sales prices of ourdistributors, or unjustly restrict their sales activities.
●We deal with subcontractors by expressly specifying inwriting the appropriate terms and conditions of business anddo not delay payments, request unreasonable discounts, orrefuse receipts of goods or services.

18

2. Responsibility to Society and Stakeholders

11

Conserving
the Environment

We always remain mindful of how we impact the global
environment and local communities as we conduct ourbusiness activities, contribute to the sustainable developmentof society, and fulfill our responsibilities to future generations.

We use genetically-modified organisms and various other materials, which may
have a significant impact on our environment in case of accident or otherincident. To preserve our environment, we proactively cooperate with various
measures and initiatives while understanding the importance of environmental
issues as well as complying with environmental laws and regulations in oursustainable corporate activities.

●We comply with all laws, regulations, ordinances, andagreements related to conservation of our environment,
including biodiversity.
●We establish proper metrics related to environmental
conservation, measure progress accurately, and report theresults appropriately.
●To promote environmental conservation activities, we work
seriously at every stage of our business activities to saveresources, conserve energy, reduce waste, recycle, properly
manage chemical substances, and create
environmentally-friendly products with the aim of reducing
environmental impact.

17

3. Fair Trading and Competition

12

Commitment to Fair Trading
and Competition
We conduct fair and legitimate corporate activities incompliance with laws and regulations for maintaining
competition and fair trading in the market.

Restricting free corporate activities and competition, and business
transactions using unfair means are strictly prohibited by the relevant
regulations of each jurisdiction. In the event of a violation, serious penalties
are imposed on not only the Company but also the person in charge.
We engage in fair and free competition in the market and do not commit any
violations, such as cartels, bid rigging, restrictions on resale prices orpurchasers, exclusion of certain business operators, abuse of a dominantbargaining position, or unfair discriminatory treatment.

●We do not use unfair means to exclude competitors in orderto monopolize the market.
●We do not restrict competition by agreeing with ourcompetitors on prices, production volumes, sales volumes,
sales territories, or customers (including agreements withindustry associations).
●We do not engage in contact with our competitors or exchange
information or opinions within industry associations in a manner
which would raise suspicion of involvement in a cartel.
●We do not restrict customers and the sales prices of ourdistributors, or unjustly restrict their sales activities.
●We deal with subcontractors by expressly specifying inwriting the appropriate terms and conditions of business anddo not delay payments, request unreasonable discounts, orrefuse receipts of goods or services.

18

3. Fair Trading and Competition

13

Prohibition of
Unfair Competition
We do not engage in the unauthorized acquisition or use of
the trade secrets of other companies or act in a manner which
would impair the business reputation of other companies.

We do not illegally acquire or use trade secrets belonging to other companies.
In addition, we do not slander or defame other companies in any way that may
harm their reputations. Any act or conduct of unfair competition is prohibitedby relevant laws and regulations applicable to each jurisdiction, and we
recognize the potential liability and criminal penalties related to such violations.

19

14Entertainment
and Gifts

We maintain sound and fair relationships with our suppliers
and other business partners, without providing or receiving
entertainment or gifts in excess of accepted social norms andcomply with relevant laws and regulations.

We will maintain moderation and transparency in entertaining and giving gifts toensure they are only for social courtesy. When providing entertainment or gifts,
such conduct should be within the bounds of socially accepted standards, andwe do not provide excessive entertainment or gifts which might impair ourbusiness judgments, nor accept such excessive entertainment or gifts.

●We do not acquire the trade secrets of other companies
through improper means or use the trade secrets of othercompanies that may have been acquired through impropermeans. In addition, we do not request the fraudulent provisionof trade secrets belonging to other companies.

●We comply with local laws and regulations regarding
entertainment-related activities for healthcare professionals.
We do not provide inappropriate gifts, money, meals, or
drinks, etc. in accordance with our industry’s Code ofPractice and other local rules.

●We do not harm the reputation of other companies byslandering or defaming their products or disseminating false
information about them.

