hhc & Compliance

ComplianceHandbook
Eisai Network Companies
Compliance Handbook

8th edition

American English Version
March 2021

Corporate Objective
A human health care company capable of making a meaningful
contribution under any healthcare system while observing thehighest legal and ethical standards in its business activities.

Message from the Chief Executive Officer
Corporate compliance incidents, also known as white-collar crimes, can have graveconsequences for individuals and companies. On the one hand, in cases involving
criminal intent, such as embezzlement of funds, the company would be required to claim
compensation from the wrongdoer or pursue criminal proceedings. In all cases, thewrongdoer will have to leave the company. On the other hand, there are cases where acompliance violation is committed because the wrongdoer believes it is in the company’s
interest. One such example is cartels, whereby price fixing or production adjustments may
falsely appear to improve profits temporarily. However, such incidents would lead to vast
amount of fines that are overwhelmingly greater than any financial gains. Wrongdoers,both employees and directors, may face prison sentences. And it takes huge amounts oftime and energy to resolve the problems created by the misconduct. It is wrong that suchaction might help the company. Compliance violations are never worth it.
Further, workplace cases such as harassment and discrimination cause enormous pain
to those affected and significantly disrupt the organization and culture of the company.
Any manipulation or misrepresentation of data, information, or product quality posesa severe risk to the company. Such a transgression can shake the very foundations of acompany, resulting in a loss of trust or the discontinuation of the company’s business. It
can even trigger the company’s downfall or an unwanted merger.
You might get the sense that you can do something because no one else would findout; you might think it is okay because you see people around you doing the same; oryou might feel it is permissible to some extent because it is within your discretion. But
these kinds of thoughts are signs of something rotten in the person and the organization.
There is no room whatsoever for such behavior in Eisai or for claims of extenuating
circumstances.
I want to emphasize strongly to you all that complianceis not optional for Eisai. It is an absolute prerequisite forthe trust placed in us by our valued patients and by all our
stakeholders.
March 2021

Haruo Naito
Representative Corporate Officer and CEO

1

Message fromthe Chair Person

The lifestyles and business styles ofpeople around the world have changed
dramatically. In particular, the number ofCommittee
face-to-face opportunities between people
has decreased significantly, making it
difficult to communicate in both life and business. We must respondquickly to changes without being bound by conventional methods.
In this way, as business practices change, compliance remains
the same. I have been advising on Eisai’s compliance promotion
for over 20 years since the establishment of the Compliance
Committee in Eisai. Today, Eisai has a great compliance programand promotion structure in place. However, this is meaningless if
each person is not conscious and compliant.
Eisai has created a globally common compliance handbook.
This Handbook is a collection of important things that each andevery one of you must protect, regardless of country or region. In
addition, the content presented in this handbook is based on morethan 20 years of Eisai’s compliance history, and its essence will notchange even after repeated revisions.

of Compliance

March 2021

D. Stuart Meiklejohn
Chair Person of Compliance Committee2

Message from the
Chief Compliance

In 2000, I was involved in launching thefirst global compliance program in Eisai as
one of the staff members. At that time, theenvironment surrounding compliance varied
from region to region, and I remember that
there was much resistance in applying global compliance standards.
However, thanks to the leadership of Mr. Meiklejohn of the Compliance
Committee and other members, we were able to set a global compliancestandard with a strong will. This has shaped the current complianceprogram of Eisai, and I am very proud to maintain it to this day.
As the times change, I feel that the demands for compliance havebecome more diverse, and also feel that the threshold for demands isconstantly increasing. In revising this Handbook, I firmly accepted thechanges and continued to think about what I should do to make Eisai
better.
As you know, compliance-based business activities cannot be
achieved only by the efforts of the Chief Compliance Officer and theCompliance Department. The most important thing is the constant effortof everyone reading this handbook. Please use this handbook to ensurethat everything you do at Eisai “in compliance with all relevant laws andethical standards.”
The most important thing to solve a compliance issue is to detect
and respond in early stages. Eisai has a whistleblowing system in place
to protect whistleblowers, so if you detect a compliance violation orsomething that might lead to it, please contact
the Compliance Department promptly.

OfficerMarch 2021

Mitsuaki Tanaka
Chief Compliance Officer

3

Eisai Charter of Business Conduct

Established: March 2000
Revised: March 2021

We give first thoughts to patients and their families. We strive toincrease the benefits that healthcare provides them and we conduct
our business to meet their diversified healthcare needs worldwide.
As a human health care (“hhc”) company, we develop and provide
products and services that contribute to the well-being of patientsand customers under any healthcare system.
In order to realize our corporate philosophy, we develop
business activities that contribute to sustainable economic growth
and the resolution of social issues, as well as make decisions andact appropriately and in a timely manner, in compliance with all
relevant laws and ethical standards.
We hereby establish our Charter of Business Conduct asa statement of our commitment to compliance. Compliance isessential to the company’s existence and is given top priority in all
corporate activities. Corporate executives recognize that it is theirrole to lead the employees by implementing the content and spiritof this Charter in all the work they do and in supervising those whowork with them. By adhering to this Charter, they will inspire andencourage everyone to apply these standards in all their activities.
Everyone is expected to abide by the content and spirit of thisCharter.

4

1. W
 e promote mutual respect and trust in our business relationships
with our stakeholders including patients, customers, shareholders,investors, employees, healthcare providers, business partners andcommunities.
2. W
 e compete fairly, and do not tolerate bribery or any other form ofcorrupt business behavior.
3. W
 e appropriately manage information and ensure our records areaccurate, complete, fair and secure.
4. W e appropriately disclose corporate information in a timely
manner, and communicate with stakeholders transparently.
5. W
 e act in the workplace in accordance with the principles offairness, respect, and non-discrimination with respect for diversity.
6. W e provide a work environment that takes health and safety into
consideration.
7. W
 e comply with all relevant laws and regulations of eachjurisdiction in which we do business and we conduct ourselveswith the highest sense of ethics.
8. W
 e respect human rights and do not tolerate, within the scopeof our business and in our supply chain, modern slavery such as
child labor, forced labor and human trafficking.
9. A
 s a “good corporate citizen,” we contribute to the resolution ofsocial issues and the development of society.
10. We maintain fair and transparent relations with political andgovernment entities.
11. We shall not enter into, or to the extent we become aware weshall sever, relations with organized crime groups.
12. We place global environmental protection as an importantcomponent of business operations and strive to maintain theenvironment.

5Compliance at Eisai

1

What does Compliance mean at Eisai?

