Anti-Corruption Policy
Expected to update:［1st Feb. 2024］
JCR Pharmaceuticals Co., Ltd. and its subsidiaries and associates (hereinafter collectively, the"JCR Group" or "we") conducts to prevent corruption in all its forms and to promote its
compliance globally.

1. Compliance with laws and regulations
The JCR Group strictly adheres to all applicable anti-corruption laws and regulations in all
countries in which it operates and acts fairly and ethically in accordance with its internal
rules and regulations.

2. Scope
This Policy applies to all directors, officers, and employees of the JCR Group, including
external contractors working on behalf of the JCR Group (the "JCR Group Employees").

3. Definitions
TermDefinition

Anti-Corruption Laws

Includes criminal laws of each country and region, unfair
competition laws, FCPA, Bribery Act 2010, Brazilian anticorruption laws, etc. In addition to the laws and regulations ofthe countries and regions in which we operate, we include thelaws and regulations of other countries and regions when they
are applicable due to extraterritoriality.

Public Official

Public Official means any natural person who:

holds,

whether

electedorappointed,

alegislative,administrative, or judicial position of any kind in anycountry, state, or territory, regardless of his or herposition;

performs public functions in any branch, agency or
instrumentality of the national, federal or municipal
government of any country, state or territory;

performs public functions for any public agency or public
enterprise of any country, state or territory; oris considered a public official or quasi-official in accordancewith applicable laws.

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Business partner

Natural persons and legal entities other than the JCR Group
with whom the JCR Group has business relations or with whomthe JCR Group has business contact (e.g., agents, consultants,healthcare professionals contractors, subcontractors, suppliersand vendors, sales agents, joint venture partners, professional
associations, trade associations, natural persons or legal
entities performing services for or on behalf of the JCR Group),
excluding Public Official.

Internal Procedures

The JCR Compliance Policy, and all rules, procedures andfor the Prevention ofstandards of conduct relating to the prevention of corrupt

Corrupt Behaviorpractices of the JCR Group.

4. Bribery
The JCR Group must not offer, propose, promise or solicit, directly or indirectly,entertainment, gifts, money or any other bribes to any Public Official in Japan or abroad, inorder to obtain or retain business benefits, to avoid disadvantages to itself or the JCR Group,or in return for such actions.
The JCR Group must not offer, promise, solicit or accept, directly or indirectly, any
entertainment, gifts, money, or other bribes to its business partners, either in Japan orabroad, in an improper manner. In addition, we recognize that making payments to Public
Official to facilitate or expedite procedures with the government is basically considered atype of bribe.

5. Governance
The JCR Group establishes a management system to promote the prevention of corrupt
practices, as well as the Internal Procedures for the Prevention of Corrupt Behavior basedon this Policy.

6. Assessment and action
The JCR Group identifies and assesses, as required and as appropriate, the risks of corrupt
practices and takes necessary measures to prevent corrupt practices.
Before entering a transaction with a new third party, the JCR Group examines and evaluates,in consultation with the relevant departments, as necessary, for the purpose of preventing
corrupt practices by the third party.

7. Violation
If any JCR Group Employees violates the Anti-Corruption Laws, this Policy, or the Internal
Procedures for the Prevention of Corrupt Behavior, he/she will be subject to disciplinary
action.

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8. Continuous Improvement
The JCR Group continuously inspects, reviews, and makes improvements to the efforts
described in items 1 to 7 above.

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