●We do not provide inappropriate gifts, money, meals, or
drinks, etc. to our private-sector stakeholders and we comply
with applicable local laws and regulations, our industry’ s
Code of Practice and other local rules.

203. Fair Trading and Competition

13

Prohibition of
Unfair Competition
We do not engage in the unauthorized acquisition or use of
the trade secrets of other companies or act in a manner which
would impair the business reputation of other companies.

We do not illegally acquire or use trade secrets belonging to other companies.
In addition, we do not slander or defame other companies in any way that may
harm their reputations. Any act or conduct of unfair competition is prohibitedby relevant laws and regulations applicable to each jurisdiction, and we
recognize the potential liability and criminal penalties related to such violations.

19

14Entertainment
and Gifts

We maintain sound and fair relationships with our suppliers
and other business partners, without providing or receiving
entertainment or gifts in excess of accepted social norms andcomply with relevant laws and regulations.

We will maintain moderation and transparency in entertaining and giving gifts toensure they are only for social courtesy. When providing entertainment or gifts,
such conduct should be within the bounds of socially accepted standards, andwe do not provide excessive entertainment or gifts which might impair ourbusiness judgments, nor accept such excessive entertainment or gifts.

●We do not acquire the trade secrets of other companies
through improper means or use the trade secrets of othercompanies that may have been acquired through impropermeans. In addition, we do not request the fraudulent provisionof trade secrets belonging to other companies.

●We comply with local laws and regulations regarding
entertainment-related activities for healthcare professionals.
We do not provide inappropriate gifts, money, meals, or
drinks, etc. in accordance with our industry’s Code ofPractice and other local rules.

●We do not harm the reputation of other companies byslandering or defaming their products or disseminating false
information about them.

●We do not provide inappropriate gifts, money, meals, or
drinks, etc. to our private-sector stakeholders and we comply
with applicable local laws and regulations, our industry’ s
Code of Practice and other local rules.

203. Fair Trading and Competition

15

Prohibition of
Corruption and Bribery
We are aware that we are subject to regulations stipulated bypublic organizations and are required to maintain proper
relationships with public organizations.

Our businesses are subject to regulations stipulated by public organizations
worldwide. We are required to maintain proper relationships with publicorganizations. We are aware that any act of corruption and bribery can ruin our
corporate trust overnight and we should therefore never permit such acts.

●We comply with the U.S. Foreign Corrupt Practices Act, theU.K. Bribery Act, the Brazilian Anti-Corruption Act and othersimilar laws, as well as our policies and regulations on
anti-corruption.
●We understand the objectives of relevant local regulations
and do not provide any inappropriate gifts, money, meals or
drinks, etc. to public officials (including persons deemed as
public officials by specific legislation).
●We do not make any improper payments to any politicalparties, politicians, or political organizations, etc.

21

4. Business Activities

16

Drug Discovery
Research

We actively pursue research activities in accordance with
relevant laws, regulations, and internal rules aiming toeradicate diseases, improve the quality of human health anddaily lives, and contribute to the future of healthcare.

We engage in research and development of pharmaceuticals and otherproducts that contribute to the advancement of people's health and medicalcare. In conducting experiments and tests, it is fundamental to collectreproducible and accurate data in compliance with relevant laws, regulations,industry rules, and internal rules. We will never tolerate unauthorized discardingof or tampering with data.

●We conduct research and testing in compliance with relevantlaws, regulations and internal rules, and collect accurate data
to appropriately judge efficacy and safety.
●When conducting animal testing, we follow the 3R principles(Replacement: Use of alternative methods; Reduction:
Reducing the number of animals used; and Refinement:
reducing the distress of laboratory animals), and carry out
experiments appropriately from a scientific perspective.
●In research and studies utilizing human-derived cells andtissues, such as stem cells, we give our utmost consideration
to the issues of bioethics and human rights. We conduct suchresearch after prior approval by the Ethics Review Committee.

223. Fair Trading and Competition

15

Prohibition of
Corruption and Bribery
We are aware that we are subject to regulations stipulated bypublic organizations and are required to maintain proper
relationships with public organizations.

