Code of Conduct

Code of Conduct

Message
To date, we members of the pharmaceutical industry have contributed to the advancement of medicalcare primarily by providing methods for treating diseases. Of course, given the multitude of intractablediseases for which there are no existing therapies or treatments and diseases that are difficult to curecompletely, the world still needs us to continue “driving innovations” that will lead to the creation of new
drugs. We are also obliged to address the challenge of limited access to pharmaceuticals so that we canrespond to the pleas of sufferers the world over who are in need of “medicine.”
Meanwhile, as populations across the globe age rapidly, we are also required to support “sustainability of
medical insurance systems” if we wish to help the global community to keep developing. The
pharmaceutical industry must transform itself into a force for providing innovative means and solutions for
expanding healthy life expectancy in people around the world and assisting patients’ rehabilitation into
society, so that we can help our society to prosper. Although we still have a long way to go before we canattain that supreme goal, we need to become actively involved in the search for solutions to social issues
through proactively and voluntarily responding to ever-changing societal demands.
Out of our sincere aspiration to continue contributing to the good health of people around the world, weat the Mitsubishi Tanabe Pharma Group will work together with the Mitsubishi Chemical Group
companies and players from other industrial sectors across the globe in a wide range of areas, while
tapping into the strengths that we have cultivated in the pharmaceutical business. In so doing, we will give
serious consideration to the future of medicine in cooperation with patients and healthcare professionals,
governments, academic institutions, and local communities, with a view to developing innovative
solutions that transcend the conventional boundaries of medical care. We are ready to take the lead in
realizing a world in which people can enjoy healthy and happy lives with their loved ones for as long as
possible.
Hiroaki Ueno
Representative Director
Mitsubishi Tanabe Pharma Corporation1

We at the Mitsubishi Tanabe Pharma Group will contribute to the Mitsubishi Chemical Group's Vision “Realizing KAITEKI”
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Declaration ofCompliance

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Declaration of Compliance
1. We conduct our business with the highest ethical standards and in a professional manner as a global
healthcare company.
2. We respect human rights, and promote safe and healthy working environments.
3. We comply with legal requirements and regulations that apply to our businesses and corporate activities.
4. We work actively to protect the global environment and strive to realize harmonious co-existence of theCompany and society.
5. We strive to trade and transact business in a fair manner at all times.
6. We appropriately manage company information and data, and work to ensure that company informationand data is disclosed in a timely and reasonable manner.
7. We appropriately manage and efficiently use company assets.

Code of Conduct( Principles for Business Activities)
The Mitsubishi Tanabe Pharma Group Code of Conduct sets forth the basic stance on andspecific policies in respect of corporate and individual behavior in line with our Corporate
Behavior Charter and Declaration of Compliance toward realization of the Group’s
MISSION and VISION 30. All employees of the Mitsubishi Tanabe Pharma Groupare required to understand and comply with this Code and with all otherrules and policies of the Group.

2Principles for
Business Activities

1 CREATION OF PHARMACEUTICALS

1Being the first to deliver unique value2

Our mission going forward

There is nothing more rewarding than to see patients and their family members and friends smiling after successfultreatment. Constantly mindful that “everything we do is for the patients and their families who support them”, we
strive to clearly distinctive and novel value by creating original and visionary pharmaceuticals in an effort to become a“company that works with a sense of urgency and is the first to deliver unique value”, thereby opening up the future
for both patients and the field of medicine as a whole.

There are still many diseases that cannot be treated adequately through existing therapies and large numbers of
sufferers who have limited access to medicine. Hence, it is our duty to research and develop innovative new drugs sothat we can deliver such pharmaceuticals to those who are eagerly awaiting medicine. Meanwhile, as ever-increasing
healthcare expenditure become a major issue in the global community, it is also our mission to contribute to curbing
such expenditure and other social costs.
Beyond merely easing the symptoms of disease, we seek to relieve patients and their families of mental stress and toprovide patients with enjoyment and satisfaction in their lives, a sense of security, and opportunities to continue in, or
reintegrate into, society. We believe that pursuing innovations in this way will help our society to prosper and thesustainability of our society.

