Standards of Behavior
We, from board members to all staff at TOA Pharmaceuticals, as dedicated people
working for a pharmaceutical manufacturer that believes in “the future of life”, havehigh standards of ethics that are socially trustworthy, and place first priority to be fairand honest in our activity.
Chapter 1 Fundamental Policy
Article 1（Legal Compliance）
Our actions shall be based on high standards of ethics and common social sense incompliance with legal, social, and internal rules and regulations.
Article 2（Contribution to Society）
We shall act upon the belief that it is our mission to create and publicly offer products
which are safe, effective, and of the highest quality.
Chapter 2 Responsibilities of Board Members and Employees
Article 3（Board Members）
3.1 Our board members are responsible for ensuring that employees strictly adhere tolegal and company rules and regulations as well as this chapter, through training andguidance. Board members are also responsible for dealing appropriately with andresolving any issues on compliance.
3.2 Our board members are responsible for taking initiative on this chapter and theiractions, to enhance upon this, and to put it to practical use.
Chapter 4 (Employees）
4.1 Our employees are responsible for complete understanding of legal and company
rules and regulations as well as this chapter, to respect and base their actions upon this.
4.2 If our employees discover any actions that are in violation of company regulations orof this chapter, they bear the responsibility to report to a compliance commissioner or tothe compliance committee.

Chapter 3 Actions Involving Stakeholders
We maintain appropriate, fair, and open relations with all stakeholders.
Article 5 (Patients and Consumers)
In order to contribute to the improvement of people’s health and quality of life throughpharmaceutical products, we pursue research, development, production, and sales ofsuperior products that meet the satisfaction of the public.
Article 6（Business Partners）
We respect the positions, rights, and profits of our business partners. Based on good
legal and commercial practices, we maintain fair, healthy relationships with ourpartners.
Article 7（Holders of Public Office）
We respect the ethical rules of holders of public office and politicians. We do not takeactions that may invite social concern and mistrust, such as donations for private gain
or illegal gifts.
Article 8（Stockholders）
8.1 We strive to enhance upon our accomplishments and profit.
8.2 We are dedicated in achieving public trust as an open company that is clear andmaintains a high level of transparency with appropriate, timely, and fair disclosure ofinformation.
8.3 We pay careful attention to the processing of important restricted information(inside information),
If important facts on our company or business partners become known in the course of
our business, we will not leak that information nor engage in trading relevant company
stock until that information becomes public.
8.4 In relation to execution of shareholders’ rights, we do not make monetary or gift
donations for profit to shareholders or other third parties.
Article 9（Employees and Labor Unions）
9.1 We respect the rights and character of each and every one of our employees, torealize an effective and pleasant working environment.
9.2 By offering opportunities for our employees to develop and maximize their talents asfully as possible, we seek to raise their levels of professionalism and promote thedevelopment of individuals with diverse ideas.
9.3 We maintain fair and healthy relations with labor unions, stand sincerity and trust
first, and pursue harmony with them.
Chapter 4 Actions toward Society
We place utmost importance on consideration for safety and the global environment,
through cooperation with the local community and a harmony with the international
community, and seek to maintain a healthy relationship with societ y.
Article 10（Involvement with Local Community）
10.1 Through involvement and participation in the local community, we pursue a wide
arena of communication with society.
10.2 As we take affirmative action in contributing to society, we understand theimportance of volunteer activity, and take on a positive role to vigorously participate
and support such opportunities

Article 11（Conservation of the Environment）
11.1 We pay attention and take care to consider the environment, and voluntarily andproactively promote conservation and improvement of the environment.
11.2 We seek to make effective use of energy and resources, and make an effort to cut
down on reducing waste material.
Article 12（Non-relations with Anti-social Forces）
We have no relations with anti-social forces that threaten the safety and order of society,never responding to improper or inadequate demands from such.
Article 13（Respect for Cultures and Traditions of Nations and Regions）
13.1 We respect the various cultures, customs and traditions of the different nations andregions of the world, and make an effort to contribute to their development.
13.2 We adhere to international treaties and local laws and statutes, and will not follow
bad practices that deviate from international standards.