Our businesses are subject to regulations stipulated by public organizations
worldwide. We are required to maintain proper relationships with publicorganizations. We are aware that any act of corruption and bribery can ruin our
corporate trust overnight and we should therefore never permit such acts.

●We comply with the U.S. Foreign Corrupt Practices Act, theU.K. Bribery Act, the Brazilian Anti-Corruption Act and othersimilar laws, as well as our policies and regulations on
anti-corruption.
●We understand the objectives of relevant local regulations
and do not provide any inappropriate gifts, money, meals or
drinks, etc. to public officials (including persons deemed as
public officials by specific legislation).
●We do not make any improper payments to any politicalparties, politicians, or political organizations, etc.

21

4. Business Activities

16

Drug Discovery
Research

We actively pursue research activities in accordance with
relevant laws, regulations, and internal rules aiming toeradicate diseases, improve the quality of human health anddaily lives, and contribute to the future of healthcare.

We engage in research and development of pharmaceuticals and otherproducts that contribute to the advancement of people's health and medicalcare. In conducting experiments and tests, it is fundamental to collectreproducible and accurate data in compliance with relevant laws, regulations,industry rules, and internal rules. We will never tolerate unauthorized discardingof or tampering with data.

●We conduct research and testing in compliance with relevantlaws, regulations and internal rules, and collect accurate data
to appropriately judge efficacy and safety.
●When conducting animal testing, we follow the 3R principles(Replacement: Use of alternative methods; Reduction:
Reducing the number of animals used; and Refinement:
reducing the distress of laboratory animals), and carry out
experiments appropriately from a scientific perspective.
●In research and studies utilizing human-derived cells andtissues, such as stem cells, we give our utmost consideration
to the issues of bioethics and human rights. We conduct suchresearch after prior approval by the Ethics Review Committee.

22

4. Business Activities

17

Export and Import

We implement appropriate export and import procedures incompliance with export- and import-related laws, regulations,international treaties, and other arrangements.

When importing or exporting products, goods, raw materials, and samples forresearch and development, we respect the rules of other countries as well asJapan, and appropriately carry out customs procedures and declarations.
When exporting specific products or technical materials to specific regions
controlled by laws and regulations from the viewpoint of international security,
we will determine whether or not such laws and regulations are applicable tosuch products or technical materials in advance in accordance with internal
procedures and obtain government approval for export.

●In carrying out import and export transactions, we understandand comply with relevant laws and regulations, and correctly
carry out export and import procedures and declarations
related to customs clearance.
●We make sure to correctly check whether or not a product ortechnology to be exported falls under the category of
specified products or technology for which export isregulated.

18

Clinical Development
In course of conducting clinical trials, we respect the humanrights of clinical trial subjects and secure their safety, alongwith ensuring the quality and reliability of data, in accordancewith relevant laws, regulations, and internal rules.

We comply with ethical principles based on the Declaration of Helsinki andconduct clinical trials with the highest priority given to the health and safety ofsubjects. If it is judged that there is a problem in the conduct of the clinical
trial, we will review the clinical study plan immediately to determine whether or
not to continue the clinical study.

●We conduct clinical trials in compliance with relevant laws,
regulations, internal rules and various procedures and in accordancewith a protocol that is adequately assured of ethical and scientificvalidity.
●We respect the human rights of subjects, ensure their safety as the
top priority, and obtain appropriate informed consents. In addition,
we always consider and act from the viewpoint of the subjects,
including protection of their personal information.
●We proactively disclose information on the provision of funds to
medical institutions, etc., and ensure transparency in our
relationships with them.
●We support studies led by researchers in compliance with applicable
local laws and regulations as well as other relevant regulations andindustry codes to ensure transparency.
●We strive to release publicly, after peer review, the outcome of clinicalstudies performed on our products under development for the
purpose of providing information to medical societies andassociations.

2324

4. Business Activities

17

Export and Import

We implement appropriate export and import procedures incompliance with export- and import-related laws, regulations,international treaties, and other arrangements.