Compliance at Eisai means not only abiding by written standards such as
laws, regulations, and Eisai policies and procedures, but also upholding ethicalstandards that are integral to how we operate.
Eisai’s ethical standards are, in all business activities, to give first thought topatients and their families, and to increase the benefit that healthcare provides
them, as well as to behave with integrity, respect, and openness.

INTEGRITY

We act with INTEGRITY, interact in a responsible
manner, and aim to ensure that our communications
with stakeholders are accurate, legitimate, and balanced.

RESPECTWe interact with all our stakeholders with RESPECT.
We commit to approach our stakeholders in an open
manner.

OPENNESS

We are committed to ensuring that OPENNESS isrespected. We are open about our activities andinteractions to stakeholders.

Eisai Compliance
Laws and regulations,
Eisai policies and procedures

6

Ethical standards
Integrity, respect, openness

2

The Structure of the Compliance function at Eisai

The Chief Compliance Officer is responsible for developing a global compliancestructure and for promoting the highest standards of compliance with laws andregulations, Eisai policies and procedures, and ethical standards of INTEGRITY,RESPECT, OPENNESS. In addition, Regional Compliance Officers and/or Regional
Compliance Departments, are responsible for implementing global complianceinitiatives as well as devising a Compliance Program and implementing Complianceactivities specific to their regions.
Compliance activities periodically undergo objective reviews by Compliance
Committee members who are external experts, such as lawyers from inside andoutside Japan.
In Eisai, the Compliance Program includes having a compliance structure, Eisai
policies and procedures, good communication and effective training, reporting andinternal controls, and processes to enable employees to report compliance concerns.
The Structure of the Compliance function in Eisai
The Chief Compliance Officer

adviceCompliance Committee

Corporate Compliance &Risk Management Department
Regional Compliance Officers and/or
Regional Compliance Departments

3

The Regional Compliance function

The Compliance function, however it is structured in the various Regions in Eisai, is
responsible for the implementation of the global and regional Compliance Program.
The Compliance function acts as a valued adviser to the business to achieve
their objectives whether by way of consultation, guidance, or when someone raises
a concern about non-compliance.
The Compliance function, in most cases, is also charged with carrying out
investigations into allegations of potential non-compliance.
The aims of the Compliance function are to support individuals working for or on
behalf of Eisai to meet the highest levels of compliance with laws and regulations,
Eisai policies and procedures, and ethical standards.

7

Contents

Message from the Chief Executive Officer....................................................1
Message from the Chair Person of Compliance Committee. ..........................2
Message from the Chief Compliance Officer.. ...............................................3
Eisai Charter of Business Conduct.. .............................................................4
Compliance at Eisai....................................................................................6

What Eisai’s Code of Conduct means
to each of us

Part

1

11

1.1 O
 ur responsibilities.............................................12
1.2 A
 dditional responsibilities of corporate executives,and managers....................................................13
1.3 A
 sking questions and reporting complianceconcerns............................................................14

Our working environment

17

2.1 D
 iscrimination.. ...................................................18
2.2 Harassment.. ......................................................19
2.3 H
 ealth and safety.. ..............................................21
2.4 Abuse of drugs and alcohol. ................................22
Part

2
Business activities

Part

8

3

23

3.1 R
 esearch and development.................................24
3.2 M
 anufacturing and distribution............................27
3.3 P
 romotional communication................................28
3.4 Adverse events and safety...................................30
3.5 Interactions with Healthcare providers, Healthcareorganizations and Patient Groups, etc.................32
3.6 Fair trade and competition practices....................33

Fraud prevention

Part

4

4.1 F
 raud risk and prevention....................................36
4.2 C
 onflicts of interest.............................................38
4.3 C
 orrupt practices and bribery..............................39
4.4 M
 isappropriation of assets..................................41
4.5 P
 roper financial reporting....................................42
4.6 P
 revention of data fraud......................................43

Proper use and management of
information

Part

5

6

45

5.1 K
 eeping records.................................................46
5.2 Intellectual property............................................47
5.3 A
 ppropriate management of information assets....48
5.4 Use of social media.. ...........................................51
5.5 Insider information and trading............................52

Relationship with society

Part

35

53

6.1 H
 uman rights......................................................54
6.2 Environmental protection. ....................................55
6.3 T
 ax payments and financial statements................56
6.4 Donations...........................................................57
6.5 O
 rganized crime ................................................58

9

Code of Conduct

A: What is Eisai’s Code of Conduct?
Eisai’s Code of Conduct defines the ethical standards for
all corporate executives and employees in accordancewith the Eisai Charter of Business Conduct.
B: Who is this Code of Conduct for?
This Code of Conduct applies to all corporate executives
and employees.

The following pages outline the Code of Conduct,
and provide specific examples of how theguidelines should be applied.

10

CHECK!

1

Code of Conduct

Part

What Eisai’s
Code of
Conduct means
to each of us

1.1 Our responsibilities
1.2 Additional responsibilities ofcorporate executives andmanagers
1.3 Asking questions and reporting
compliance concerns

11

1.1
Our
responsibilities

Corporate executives and employees are responsible forbeing trained on, understanding, and applying relevantlaws and regulations, Eisai’s ethical standards, policies
and procedures, and rules that apply to our work.
Although it is difficult to be prepared for every possible
situation in our daily work, this Handbook can help us
recognize some potential issues and give us basic
guidance on how to respond in different situations.
We should ask our superiors if we have questions or
are unsure about how to deal with situations which would
be difficult to judge only by the Handbook, policies, orprocedures, or we are unsure how to apply Eisai’s ethicalstandards in a given situation.
Eisai resources, such as the local or regional
Compliance Contact or Helpdesk, ComplianceDepartment (“Compliance”), Human Resources
Department, or Legal Department, can also help if yoursuperiors are unable to provide clear guidance, or if you
are more comfortable discussing a concern withsomeone other than your superiors.
We have an obligation to report concerns regarding
non-compliance with written standards and Eisai’s ethicalstandards.
We are also obliged to cooperate with investigations
conducted by the compliance function.

12

What Eisai’s Code of Conduct means to each of us

1.2
Additional
responsibilities
of corporate
executives andmanagers

Part 1

In addition to the responsibilities described in “Ourresponsibilities” in the previous section, corporate
executives and managers are not only expected to leadby example, but also must guide and train employees
when applying relevant laws and regulations, Eisai’s
ethical standards, policies and procedures to our day-today activities.
Corporate executives and managers are responsible
for ensuring that compliance concerns in their area areproperly handled and resolved. Prompt and accurateinternal reporting of compliance concerns is essential to
the success of the compliance program. The compliance
performance of corporate executives and managers is a
critical part of their management performance and they
are evaluated on that basis.
Eisai gives its corporate executives and managers
responsibilities for the compliance program, but theBoard of Directors oversee the overall implementation of
the compliance program and is responsible for ensuringthat appropriate structures and systems to enforce
compliance are in place and are operated effectively.