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Creation of new drugs

The process of creating a new drug is a long one. Against a backdrop of rapid progress in science and technology, we
will not only further enhance our drug discovery capabilities but also proactively utilize partnering arrangements (openinnovation and open shared business) to integrate the technologies and strengths of other entities and individuals with
our own, thereby delivering new drugs to sufferers who are anxiously awaiting medicine as promptly as possible.
We will also pursue development of new types of pharmaceuticals (drugs of the future) by tapping into the distinctive
resources of the Mitsubishi Chemical Group to incorporate various elemental technologies, materials, diagnostic
agents, and devices. In addition to these technological assets, we will assimilate other technologies that promise
substantial progress going forward, such as those for middle-molecule peptides, high molecular weight proteins,
nucleic acids and cells, thereby seizing the opportunities presented by regenerative medicine and genetic therapies.

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Maximization of product/pipeline value

The overall value of medicine is determined by taking into account such aspects as: pharmaceutical efficacy andsafety; reliability; usability; and drug information, including information on dosage and administration. From the initialstages of research and development, we apply approaches based on medical science to maximize the clinical valueof pharmaceuticals by understanding medical needs, conducting medical and pharmacological evaluation, andworking to improve cost competitiveness.
In the later stages of drug development, we conduct clinical trials, giving consideration to each compound’s uniquecharacteristics. After launch, we continue to monitor for adverse events and drug reactions and conduct clinicalresearch to collect treatment and other information on drugs, thereby accumulating data on their efficacy and safety.
Through such initiatives, we maximize the full potential of each type of medicine from an early stage.

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The art of drug development

For a new compound to be launched as medicine, a broad range of research and development activity is required.
With every single product, we strive to establish: robust and significant manufacturing technologies, including
manufacturing processes, to efficiently produce drug substances with stable quality, drug ingredient mixtures, andformulation designs, to ensure that active ingredients are delivered to therapeutic targets in the body; highly
productive manufacturing methods and technologies to scale up such manufacturing; packaging that helps to further
enhance the quality of therapies; and appropriate quality evaluation. Our goal is to deliver high-efficiency, low-cost,and high-quality “medicine” to patients.
By combining these proven technologies with new materials, devices, IT, and other technologies, we also seek todevelop medicine that offers greater convenience.

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Clinical research

We properly undertake clinical research with regard to both ethical and scientific considerations by ensuringtransparency and reliability, respecting the WMA Declaration of Helsinki (“Ethical Principles for Medical Research
Involving Human Subjects”) and the ethical principles on which it is based, and complying with all relevant laws andregulations, government guidelines and trade norms.
We conduct only scientifically valid clinical research that offers justifiable value for prevention, diagnosis, or treatment
of diseases, and we conduct it only when the importance of its aims outweighs any potential risks or inconvenience tothe participants who voluntarily cooperate in such research. In conducting clinical research, we prioritizeconsideration of the human rights, safety and health of research participants and we take appropriate and valid
measures to protect the privacy of such participants. We also adhere to these policies in clinical research conductedjointly with external partners such as medical and research institutions.

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Relationships with medical and research institutions

In conducting drug discovery research jointly with external partners or in outsourcing or subsidizing
such research, we consistently maintain fair relationships with our partners and refrain from any
conduct that could give rise to concerns about the integrity and independence of theirdecision-making.
When we conduct joint research and provide research support, we pay due
attention to management of conflicts of interest, recognizing that theindependence of researchers is extremely important in ensuring
objectivity and reliability.