When importing or exporting products, goods, raw materials, and samples forresearch and development, we respect the rules of other countries as well asJapan, and appropriately carry out customs procedures and declarations.
When exporting specific products or technical materials to specific regions
controlled by laws and regulations from the viewpoint of international security,
we will determine whether or not such laws and regulations are applicable tosuch products or technical materials in advance in accordance with internal
procedures and obtain government approval for export.

●In carrying out import and export transactions, we understandand comply with relevant laws and regulations, and correctly
carry out export and import procedures and declarations
related to customs clearance.
●We make sure to correctly check whether or not a product ortechnology to be exported falls under the category of
specified products or technology for which export isregulated.

18

Clinical Development
In course of conducting clinical trials, we respect the humanrights of clinical trial subjects and secure their safety, alongwith ensuring the quality and reliability of data, in accordancewith relevant laws, regulations, and internal rules.

We comply with ethical principles based on the Declaration of Helsinki andconduct clinical trials with the highest priority given to the health and safety ofsubjects. If it is judged that there is a problem in the conduct of the clinical
trial, we will review the clinical study plan immediately to determine whether or
not to continue the clinical study.

●We conduct clinical trials in compliance with relevant laws,
regulations, internal rules and various procedures and in accordancewith a protocol that is adequately assured of ethical and scientificvalidity.
●We respect the human rights of subjects, ensure their safety as the
top priority, and obtain appropriate informed consents. In addition,
we always consider and act from the viewpoint of the subjects,
including protection of their personal information.
●We proactively disclose information on the provision of funds to
medical institutions, etc., and ensure transparency in our
relationships with them.
●We support studies led by researchers in compliance with applicable
local laws and regulations as well as other relevant regulations andindustry codes to ensure transparency.
●We strive to release publicly, after peer review, the outcome of clinicalstudies performed on our products under development for the
purpose of providing information to medical societies andassociations.

2324

4. Business Activities

19

Product Quality

Our top priority is to steadily supply high-quality products with
an emphasis on efficacy and safety to patients around theworld. We provide a timely and appropriate supply of products
in accordance with relevant laws, regulations, and internal rules.

As a supplier of life-related products, we are strongly aware of our social
responsibility. To ensure their efficacy, safety, and quality, we manufacture our
products in accordance with relevant laws, regulations, and internal rules, andprovide stable supplies to medical institutions and patients. To protect thesafety of patients, we take all possible measures to ensure that our products
do not cause any damage to human life and health.

●We comply with all relevant laws, regulations, and internal
rules through adequate manufacturing control and quality
control throughout the entire production process, from thereceipt of raw materials to the packaging and shipment offinished products, and ensure the timely and appropriate
supply of products.
●We shall promptly report to the supervisor any concern
related to the efficacy, safety, and quality, no matter how
minor it may seem.

25

20

Management of Information
Related to Product Efficacy,
Safety, and Quality
We provide timely and accurate information related to productefficacy, safety, and quality in accordance with relevant laws,
regulations, and internal rules with the aim of ensuring properuse of the products manufactured and sold by the Company.

To ensure the proper use of our products, we always collect and examine
information on their efficacy, safety, and quality, and promptly and accurately
provide such information to the regulatory authorities and medical institutions.

●We have a legal obligation to collect and report any and all
information about the safety of our products, whether they arebeing developed or sold.
●We will immediately report information on the effectiveness,safety and quality of our products to the department in chargeof pharmacovigilance and the department in charge of quality
assurance.
●Inquiries about complaints and quality information will behandled with appropriate respect for personal information.

26

4. Business Activities

19

Product Quality

Our top priority is to steadily supply high-quality products with
an emphasis on efficacy and safety to patients around theworld. We provide a timely and appropriate supply of products
in accordance with relevant laws, regulations, and internal rules.

As a supplier of life-related products, we are strongly aware of our social
responsibility. To ensure their efficacy, safety, and quality, we manufacture our
products in accordance with relevant laws, regulations, and internal rules, andprovide stable supplies to medical institutions and patients. To protect thesafety of patients, we take all possible measures to ensure that our products
do not cause any damage to human life and health.