13

1.3
Askingquestions andreportingcomplianceconcerns

1.3.1

Reportingcomplianceconcerns

It is everyone’s responsibility to ensure that laws andregulations, and Eisai’s policies, procedures, and ethicalstandards are upheld. When the right thing to do is notclear to us or something does not seem right, we should
ask questions or report our concerns. Failing to do theright thing may also damage Eisai’s business, reputation,and patients.
If we are unsure that what we or our colleagues are
doing complies with written and ethical standards, orwhen we become aware of non-compliance, we should
speak with our superiors or consult with Compliance,
Human Resources, Legal, or the Relevant Department as
appropriate. The earlier the company knows about them,the sooner it can investigate and take appropriate action.

We should always report something we believe does notcomply with relevant laws and regulations, and Eisai’s
policies, procedures, and ethical standards. If we are notsure, we should contact Compliance.
Compliance can help:• when we are not sure that what we or our colleagues
are doing is compliant or ethical;• if we want to speak to someone other than our
superiors, or we do not believe that our superiors’
advice meets Eisai’s standards; and• when we report an activity that may not comply with
policies, procedures, and ethical standards.

14

What Eisai’s Code of Conduct means to each of us

Part 1

Compliance cannot help:• with advice for personal legal issues or other issues
not related to work at Eisai; or• if we knowingly make a false compliance report.

1.3.2

Policy ofnon-retaliation

Eisai encourages everyone to report complianceconcerns and does not tolerate attempts to stop
someone from making a report. No one will be punishedor disciplined for making a report in good faith.
Additionally we will not allow anyone to interfere with aninvestigation of a compliance concern or retaliate against
the person who reported it. Any attempt to interfere withan investigation or to retaliate may result in disciplinary
action.
The policy of non-retaliation applies to every Eisai
employee, including the report investigator and individuals
cooperating with the investigation.

15

1.3.3

Confidentiality

Be assured that reports of compliance concerns will betreated confidentially and information will be shared only
in order to carry out any necessary investigation.
Corporate executives and employees who have beenasked by Compliance to investigate are prohibited fromdisclosing information regarding the matter to others
unless authorized by Compliance.

Scenario & Advice
I think a colleague may have violated
Eisai policy. What should I do?

16

You should report it to yoursuperiors or Compliance.

2

Code of ConductPart

Our working
environment

2.1 Discrimination
2.2 Harassment
2.3 Health and safety
2.4 Abuse of drugs and alcohol

17

2.1
Discrimination

Eisai respects the human rights of everyone who works
for Eisai. Eisai welcomes and respects diversities, andbelieves in the fair treatment of everyone. Eisai policies areintended to encourage the professional growth anddevelopment of everyone in a work environment that is
free from discrimination.
All of our activities, including recruitment, training,exchange, annual evaluations and promotions, reflect
those policies.
Eisai does not tolerate any discrimination in ourorganization.
Examples of discrimination include,
but are not limited to:race, physical characteristics such as color, age,pregnancy, gender, sexual orientation, ethnicity,disability, religion, political affiliation, union
membership, or marital status, etc.

18

We should• treat everyone with respect.

We should not• make decisions regarding any employee or applicant based on
attributes not related to the person’s job performance, behavior,or qualifications.

Our working environment

2.2
Harassment

Part 2Eisai does not tolerate anyone making sexual advances
toward any corporate executives and employees in theworkplace or work-related environment, or taking
intimidating or offensive actions that create a hostileworking environment.
Everyone has the right to work in a place that is freefrom harassment and no one should engage in conductthat constitutes harassment.

We should• treat everyone with respect and act as professionals.

We should not• make or use sexual or other offensive or inappropriate
comments, pictures, or written text.

19

Scenario & Advice
A colleague talks
about sexual mattersand tells sexual jokes
during lunch break. Whatshould I do?

Behaviors or actions which make you
uncomfortable and unreasonably interfere withyour work performance may be consideredharassment. To some extent, this is a question ofdegree, but in appropriate cases, you should let yourcolleague know that this behavior is offensive to you or
your colleagues and ask him or her to stop. You may
also consult with your superiors, Compliance, or Human
Resources for further guidance.

Scenario & Advice
A colleague of minealways yells at me.
What should I do?

20

Such behavior by your colleague may beconsidered harassment. Please consult with yoursuperiors, Compliance or Human Resources.

Our working environment

2.3
Health andsafetyPart 2Eisai provides a work environment that complies withhealth and safety laws and regulations. We should all beaware of the safety procedures applicable to our activities
and follow them. We must immediately report any
accident, or unsafe or potentially hazardous practice or
condition, including actual or potential security risks, toour superiors or the relevant department.
Eisai believes that ensuring the safety of employees,
who play a key role in realizing hhc, is always a toppriority. In the event of a pandemic, disaster, etc., wemust endeavor to ensure the health and safety ofourselves and our families in accordance with the rules ofprocedures of administrative instructions regarding crisis
management established by each country or region.
Certain areas of our business, such as Research andDevelopment and manufacturing, involve the handling ofmaterials and equipment that can pose hazards to thehealth and safety of employees, and may impact theenvironment, which are regulated by laws.
If we are involved in these types of activity, we should
adhere to the relevant laws and regulations, Eisai policies,
procedures, and rules regarding how to work with thesematerials or equipment.

We should• be aware that not complying with health and safety laws,
regulations, Eisai policies and procedures can lead to serious
health and safety problems;• obtain written approval from the appropriate superiors if there are
no relevant laws and regulations, or Eisai policies or procedures
related to health and safety; and• immediately report accidents and unsafe or potentially
dangerous practices to superiors or the relevant departments.

21

2.4
Abuse of drugs
and alcohol

The abuse of drugs and alcohol not only can lead tosignificant health problems but anyone under the
influence of drugs or alcohol while in the workplace, canbe a hazard to themselves and the others. Eisai does notallow the use or unauthorized possession of illegal drugs
at work. The consumption of alcohol on site without
permission is also prohibited.

We should• be aware that the abuse of drugs or alcohol can be dangerous in
the workplace.

We should not• drink alcohol in the workplace without appropriate permission.