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2 SAFETY
We strive to minimize the possibility of health hazards resulting from adverse reactions by reducing the safety risks ofour pharmaceuticals. In order for patients to be able to consult physicians for treatment using our pharmaceuticals
with peace of mind, we collect and analyze treatment information worldwide on a daily basis during clinical trials andpost-marketing surveys, whether the pharmaceuticals in question are in-house or co-developed. Our goal is toprovide healthcare professionals with the timely and reliable feedback that they need to appropriately determine abalance between the benefits and risks of a particular pharmaceutical in the treatment of each and every patient.

3 QUALITY ASSURANCE
It is absolutely essential to assure the quality, efficacy, and safety of “medicine” throughout the product lifecycle, fromresearch and development through manufacturing and post-marketing activities. In accordance with the applicablelaws, regulations, and public standards of each country in which we operate, we establish and continuously improvesystems for ensuring and monitoring compliance with GxP and other guidelines so that we can maintain and operate
an effective quality management system that assures the reliability of data and the quality of our pharmaceuticals. We
disclose reliable information in a timely and accurate manner.

4 SUPPLY CHAIN
In order to safely deliver to patients pharmaceuticals that both healthcare professionals and patients can use withpeace of mind, we strive to assure product quality and reduce costs at every stage of our supply chain, while
concurrently building a system for the stable supply of quality pharmaceuticals through constant efforts to develop
technologies and improve the relevant systems. We also improve our preparedness to take prompt and appropriate
action, even in the event of unforeseen circumstances, by reinforcing the functioning of our entire supply chain andfacilitating cooperation among concerned parties.

55 PRODUCT AND MEDICAL INFORMATION
In every country where we market our pharmaceuticals, with pride and a sense of mission as an organization involvedin the creation of “medicine” that has significant influence on people’s lives, in accordance with the applicable laws,
regulations and trade norms, we provide information to ensure the proper use of our pharmaceuticals as well as
important product information for patients and the medical fraternity. While monitoring healthcare conditions andever-changing patient needs in each country and region, we utilize appropriate measures to provide, collect, andcommunicate pharmaceutical information, both accurately and in a timely manner. We also provide information as apart of our effort to contribute to regional healthcare in collaboration with healthcare professionals and governments.

6 MANAGEMENT AND UTILIZATION OF
INTELLECTUAL PROPERTIES

We create, protect, and put to effective use our globally competitive intellectual properties related to pharmaceuticals,
which serve as the basis for our development of innovative pharmaceuticals and proper provision of opportunities forpatients to receive healthcare. We pursue intellectual property strategies, which are integrated with our management
and research and development strategies in order to establish our rights in a timely manner. Mitsubishi Tanabe
Pharma Corporation manages all intellectual property rights held by the Mitsubishi Tanabe Pharma Group in an
integrated manner and advances their optimal utilization and protection in order to contribute to enhancement of ourcorporate value by protecting, licensing, and otherwise utilizing our own pharmaceuticals and business activities.

7 OUR EMPLOYEES
To create innovative new drugs it is vital that employees constantly take on challenges for advancement without fearof failure, and that the organization and corporate culture is geared toward utilizing such talented individuals.
With this in mind, we remain flexible in administering our organization so that we can closely connect management decisions
with the challenges taken on by employees and produce good results through timely decision-making and actions.
We always assign the right people to the right positions by fully acknowledging the importance of different values
and suggestions of novel ideas from our diverse employees. In seeking to develop new drugs for which there
is a high social need and to maximize their value, we focus on developing professional expertise ineach aspect of our value chain, including research, development, production, and sales, and in
the corporate functions that underpin them.
Toward the goal of creating new value, we constantly seek synergy and cooperation
both within and outside of the company in order to establish or expand networks.
We promote work environments in which all individuals can find greatsatisfaction in their work while enjoying good health so that they can
maximize their abilities.

68 INFORMATION MANAGEMENT/SECURITY
Recognizing that information represents important management resources and assets, we systematically andefficiently manage and use our information assets according to their nature and significance. We have establishedand operate appropriate management systems and guidelines for maintenance and enhancement of information
security effectiveness. We also implement systematic, personnel-related, physical, and technical safety management
measures to ensure information security.