●We comply with all relevant laws, regulations, and internal
rules through adequate manufacturing control and quality
control throughout the entire production process, from thereceipt of raw materials to the packaging and shipment offinished products, and ensure the timely and appropriate
supply of products.
●We shall promptly report to the supervisor any concern
related to the efficacy, safety, and quality, no matter how
minor it may seem.

25

20

Management of Information
Related to Product Efficacy,
Safety, and Quality
We provide timely and accurate information related to productefficacy, safety, and quality in accordance with relevant laws,
regulations, and internal rules with the aim of ensuring properuse of the products manufactured and sold by the Company.

To ensure the proper use of our products, we always collect and examine
information on their efficacy, safety, and quality, and promptly and accurately
provide such information to the regulatory authorities and medical institutions.

●We have a legal obligation to collect and report any and all
information about the safety of our products, whether they arebeing developed or sold.
●We will immediately report information on the effectiveness,safety and quality of our products to the department in chargeof pharmacovigilance and the department in charge of quality
assurance.
●Inquiries about complaints and quality information will behandled with appropriate respect for personal information.

26

4. Business Activities

21

Promotion Activities

When providing medical or pharmaceutical information to
healthcare professionals, we provide, gather, andcommunicate accurate information based on solid medical andpharmaceutical evidence in accordance with relevant laws,
regulations, our industry’s Code of Practice, and internal rules.

We act with the conviction that "the dignity of life is at all times our first priority,
and we shall always fulfill society’s trust in us." We conduct all promotional
activities, including materials and information used for information gatheringand information provision based on high ethical standards, in compliance with
relevant laws, regulations, our industry’s Code of Practice and internal rules.

27

22

Evaluation ofBusiness Partners

We are required to appropriately evaluate suppliers and otherthird parties with whom we trade.

Before trading with a supplier or other third party, we are required to conduct
screening and evaluation in an appropriate manner based on the nature of ourrelationship and the importance with that party.

●We acquire the necessary medical and pharmaceuticalknowledge, and provide, collect, and communicate accurate
and appropriate information.

●We evaluate our business partners based on the nature oftransactions, their substance, financial positions, supply
stability, quality controls and other factors.

●We provide information on indications, usage and dosage,etc. to the extent approved by the regulatory authorities
based on scientific evidence and without bias in terms ofefficacy and safety.

●In cases where a supplier or third party does not meet ourrequired standards or falls short on an issue, we request the
party to meet our standards and do not start transactions withthe party unless it meets our standards.

●We prepare and use materials for promotional activities after
their review and approval in accordance with the in-housereview system.

●We do not trade with any entity with human-rights problems,such as child labor or slavery.

28

4. Business Activities

21

Promotion Activities

When providing medical or pharmaceutical information to
healthcare professionals, we provide, gather, andcommunicate accurate information based on solid medical andpharmaceutical evidence in accordance with relevant laws,
regulations, our industry’s Code of Practice, and internal rules.

We act with the conviction that "the dignity of life is at all times our first priority,
and we shall always fulfill society’s trust in us." We conduct all promotional
activities, including materials and information used for information gatheringand information provision based on high ethical standards, in compliance with
relevant laws, regulations, our industry’s Code of Practice and internal rules.

27

22

Evaluation ofBusiness Partners

We are required to appropriately evaluate suppliers and otherthird parties with whom we trade.

Before trading with a supplier or other third party, we are required to conduct
screening and evaluation in an appropriate manner based on the nature of ourrelationship and the importance with that party.

●We acquire the necessary medical and pharmaceuticalknowledge, and provide, collect, and communicate accurate
and appropriate information.

●We evaluate our business partners based on the nature oftransactions, their substance, financial positions, supply
stability, quality controls and other factors.

●We provide information on indications, usage and dosage,etc. to the extent approved by the regulatory authorities
based on scientific evidence and without bias in terms ofefficacy and safety.

●In cases where a supplier or third party does not meet ourrequired standards or falls short on an issue, we request the
party to meet our standards and do not start transactions withthe party unless it meets our standards.