Scenario & Advice
We want to hold a celebration forthe launch of our new product inour department. We want toserve food and alcoholic beverages.
Since it is a celebration, is it all right tohave alcohol at work?

22

It might be, but in any event, youmust obtain appropriate managerial
approval or approval as set out inyour local policy before you have alcohol ata work event.

3

Code of Conduct

Part

Business
activities

3.1 Research and development
3.2 Manufacturing and distribution
3.3 Promotional communication
3.4 Adverse events and safety
3.5 Interactions with Healthcare
providers, Healthcareorganizations and PatientGroups, etc.
3.6 Fair trade and competition
practices23

3.1
Research anddevelopment

3.1.1

Respect for clinical
trial participants

3.1.2

Data integrity

24

Research and Development activities are the basis of
Eisai’s business and are essential to achieve our hhc
mission. We engage in Research and Development
activities that comply with all regulations andinternationally recognized standards (e.g., Good
Laboratory Practice (GLP) and Good Clinical Practice(GCP)), and we adhere to high ethical standards.

Eisai respects the principles of GCP for clinical trials
including the human rights, safety, and ethicalconsiderations of trial participants. Prior to participating ina clinical trial, sufficient explanation must be given andwritten consent from the clinical trial participant must be
obtained. Ensuring safety in clinical trials is a top priority.
Special attention should be paid to First in Human (FIH)
study, which is administered to humans for the first time.
Data integrity, meaning the reliability and trustworthinessof data throughout its life cycle, is of the utmost
importance to Eisai. We recognize that in order to build
trust with the public and to support our scientificdiscoveries, we must ensure that the data supporting
those discoveries are sound and secure. Eisai maintains
policies and conducts training to ensure that we areadhering to principles that preserve data integrity,especially in our clinical trial work.

Business activities

3.1.3

Part 3We must disclose, in a timely and accurate fashion,
clinical trial results, regardless of outcome.

Disclosure ofclinical results

3.1.4

Handling regulated
chemicals andmaterials

In the process of Research and Development, we createand handle various chemicals and materials such as
narcotics, anti-hypnotics (and their raw materials),
psycho-pharmaceuticals, and other hazardous chemicals.
It is necessary to follow appropriate procedures tocreate and handle such chemicals and materials.
Chemicals and materials may be hazardous if they are
not properly handled (including living organisms andradioactive materials) and may impact the environment(including genetically modified organisms). Eisai adheres
to all relevant laws and regulations governing theappropriate handling of such substances.

25

3.1.5

Animal research

Eisai accepts that animal research is a necessary andrequired part of verifying safety and efficacy in thedevelopment of new drugs. We are dedicated to thehumane care and treatment of the laboratory animals weuse. Our animal research is overseen and guided by an
Institutional Animal Care and Use Committee (IACUC),
which includes external specialists.

Our research is conducted with scientific rigor, and due consideration is given to thewell-being of the animals as well as to the 3R Principles of animal research:• Replacement : Evaluating alternative techniques for animal research• Reduction: Reducing the number of animals used to a minimum• Refinement : Minimizing pain and suffering of animals to be used in research

We should26• prioritize patient safety prior to conducting testing on humans;• conduct our Research and Development activities strictly inaccordance with Eisai’s policies and procedures;• take steps to secure appropriate intellectual property protection
for any Research and Development work Eisai does; and• follow Eisai’s guidelines on preserving data integrity anddisclosing truthful and accurate results from clinical trial(s).

Business activities

3.2
Manufacturing
and distribution

Part 3Eisai’s manufacturing and distribution activities comply
with all laws, regulations, and internationally recognized
standards (e.g., Good Manufacturing Practice (GMP) andGood Distribution Practice (GDP)). Eisai manufactures
pharmaceutical products of high quality to ensure thehealth and safety of patients. We carry out our
manufacturing activities with due regard for health, safety,
and the environment. In addition, manufacturing andquality activities must be carried out in accordance withthe methods or conditions for which the product has
been approved by the authorities.
We have a mission and responsibility to maintain astable supply of high-quality medicines. In order toachieve that goal, we must strive to ensure quality with athorough system in all processes from manufacturing to
distribution.
In order to ensure the quality of pharmaceuticalproducts, we carry out appropriate raw material
procurement, manufacturing control, and quality control,
not only at our own factories but also at contract
manufacturing companies, and it is necessary to build
and implement a mechanism to ensure quality at the
distribution stage.
We need to have a management system in place toprevent acts that violate GMP and GDP-related laws,
Eisai policies and procedures.

We should• ensure that there is a system for manufacturing and distributing
high-quality pharmaceutical products; and• be aware of and report any events and actions that raise doubts
about the quality of pharmaceutical products to our superiors or
the Quality Assurance Department.

We should not• violate GMP, GDP, and other laws and regulations, or related
Eisai policies and rules; or• use manufacturing methods and quality control that differ fromthe conditions for approval by the regulatory authorities.

27

3.3
Promotional
communication

28

Eisai markets and promotes its pharmaceutical products
worldwide. We provide accurate and balanced scientificinformation, and promote our products only for the uses
for which they have been approved by the applicableregulatory authorities.
“Promotion” means any activity undertaken,organized, or sponsored by a pharmaceutical company
which is directed at Healthcare Providers (HCPs) topromote the prescription, recommendation, supply,
administration, or consumption of its pharmaceuticalproducts through all methods of communication,
including the Internet. When engaging in promotional
activities with HCPs, we are expected to be familiar withlocal laws and regulations for such engagements in ourhome country. Promotion in a manner not consistent withthe approved label is prohibited and promotion of drugs
prior to approval is also prohibited. All promotional
materials must be reviewed and approved in accordancewith local processes and may be used only for theapproved purpose.

We should• provide accurate and balanced scientific information regarding
our products’ appropriate use and safety information; and• conduct promotional activities using only materials that havebeen approved by the relevant department in our company.

We should not• conduct promotional activities inconsistent with the approved
label or promote drugs prior to approval.

Business activities

Part 3

Scenario & Advice
I found an article in a
reputable medical
journal regarding one of
our products. May I circulate it
to our sales representatives touse as a reference?

Not unless it has been approved by therelevant department. Sales representatives
may use only those documents and materials
that the relevant department in our company has
reviewed and approved for promotion and advertising.

29

3.4
Adverse eventsand safety

The safety of our products, whether they are underdevelopment or on the market, is fundamental to our hhc
mission. We are obliged by law to collect and report all
information regarding the safety of our products.
Eisai is responsible for reporting adverse events togovernmental or regulatory authorities. If any of us
becomes aware of an adverse event related to an Eisai
product, we should immediately report it to our local
Pharmacovigilance Department in accordance with local
standards.
If we are not sure how to proceed, we must ask our
superiors or contact our local Pharmacovigilance
Department.