Chapter 5 Corporate Actions
We execute corporate activity suitable for our identity as a trustworthy pharmaceuticalmanufacturer, making available to the public products which are backed by highstandards of reliability, together with accurate information.
Article 14（Research and Development）
14.1 With regard to research and development of pharmaceutical products, we adhere
strictly to laws such as the Pharmaceutical Affairs Act and the Good Clinical Research
Practice (GCP), along with internal rules and regulations.
14.2 With regard to research and development of pharmaceutical products, we create
accurate, unbiased and objective data on the effectiveness, safety, and quality of ourproducts.
14.3 With regard to clinical testing, we pay maximum attention and respect to thehuman rights of our subjects. While making full efforts to the protection of the life andhealth of our subjects, we take utmost care in the protection of their personalinformation.
14.4 With regard to clinical experiments on animals, we respect laws such as the Act on
Welfare and Management of Animals, and proceed based on beliefs of animal protection.
14.5 With regard to research and development, should there be doubt as to possibilities
of adverse occurrences, we report immediately to relevant authorities while taking
appropriate safety measures.
Article 15（Production）
15.1 With regard to the manufacturing of pharmaceutical products, we adhere strictly
to laws such as the Pharmaceutical Affairs Act, the Good Clinical Research Practice(GCP), and internal rules and regulations, and manufacture highly reliable
pharmaceutical products under appropriate manufacturing and quality control, making
safe products available to the public.

15.2 In the course of manufacturing, we take great care in safe operation, to avoid
occurrences of accidents. If an accident should occur, we will take maximum safetymeasures to protect lives and make immediate efforts to investigate cause, to prevent
repetitions of such incidents.
15.3 With regard to the manufacturing of pharmaceutical products, we endeavor toadopt facilities and equipment that are friendly to the environment.
Article 16（Product Guarantee）
16.1 As a manufacturer/retailer of pharmaceutical products, we adhere strictly to laws
and ordinances such as the Pharmaceutical Affairs Act, Good Quality Practices (GQP)
outlining quality practices on pharmaceuticals, medication, cosmetics and medical
devices, and internal rules and regulations.
16.2 In order to maintain our product quality, we establish procedure mechanisms indelivery management, processing of product quality information and recovery
treatments, engaging in appropriate product guarantee operations.
Article 17（Procurement and Purchasing）
For the procurement of raw materials, facilities and equipment, and services needed forour corporate activities, we adhere strictly to laws and internal rules and regulations inan effort to maintain fair trade.
Article 18（Sales）
18.1 For the sales of our pharmaceutical products, we adhere strictly to the Act on
Prohibition of Private Monopolization and Maintenance of Fair Trade、Act against
Unjustifiable Premiums and Misleading Representations and internal rules andregulations to engage in fair, free, and transparent sales activity.
18.2 We adhere strictly to laws and regulations of those such as the Fair Trade Councilof the Ethical Drug Manufacturing Industry, and refrain from improper actions such as
improper gift-giving to medical professionals, business entertaining and rebates forbusiness.

18.3 We do not restrain product nor bidding prices between our competitors. Neither do
we take part in groups or organizations that are seen to engage in such dealings.
18.4 We do not place restrictions with the purpose of maintaining resale prices indealings with wholesalers and retailers.
18.5 When dealing with consultation, requests and complaints on health and healthdamage from patients, consumers, and trade partners, we take care to makeappropriate and sincere accommodation available.
Article 19（Medical Information Activity）
19.1 With regard to activity on medical information, we adhere strictly to laws andinternal rules and regulations and act on providing timely and appropriate information
on pharmaceutical products as well as collecting such in the same manner.
19.2 With regard to the provision of information on pharmaceutical products, we will
not undertake libelous and defamatory action against our competitors or their products.
Article 20（Post-marketing Safety Management）
20.1 With regard to safety and control following product sales, we adhere strictly to laws
and ordinances such as the Pharmaceutical Affairs Act, the Good Post-Marketing
Surveillance Practice (GVP), internal rules and regulations, and engage inminimization of product side-effect damage.
20.2 We work on immediate collection of information on adverse effects related with ourproducts in Japan and abroad.
20.3 If there is doubt as to the possibility of adverse effects occurring due to ourproducts, we will immediately report to relevant authorities and take rapid action forsafety measures.
20.4 As a manufacturer/retailer of pharmaceutical products, we adhere strictly to laws
and ordinances such the Pharmaceutical Affairs Act, Good Post-Marketing StudyPractice (GPSP) and our internal rules and regulations, and appropriately conduct
surveys on usage outcomes, surveys of specific usage, and post-manufacture/sales
clinical testing.
Article 21（Labeling and Advertising）
With regard to labeling and advertising activities of our products, we adhere strictly tolaws and internal rules and regulations, eliminating falsity and hyperbole, ensuring
fairness and consideration for appropriate content and expression as to avoid social
inequality and infringement of human rights.
Article 22 (Import and Export）
When we engage in import/export with overseas business partners, we adhere strictly tothe laws of that partner’s country and all internal rules and regulations. We will follow
all requirements appropriately and ensure that our actions do not result in friction withthat country.
Chapter 6 Internal Discipline
We govern ourselves under strict internal disciplines, and maintain high standards ofcompliance.
Article 23（Fairness in Personnel Affairs）
23.1 We adhere strictly to the Labor Standards Act, employment-related laws, andinternal rules and regulations, and pursue appropriate placement of employees andpromote personnel interchange.
23.2 We conduct fair personnel appraisals, and refrain from granting privilege or
unfairly treating particular individuals with respect to promotions or pay increases
based on issues that are unrelated to their duties.
Article 24（Respect to Individuals）
24.1 We respect each other’s values and philosophies, individual character and qualities,
and refrain from biased treatment, abuse, or harassment based on nationality, race,beliefs, religion, sex, social standing, handicaps, or appearance.