●We prepare and use materials for promotional activities after
their review and approval in accordance with the in-housereview system.

●We do not trade with any entity with human-rights problems,such as child labor or slavery.

28

5. Information Management

23

Respect forIntellectual Property

Recognizing that intellectual property is an important asset of
the Company, we take appropriate steps to protect our
intellectual property. In addition, we respect the intellectual
property rights of others and will not engage in infringement orunauthorized usage.

Intellectual property such as patents and inventions, utility models anddevices, designs, copyrights, trademarks, trade names and brands are theresults of the efforts of companies and individuals. We take full care not toinfringe upon the intellectual property rights of others, while proactively taking
steps to protect the intellectual property created through our research,development and other activities.

24

Handling ofConfidential Information
We recognize that confidential information, such as
non-public information, know-how and customer information,is an important asset of the Company. Therefore, we use andcontrol such confidential information appropriately inaccordance with relevant laws, regulations, and internal rules.

We understand that confidential information is an important asset of theCompany, and recognize the increasing risk of outflow and leakage ofconfidential or other information with advances in IT technology. Therefore, we
pay utmost attention to the handling of such information.
In addition, we respect and handle confidential information disclosed by third
parties with the same care.

●We do not upon the intellectual property rights of any otherparty. We pay careful attention to avoid unauthorized use
when conducting research and development or selecting
trademarks, etc.

●We do not use confidential information for any purpose otherthan business and appropriately control confidential
information according to its importance to prevent improper
use and disclosure.

●We manage and use trade names and trademarks
appropriately in accordance with internal rules.

●We disclose confidential information only to persons
concerned to the extent necessary for their duties.
●We execute confidentiality agreements without fail before
disclosing confidential information on our products or
technologies to third parties.
In addition, we shall handle confidential information disclosedby third parties in the same strict manner as the confidential
information of the Company, and comply with the terms andconditions of confidentiality agreements with third parties.

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5. Information Management

23

Respect forIntellectual Property

Recognizing that intellectual property is an important asset of
the Company, we take appropriate steps to protect our
intellectual property. In addition, we respect the intellectual
property rights of others and will not engage in infringement orunauthorized usage.

Intellectual property such as patents and inventions, utility models anddevices, designs, copyrights, trademarks, trade names and brands are theresults of the efforts of companies and individuals. We take full care not toinfringe upon the intellectual property rights of others, while proactively taking
steps to protect the intellectual property created through our research,development and other activities.

24

Handling ofConfidential Information
We recognize that confidential information, such as
non-public information, know-how and customer information,is an important asset of the Company. Therefore, we use andcontrol such confidential information appropriately inaccordance with relevant laws, regulations, and internal rules.

We understand that confidential information is an important asset of theCompany, and recognize the increasing risk of outflow and leakage ofconfidential or other information with advances in IT technology. Therefore, we
pay utmost attention to the handling of such information.
In addition, we respect and handle confidential information disclosed by third
parties with the same care.

●We do not upon the intellectual property rights of any otherparty. We pay careful attention to avoid unauthorized use
when conducting research and development or selecting
trademarks, etc.

●We do not use confidential information for any purpose otherthan business and appropriately control confidential
information according to its importance to prevent improper
use and disclosure.

●We manage and use trade names and trademarks
appropriately in accordance with internal rules.

●We disclose confidential information only to persons
concerned to the extent necessary for their duties.
●We execute confidentiality agreements without fail before
disclosing confidential information on our products or
technologies to third parties.
In addition, we shall handle confidential information disclosedby third parties in the same strict manner as the confidential
information of the Company, and comply with the terms andconditions of confidentiality agreements with third parties.

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5. Information Management、25

Use of Communication
Channels
We take responsibility for the outcome and impact on social
reputation arising from the use of communication channels,
including social media, regardless of whether it is for businessor personal use.

We make sensible and sound judgement before and when using
communication channels.