30

We should• report immediately all adverse events and safety information onmarketed products, as well as on products being used in clinical
trials, to the appropriate Local Safety Officer (LSO) or
Pharmacovigilance Department.

We should not• ignore or attempt to conceal adverse information about our
products.

Business activities

Part 3

Scenario & Advice
A friend of my friend has posted
on social media that they felt
unwell after taking an Eisai
product. Do I need to report it tosomeone?

Yes. You must report the message
you have seen to your Local Safety
Officer (LSO) or Pharmacovigilance
Department in accordance with your local
procedures.

31

3.5
Interactions with
Healthcare
providers,
Healthcareorganizations
and PatientGroups, etc.

We engage in various interactions with HCPs and
Healthcare Organizations (HCOs) through promotional
activities, including clinical research, sharing the besttreatments, and exchanging information on how new
drugs adapt to patients’ illnesses, etc. Our mission, thedesire to contribute to patient’s well-being, is our
corporate philosophy and the core of our business. In
order to fulfil our hhc mission, Eisai spends time withpatients or caregivers to understand their true needs,
which ultimately helps to drive innovation.
In all of these and other interactions, it is importantthat we ensure that any interactions with patients or
HCPs are in accordance with applicable laws, regulations,and Eisai policies and procedures.
We should keep in mind the following wheninteracting with HCPs, HCOs, and Patient Groups:• Interact with HCPs and HCOs only for legitimate
business purposes.
• Follow the various local laws, regulations, policies,
and procedures applicable to interactions with HCPs
and HCOs or Patient Groups.
• Ensure that any compensation provided to HCPs,
HCOs, or patients is in accordance with fair market
value for the particular service provided.

Disclosure ofpayments to HCPs,
HCOs and PatientGroups32

The collaboration Eisai has with HCPs, HCOs and PatientGroups is important to us. In many areas where Eisai
does business, we are sought reporting on theinteractions with HCPs, HCOs and Patient Groups as apharmaceutical company. We need to comply with local
or national disclosure rules, provide necessary
information, and may need to disclose payments to
HCPs, HCOs, and Patient Groups.

Business activities

3.6
Fair trade andcompetition
practices

Dealings withcompetitors,
distributors,
customers, andsuppliers

Part 3Eisai’s policy is to compete fairly and legitimately, and tocomply with anti-trust and competition laws in eachcountry in which we operate. Acts or practices of unfair
restraint of trade, for example, cartels, price-fixing, etc.,
are prohibited. In addition, any discussion of pricing or
discounts must be done in accordance with local
standards.

Certain formal or informal agreements or understandings
with competitors, distributors, customers, and suppliers(“Third Parties”) may be prohibited under competition
laws. In some cases, even discussion about the sensitive
topics listed below may violate those laws. Therefore, weneed to seek guidance from our local Legal Department
before having any interaction involving these sensitive
topics (listed below).
Sensitive topics for discussion with Third Parties• Pricing, costs, or profits• Terms or conditions of sale (including credit
extensions or information)• Entering or leaving, or dividing with one or more othercompanies, products, services, or geographic
markets• Market share or production or sales volume• Decisions to bid or quote or otherwise divide up
customers, suppliers, or distribution channels• Whether and how diligently to pursue R&D projects• Terms under which a purchaser of our products
resells the products (including price or whether thepurchaser can resell)• Unfair restriction of competitors, etc., manufacturing,purchase, sale, or provision of products or services toanother party

33

We should• take measures to avoid discussion of sensitive topics with Third
Parties and, if required, remove ourselves from any such contact
at the earliest opportunity;• obtain prior written approval from Legal Department for any
agreement or understanding with any Third Parties about any
sensitive topic; and• report contact with Third Parties in line with company policy.

We should not• communicate or agree with Third Parties about sensitive topics
without consulting with Legal Department.

Scenario & Advice
I just want to talk toother market
participants aboutsome issues having to dowith standard practices,which I think will be in all ourinterests. Is there any reason
I can’t do that?

34

Yes, there may be. Competition laws assert thatmarkets should not be without competition.
Competitors are supposed to make independent
business decisions. If they have agreements orunderstandings with their competitors about sensitive
topics, they may violate competition laws in the process.
Eisai will not tolerate such actions, which may expose
the individuals involved, as well as Eisai, to legal liability.

Code of Conduct

Part

4

Fraud
prevention

4.1 Fraud risk and prevention
4.2 Conflicts of interest
4.3 Corrupt practices and bribery
4.4 Misappropriation of assets
4.5 Proper financial reporting
4.6 Prevention of data fraud

35

4.1
Fraud risk andprevention

Eisai provides guidelines to detect and prevent fraud,misappropriation, and other infringements. Fraud isdefined as the intentional, false representation orconcealment of a significant fact which brings great
detriment. We should well understand the types ofinfringements that could occur within the scope of ourwork.
The following risks of fraud exist around us. We needto take measures to prevent fraud, such as bystrengthening internal controls.
Examples of Fraud risks• Conflict of interest (a situation in which one’s interestsor those of a business partner are prioritized overEisai’s interest in transactions with interested
business partners)• Bribery (providing money or goods to civil servants,etc.), illegal rewards, etc.
• False expense reimbursement, expense inflating,private purchase, asset theft/unauthorized use, etc.
• Finance (overstatement of sales/assets, concealmentof liabilities, inappropriate asset valuation, etc.)• Non-financial (falsification of in-house materials and/or certificates, data fraud, etc.)