24.2 We refrain from instruction for illegal actions by our board members, employees, or
any other persons engaged in our operations.
Article 25（Quality of Our Workplace Environment）
25.1 We pursue a vital work environment that is clean, safe, and comfortable to work in.
We adhere strictly to health and safety laws and internal rules and regulations while
taking action to prevent work-related accidents, injury, and illnesses, as we promote themaintenance of good health.
25.2 We adhere strictly upon the Act for Measures to Support the Development of theNext Generation and internal rules and regulations, proactively promoting a balance ofwork and child care.
25.3 We adhere strictly to nursing care-related laws and internal rules and regulations,proactively promoting a balance of work and nursing care.
Article 26（Prohibition of Harassment）
26.1 We strictly disapprove of sexual or power harassment.
26.2 We take care and ensure that harassment does not harm our workplaceenvironment.
Article 27（Protection of Informants）
27.1 We forbid efforts attempting to prevent informants from reporting on actions
violating or seen as in possible violation of our compliance measures.
27.2 We forbid retaliatory or detrimental treatment of informants of violations or
possible violations of our compliance measures.
Article 28（Effective Use of Corporate Resources）
Corporate resources are to be effectively utilized for the profit of the company and notfor personal or third-party gain.

Article 29（Avoidance of Conflicting Gain）
29.1 In the case of clashing or conflicting interests between company and board or
employee gain, corporate profit shall be prioritized.
29.2 With regard to business partners, we do not seek personal gain (monetary, goods,entertainment, and convenience) using work-related positions or authority.
Article 30（Adherence to Record Accuracy and Tax Laws）30.1 Documents for submission to government and public offices are accurately logged
and recorded. We refrain strictly from concealment, alterations and falsification.
30.2 Company accounting is in strict adherence to corporate law, the Securities
Exchange Act, business accounting principles, the Financial Instruments and Exchange
Act and other relevant laws and internal rules and regulations. We ensure that ourfinancial statements, asset securities reports, and account ledgers are in proper order.
We strictly prohibit accounting irregularities and accounting fraud, and adhere strictly
to tax laws, and make all appropriate tax payments.
Article 31（Respect to Intellectual Assets）
31.1 We respect the intellectual assets obtained in discovery through our businessduties, inventions, ideas, designs, proprietary trademarks, and copyrighted works, andengage in the maintenance and security of such properties.
31.２ We do not unjustly infringe upon the intellectual assets of third parties in thecourse of our operation.
Article 32（Appropriate Treatment of Information）
32.1 We conserve under strict management any restricted information regarding ourcompany or of other corporations obtained through our operations, and refrain fromillegal disclosure of such to third parties.
32.2 We do not illegally acquire restricted information on other companies.

32.3 We handle personal information carefully and in an appropriate manner, and takestrict measures to prevent leakage, alteration, loss, or theft of the information. We do
not illegally disclose personal information to third parties nor acquire such from thirdparties illegally.
Chapter 7 Disciplinary Action
Article 33 (Disciplinary Action）
Imposition of sanctions against employees who violate these standards are based oncompany rules of employment. Stringent action is taken in the case of board members.