9 DISCLOSURE
We disclose information on our business activities that is reliable and useful for societies and stakeholders in a timely
and appropriate manner. When disclosing such information we do so accurately, promptly, proactively and withintegrity, taking due care not to infringe copyrights, privacy or other rights, so that every stakeholder can be given fair
access to the information disclosed.
We also disclose information on our clinical trials in a timely and appropriate manner and in accordance with the laws,
regulations, guidelines and trade norms in each country and region.

10 ENVIRONMENT AND SAFETY
In conformity with the overriding principle that safety is paramount, we strive to prevent disasters occurring at
workplaces and to implement adequate precautions and preparations against all contingencies, including
occupational accidents and disasters.
We also take continuing steps to reduce the impact of our corporate activities on the natural environment and we are
fully committed to community environmental conservation activities.

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11 RESPECT FOR HUMAN RIGHTS
We support the protection of human rights. We also support the elimination of any and all forms of forced labor andthe abolition of child labor.
We promote creation of healthy workplace environments in which everyone respects each other’s personality andhuman rights, feels free to speak openly about any matter and maintains good personal relationships. Furthermore,
we do not tolerate any act that could infringe fundamental human rights or devalue individual abilities, including casesof discrimination and forms of harassment.
We at the Mitsubishi Tanabe Pharma Group shall not treat our employees in a discriminatory manner on the basis of
ethnicity, gender, religion, or other grounds.

12 ASSURANCE OF FAIR BUSINESSWe always pay attention to any discrepancies between social norms and the company’s positions and never engage
in any conduct that would go against such norms.
Whilst strengthening corporate governance and promoting compliance, we check our internal control systems asnecessary and make any necessary improvements to increase their effectiveness in order to prevent risks fromarising.
In strict observance of the competition laws and other relevant regulations in each country, we engage in fair and freecompetition in the marketplace. We do not abuse our position in business transactions in order to impose
unreasonable requests, rather, we build relationships of mutual trust through fair transactions. We maintain sound andproper relationships in transactions associated with business activities on the basis of accurate understanding ofanti-corruption and bribery laws and regulations.
We put the capital, goods and other assets of the company to efficient and proper use in order to achieve efficientbusiness management. We are committed to maintaining sound and proper relationships with political bodies andgovernment agencies.
We use cell-based experiments and other methods as efficiently as possible and keep any animal-based testing to abare minimum.

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13 RESPONSIBILITIES AS A CORPORATE CITIZEN
In order to fulfill our social responsibilities as a good corporate citizen, we respect the cultures and customs of thecountries and regions in which we operate, conduct our business activities giving due consideration to such culturesand customs and promote worthy social contribution activities. We also provide individual employees with workplaceenvironments that make it easy for them to independently participate in volunteer activities.
(End)

Response to non-compliance
The Mitsubishi Tanabe Pharma Group defines “compliance” as “behavior that conforms to laws andregulations, in-house rules, and social norms,” and we are expected to meet an ever-expanding range ofdemands from society in this regard.
In the event that any suspicions or problems concerning compliance are raised in relation to our corporate
behavior, our employees consult with and report to their supervisors or compliance/legal affairs departments.
Requests for consultation and reports from employees are taken seriously and responded to in accordancewith the policies below, and investigations are conducted without delay. Each Group company has
established a hotline to assist in cases where consultation or reporting may be difficult.

[Policies on responses to consulting and reporting from employees]-Cases that have been consulted about or reported shall be responded to with fairness and integrity, and all
personal information shall be kept strictly confidential.
-No one shall be treated unfairly on account of issues that have been correctly consulted about or reported.
-No one shall be allowed to retaliate against any individual who has engaged in such consultation, submitted
a report, or cooperated in an investigation.

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Established as of July 1, 2017
Revised as of July 1, 2022