36Fraud prevention

Part 4

We must comply with the laws, regulations, and Eisai
policies and procedures related to our duties. Below are
the various global guidelines Eisai has implemented tohelp prevent fraud.
Guidelines for preventing fraud• Eisai Internal Control Policy• Eisai Internal Control Guideline• Eisai Global Code of Conduct for Business Partners• Eisai Guideline for Segregation of Duties• Eisai’s Anti-Bribery and Anti-Corruption Policy

Due diligence
related to business
partners

Eisai may be liable for fraudulent activities by our business
partners. We need to ensure that our business partners,in doing business for us, comply with the same standards
we set for ourselves. We must properly perform due
diligence on our business partners in accordance with thefollowing global policies and local laws, policies,
guidelines, and procedures before we start business witha new partner.
• Eisai Global Code of Conduct for Business Partners• Eisai’s Anti-Bribery and Anti-Corruption Policy• Eisai Sustainable Procurement Policy• Human Rights Policy

37

4.2
Conflicts ofinterest

When we make professional judgments or act on behalfof Eisai, we are responsible for doing so impartially and in
the best interests of the company. A conflict of interest
exists when our personal interest is inconsistent withthose of Eisai’s and causes conflicting loyalties. This
conflict may cause us to make a biased business decisionthat may not be in Eisai’s best interests.
If there may be such possibilities existed actual
conflicts occurred, we should report them to our superiors
so that appropriate solutions can be found, such as
removing ourselves from the decision-making process.
Examples of potential conflicts• Accepting a position with an existing or potential
business partner or competitors while employed at
Eisai• Accepting anything of value including cash, gifts orentertainment, or favors from a business partner• Owning shares of existing or potential business
partner or competitors• Conducting business with companies owned byfamily members or friends

Scenario & Advice
I have someshares of acompany that
does business with Eisai.
Do I have to disclose thisinformation to Eisai?

38

There may be an issue with your owning shares ofa company that does business with Eisai, and you
must disclose this information to Eisai. Your
ownership of the shares means you have a personal
interest that may be different from Eisai’s and the potential
for a financial gain at Eisai’s expense. You need to let Eisai
determine how to deal with the situation.

Fraud prevention

4.3
Corrupt
practices andbribery

Part 4Eisai’s policy prohibits bribery including facilitation
payments* or other corrupt conduct in Eisai businessdealings, either directly or by third parties acting on ourbehalf.
Many countries have laws, regulations, rules, codes,
and guidelines (“laws”) that prohibit bribery of public
officials or any other private persons or organizations.
These laws forbid making, offering, or promising any
payment or giving anything of value to public officials or
any other private persons or organizations for the purposeof inappropriately influencing decisions by public officials,
private persons, or organizations, to secure improper acts
in connection with the supply of goods or services to orfrom Eisai. We should recognize that violation of theselaws may result in criminal charges not only against Eisai
but individuals as well.
Additionally, because our pharmaceutical business isregulated by many public authorities in and around theworld, we must ensure that Eisai has appropriate
interactions with such authorities and that
communications with such authorities are accurate,complete, timely, and transparent.
* Facilitation payments mean payments of a small amount of money forthe purpose of facilitating procedures related to administrative services.

39

40

We should• follow written standards for dealing with third parties, whether
they are public officials or any other individuals or organizations;• obtain approvals for all gifts, hospitalities, and expenses inaccordance with local standards; and• report to superiors, Compliance, or the Relevant Departments incase to witness or to recognize any suspicious transactions by athird party acting on behalf of Eisai.

We should not• give, promise, or offer anything of value which is or may beperceived as an inducement for improper conduct; or• contract with a third party without conducting appropriate due
diligence.

Fraud prevention

4.4
Misappropriationof assets

4.4.1

Asset preservation

4.4.2

Use of expenses

Part 4

We need to properly manage the appropriate level ofinternal controls, separate responsibilities, establish
approval authorities, and prevent the diversion of assets.
Misappropriation of assets may include false settlement ofexpenses, inflated expenses, private purchases, theft or
misuse of assets, etc. It is said that these frauds often
allow employees to gain profits within their responsibilities
without being known to others. We must properly protect
assets and use and settle expenses.

We are responsible for preserving assets so that they are
acquired, used, and disposed of under due process andapproval. Unauthorized or inadvertent acquisition, use, or
disposal of assets can result in significant damage to or
impact on Eisai’s property and social credibility, as well as
financial loss. Eisai’s assets include tangible assets suchas land, buildings, machinery, equipment, inventory,
computers, and cash; and intangible assets such as
intellectual property (patents, trademarks, copyrights,etc.) and confidential information. We must properly
preserve these assets.

Proper use and settlement of expenses is the basis ofbusiness activities. Eisai does not allow false settlement ofexpenses, inflated expenses, private purchases, or otherunauthorized use of expenses. Corporate executives andemployees must properly use and settle their expenses inaccordance with the rules regarding the use andsettlement of expenses.

41

4.5
Proper financial
reporting

As we are a publicly listed company, we are required toestablish, develop, and implement internal controls andaccurately disclose information about certain types ofcorporate activity in our annual reports. We do nottolerate fraudulent activities, such as overstatement ofsales or assets, hiding of liabilities, or improper asset
valuation.
In order for Eisai to fulfil its responsibility to disclose
appropriate corporate information and to makeappropriate business performance decisions, it isimportant to create and store transaction records fairly
and appropriately. The same applies to transactions
conducted not only with our own company’s expenses
but also to those conducted with expenditures fromoutside Eisai, such as subsidies.
We must clarify accounting facts and properly createtransaction records in accordance with Eisai’s rules sothat the actual conditions of purchasing, inventory control,
sales recording, etc., are properly reflected.

Report of fraudulent
accounting

42

We are obliged to report any false or counterfeit records
of corporate books in the event that we detect that there
are funds or assets that are not recorded in our
accounting books. If we detect or suspect fraudulent
accounting, we must contact Compliance immediately.

Fraud prevention

4.6
Prevention ofdata fraud

Part 4

We have the opportunity to acquire important data in all
operations, including finance, Research & Development,
clinical development, manufacturing, and quality
assurance.
We must ensure the reliability of our data inaccordance with policies, rules, and laws set by eachcountry and region or by each department. Forgery or
tampering with data is never tolerated, and data must be
acquired, verified, stored and used in an appropriatemanner. In addition, it is necessary to establish an
appropriate mechanism to deal with fraudulent activities(fabrication of non-existent data and results, falsification ofobtained data, concealment of inconvenient data andresults, plagiarism of the results of the research of others,etc.).
In the event that we detect or suspect fraud, we must
contact Compliance.

We should• obtain, verify, store and use data related to finance, R&D,
manufacturing, or quality in an appropriate manner, and establish
an appropriate mechanism to prevent fraudulent activity; and• immediately report to the superiors, Compliance, or the Relevant
Department if we detect or suspect fraud, negligence, or
improper operation related to data such as finance, R&D,
manufacturing, or quality assurance.

We should not• fabricate, falsify, conceal, or steal data or records such as
finance, R&D, manufacturing, or quality assurance, etc.