●For business use of communication channels, we confirm
strictly in advance that information will be released using
proper communication channels in accordance with internal
rules. We also confirm whether the information to be released
will not be of a nature that will undermine our social trust.
●For the personal use of social media, we do not make any
remarks that may be mistakenly considered as JCR
Pharma’ s promotion activities or be regarded as an official
corporate position. We do not make any senseless, offensive,
defamatory, or discriminatory remarks that may damage thetrust of our colleagues, our customers, etc. We do notdisclose any confidential or personal information throughsocial media.

31

26

Prohibition of
Insider Trading

We do not commit acts that violate insider trading regulations
or acts that could be suspected of violating such regulations.

Insider trading refers to "the purchase or sale of shares or other securities of acompany, before the disclosure of information that may have a significant
impact on the stock price of the company (“Material Facts”) by a person who isaware of such important information." Such transactions are strictly prohibitedby laws and regulations because they cause significant inequality for ordinary
investors and undermine the soundness of the securities market.

●When we become aware of any Material Facts of theCompany that has not yet been disclosed to the public, we do
not purchase or sell any shares of the Company until suchinformation is disclosed to the public.
●In addition to not engaging in insider trading on our own
accounts, we also do not talk about Material Facts notdisclosed by the Company to our family members,
acquaintances and business partners, as it may lead to
insider trading by such persons.
●When buying or selling shares of the Company, we mustobtain internal approval in advance in accordance withinternal rules, including cases where family members residing
with us buy or sell the shares.

32

5. Information Management、25

Use of Communication
Channels
We take responsibility for the outcome and impact on social
reputation arising from the use of communication channels,
including social media, regardless of whether it is for businessor personal use.

We make sensible and sound judgement before and when using
communication channels.

●For business use of communication channels, we confirm
strictly in advance that information will be released using
proper communication channels in accordance with internal
rules. We also confirm whether the information to be released
will not be of a nature that will undermine our social trust.
●For the personal use of social media, we do not make any
remarks that may be mistakenly considered as JCR
Pharma’ s promotion activities or be regarded as an official
corporate position. We do not make any senseless, offensive,
defamatory, or discriminatory remarks that may damage thetrust of our colleagues, our customers, etc. We do notdisclose any confidential or personal information throughsocial media.

31

26

Prohibition of
Insider Trading

We do not commit acts that violate insider trading regulations
or acts that could be suspected of violating such regulations.

Insider trading refers to "the purchase or sale of shares or other securities of acompany, before the disclosure of information that may have a significant
impact on the stock price of the company (“Material Facts”) by a person who isaware of such important information." Such transactions are strictly prohibitedby laws and regulations because they cause significant inequality for ordinary
investors and undermine the soundness of the securities market.

●When we become aware of any Material Facts of theCompany that has not yet been disclosed to the public, we do
not purchase or sell any shares of the Company until suchinformation is disclosed to the public.
●In addition to not engaging in insider trading on our own
accounts, we also do not talk about Material Facts notdisclosed by the Company to our family members,
acquaintances and business partners, as it may lead to
insider trading by such persons.
●When buying or selling shares of the Company, we mustobtain internal approval in advance in accordance withinternal rules, including cases where family members residing
with us buy or sell the shares.

32

5. Information Management

27

MEMO

Handling of
Personal Information
To protect the interests of individuals, we appropriately handle
the personal information of customers, patients, clinical trial
subjects, donors of human cells, tissue and other biologicalsamples, shareholders, and employees in accordance with
relevant laws, regulations, and internal rules.

We handle various kinds of information in accordance with relevant laws andregulations, our internal rules and personal information protection policies toprevent unauthorized outflows and incidents relating to personal information.

●When acquiring personal information, we specify clearly its
purpose and acquire personal information only when it isnecessary for business purposes and only when we obtainthe consent of the disclosing party.
●Personal information acquired will not be used for any
purpose other than the authorized purpose for which it was
acquired.
●We take preventative measures and appropriately control theacquired personal information to prevent its unauthorized use
or leakage.
●We do not disclose acquired personal information to any third
parties that are not included in the scope of consent by thedisclosing party.
●We comply with applicable local laws and regulations whenobtaining, transferring or providing personal information
across country borders.

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34ComplianceHandbook

2022.04