43

44

5

Code of Conduct

Part

Proper use andmanagement of
information

5.1 Keeping records
5.2 Intellectual property
5.3 Appropriate management of
information assets
5.4 Use of social media
5.5 Insider information and trading

45

5.1
Keeping records

Documents are the records of a company. Individuals
may remember events, but their memories are notconsistently reliable. People inside and outside thecompany regard documentary records as much more
important in trying to reconstruct things that happened in
the past.
Not everything that happens needs to be
documented. But we need to be aware that when we
write emails or other messages, when we leave voice
mails, and even when we have telephone conversations,
if they are recorded, we are creating documents.
It is essential that documents be created for mattersthat need to be documented. There are many laws, rules,
regulations, and Eisai policies and procedures that coverthese topics. We need to be fully aware of the ones that
apply to our work. It is also essential that when
documents are created, they be timely, accurately andthoughtfully prepared so they are not misunderstood lateror taken out of their proper context. Retained records
must have a retention period that suits their purpose.
The knowing creation of false documentation, theimproper alteration of documents and the intentional
destruction of documents within approved retention
period — all these things make it impossible to rely on thecompany’s memory. Such misconduct is a violation ofcompliance and will be punished, up to and including
termination from employment.

46

Proper use and management of information

5.2
Intellectual
property

Part 5

We spend a great deal of time, effort, and money on
developing valuable new products to improve patients’
health and quality of life. The course of this productdevelopment, may give rise to valuable assets in the formof intellectual property rights such as patent rights, design
rights, trademark rights, copyrights, expertise, or trade
secrets and these to be protected and secured. It is
important to remember that any asset an employee
creates while employed by Eisai is the property of Eisai
but not the employee.
We must also respect intellectual property rights
which belong to other people or companies, and we may
not use intellectual property owned by a third party
without the third party’s permission.

Scenario & Advice
I found a third
party’s productwith a name andpackaging substantiallysimilar to one of our
products. Is there
anything I can do?

Our product names and product packaging designs
are protected under trademark laws or relative laws
in most countries. Such protection given by laws
may be seriously undermined if Eisai does not takeappropriate countermeasures immediately. Therefore, if you
find such a product, please contact Compliance as soon
as possible so Eisai can take appropriate actions.

47

5.3
Appropriate
management of
information
assets

5.3.1

Protection of
personal data

48

Eisai has established a management system in place fordata protection and legal compliance. Also, Eisai manage
IT security risks, including personal information andconfidential information.
If personal or confidential information is leaked
fraudulently or accidentally, it may cause not only financial
losses but also serious damages to or impact on Eisai’s
property and social credibility. In the unlikely event that it
is leaked, it is important to take prompt action to minimize
the damage. If we suspect a leak, contact our superiors
and Compliance.
In the course of its business, Eisai obtains personal
information about its employees, patients, healthcare
providers, suppliers, customers and contractors. Personal
information designated for protection is defined inaccordance with local and national laws. Generally
speaking, it may be any information that identifies living
individuals. Examples include lists of employees, andrecords that show their birth date, government-issued
identification number or other identifying information, or
medical information. In particular, personal informationthat requires careful handling must be handled strictly.
Eisai is committed to complying with data protection laws
in and around the world. Improper use of personal
information may cause irreparable damages to the rights
and interests of the individuals, and may also result in theimposition of penalties on the company. In addition, thetrust of others toward the company may be damaged.
We are responsible for properly acquiring, using,managing and storing data.

Proper use and management of information

Part 5

Keep the following in mind
when handling personal information• At the time of acquisition, specify the purpose of use
and obtain the consent of the person for that use if
required.
• Do not use the information for any other purposes
other than consented ones.
• Be aware of all local laws and regulations regarding
personal data protection when handling, storing,transferring, or receiving personal data across theborders of countries and regions.
• When we identify the loss or leak of personal
information, or become aware of the possibility, wemust contact the superiors or the departments incharge of protection of personal information.

5.3.2

Confidential
information

Confidential information is an important Eisai asset.
Confidential information includes anything from inventions,know-hows, and research results, financial data andcustomer lists etc. Confidential information is defined as“information used in the business of a company, such astechnically or commercially useful information owned by
the company, which is managed by the company asconfidential.”
Disclosing confidential information intentionally or
accidentally might undermine our business. Therefore, wemust make every effort seriously and diligently to protect
our confidential information.
Please note that if some information, despite being
confidential information, is not managed appropriately, we
may lose valuable legal protection that would otherwise
apply to it.
Confidential information received from other people orcompanies is their property. When we come acrossinformation from them in our work or everyday life, we
may be required to obtain the necessary permission fromthem to use it.

49

5.3.3

Information andtechnology security

Eisai takes Information and Technology (“IT”) security
seriously and has policies, procedures, and systems inplace to help prevent unauthorized access, leakage, anddisruption of information held in its IT systems.
On the other hand, the risk of cyber attacks such as
targeted attack emails are increasing.
If a company device, laptop or computer is infectedwith a virus by a targeted attack email, the network
system may go down, hinder Eisai’s business, or occur
leakage of confidential or personal information, so wemust use IT systems properly in accordance with Eisai
policies and procedures.

50

We should• get the approval of the superiors and the manager responsible
for Information Security in advance if we need to shareconfidential information with a third party; and• when sending emails, facsimiles, social media, and othermessages, ensure they are sent only to the proper recipients.

We should not• discuss confidential information in elevators, hallways,
restaurants, airplanes, trains, or any other public places where
unspecified people come and go;• bring in confidential information that belongs to anothercompany that a new colleague may have previously worked for;• take confidential information when leaving Eisai or provide Eisai’s
confidential information to any third party without prior andproper authorization; or• open attachments on emails that may contain computer viruses,
or access URLs that may be infected with computer viruses.

Proper use and management of information

5.4
Use of social
mediaPart 5

We must understand the characteristics of social media,
be aware of our responsibility as members of Eisai, anduse social media with good sense even when using social
media in private. In addition, it is necessary to recognizethat it can impact the impression of Eisai depending on
the content itself and how it is perceived by third parties.
The following are the principals for using social media
in private. If such guidances of using social media aredefined in each countries or regions, it is required to act inaccordance with relevant guidelines.

1. Do not publish, post, or release any information owned by Eisai that is consideredinternal or confidential information.
2. Do not publish, post, or release any information or commentary that may be viewed
or regarded as Eisai’s official view or opinion in any personal social media account.
3. Do not, under any circumstances, engage in any discussion or any activity that may
reasonably be interpreted by others as acting on behalf of Eisai. Examples of suchactivity include, but are not limited to, establishing or operating accounts that
include an Eisai name or the names of Eisai-related products and services or using
words that imply an association with Eisai; promoting or providing information on
Eisai-related products or services; posting content that include copyrighted
materials and intellectual property owned by Eisai, e.g., logos, logos in the
background of photos, trademarks, advertisements, etc.
4. Do not post or publish any advertisements, or any material that may be construed
as advertising or promotion of Eisai’s products.
5. Be respectful of others and remember that posting any information or material thatis another person’s personal information could result in libel, defamation, or
discrimination or other claims, which could potentially result in civil or criminal
liability for you.
6. Remember that posting any information or material that is considered illegal,
inappropriate, or harmful to Eisai, Eisai’s employees, clients, business partners or
any third party individual or business, could result in claims, which could result incivil or criminal liability against you.
7. Do not post information or material that is, or may be, information or material
relating to a competitor’s products or services; and8. Respect intellectual property laws, such as trademark, copyrights, publicity rights,
etc., and do not infringe upon the rights of third parties in any photograph, motion
picture, video, music, image, painting, text, etc. (“Copyrighted Material”), bydownloading, copying, or posting on social media such Copyrighted Material
without getting appropriate permission from the owner of such Copyrighted
Material.

51

5.5
Insider
information andtrading

Insider trading is the buying and selling of securities orother investment products with the knowledge ofimportant facts before announcement, and is prohibitedby laws.
The use of important facts for making personal
decisions relating to the buying and selling of securities orother investments is illegal. Important facts must be kept
strictly confidential and we should not give trading
recommendations to those without the information.
Important facts are information that could substantially
impact an investor’s decision to buy or sell securities (e.g.,financial results and forecasts; mergers, acquisitions or
joint ventures; and significant strategic and corporate
developments, such as clinical trial results or major
litigation cases).

We should not• share Eisai’s important facts with families, friends, or any third
parties; or• make investment decisions that involve Eisai or other listedcompany shares for ourselves or anyone else based in any way
on important facts.

Scenario & Advice
A relative asked me if she should sell Eisai
shares, when I knew there would be anannouncement soon that would likely havean effect on the share price. Can I tell her what I
think she should do?

52

No. You need to tell herthat you can’t advise her
and that you are not able
to share company information.

Code of Conduct

Part

6

Relationshipwith society

6.1 Human rights
6.2 Environmental protection
6.3 Tax payments and financial
statements
6.4 Donations
6.5 Organized crime53Eisai has expressed its support for the United Nations
Global Compact, a global effort to achieve sustainablegrowth in the international community. Eisai is committed
to upholding internationally recognized human rights
wherever our operations are located, and is opposed tomodern slavery such as child labor, forced labor, humantrafficking, or any other behavior that does not maintainhuman dignity and respect. This idea is also required ofbusiness partners, including suppliers. We need to
identify any negative impact on human rights related toour business activities. We should take appropriate action
to prevent or mitigate the violation of human rights or to
engage in human rights due diligence.

6.1
Human rights

We should• respect the rights of all people in the way we conduct ourbusiness.

Scenario & Advice
I have become awarethat one of our
suppliers might beusing child labor in theirfactory. What should I do?

54

You should inform your superiors, Legal
Department, and/or Compliance so that we
can investigate, remind them of their
obligations under the Eisai Global Code of Conduct
for Business Partners and their contracts, and if
necessary, terminate the relationship or put additional
controls in place.

Relationship with society

6.2
Environmental
Protection

Part 6

Eisai considers global environmental protection an
important component of business operations and strives
to preserve and maintain the environment in compliancewith written standards, Eisai’s policies and procedures.
Climate change not only threatens human life andlivelihoods, but can also hinder the stable supply ofpharmaceutical products, which is Eisai’s mission, by
causing extreme weather events and shutting down
factories.
To achieve a sustainable society, Eisai aims to mitigate
climate change by reducing greenhouse gas emissions,promote resource recycling through effective use ofresources, including water and proper disposal of waste,and conserve biodiversity. We strive to develop businessactivities that take into consideration the fair use of
biological resources.

55

6.3
Tax payments
and financial
statements

Eisai must make the correct payments to governments as
required by applicable tax laws. For proper tax payments,
it is important to maintain sufficient documents to proveand support the accuracy of our records and to establish
proper criteria for our decisions. Eisai prohibits false
information and forged expense claims in reimbursement
and account settlements, as well as misrepresentation orconcealment of relevant facts in a tax investigation, all ofwhich hinder proper tax payments.
Because we are a publicly traded company, we are
required to establish, develop, and implement internal
controls and accurately disclose information about certain
types of corporate activity in our annual reports.
Accordingly, we must make sure that all our stakeholders
receive correct and complete information in a timely
manner.

56

We should• properly document decisions to support information we disclose
to tax authorities;• prepare expense claims promptly and accurately, attaching all
relevant documents (i.e., invoices, expense claims), and clarifying
the amount and business purpose of the expense; and• keep proper documentation of approved company spending,and provide complete and accurate documentation uponrequest by Eisai, its auditors, or the government.

We should not• falsify any company records or take any step to impair theaccuracy of Eisai’s reports of its business or financial
performance.

Relationship with society

6.4
Donations

Part 6

Eisai may make donations that contribute to society.
Donations range from medical associations and academic
societies involving medical personnel, patient groups,
community groups, and non-profit organizations. Suchdonations must be reviewed and approved in accordancewith local regulations and internal procedures.
To ensure transparent decision-making andaccountability for all donations, we establish donation
rules.

57

6.5
Organized crime

58

Eisai does not enter into relationships with organizedcrime groups, and in the event that we identify such, we
sever the relationship.
If it is found that individuals or third parties we workwith are involved in, or are suspected of being involved inorganized crime, we promptly report our concerns toCompliance.

Compliance test
We all aim to realize our hhc mission. Before you take any action
or make any business decision, please ask yourself the following
questions to make sure you are in line with our compliancestandards. If you are in any doubt, you are encouraged to consult
with your superiors. If, for some reason, you cannot consult withyour superiors, please contact Compliance.

1. Could you openly tell your family what you havedone?
2. Do you think it’s acceptable to be non-compliant
as long as you are not found out?
3. How would it feel to read a report of your activities
in the news or on social media?

59

60

Compliance Handbook for
Eisai Network Companies
American English Version
Published by:
Corporate Compliance & Risk Management Department,
Eisai Co., Ltd.

The first edition: April 1st, 2000
The second edition: July 1st, 2001
The third edition: January 1st, 2003
The fourth edition: July 1st, 2005
The fifth edition: October 1st, 2007
The sixth edition: March 31st, 2013
The seventh edition: January 31st, 2017
The eighth edition: March 31st, 2021
© 2021 Eisai Co., Ltd.

Compliance Handbook for
Eisai Network Companies

GlobalComplianceHandbook