OUR
CODE

Daiichi Sankyo Group Employee Code of Conduct

I N N O V A T I O N . I N T E G R I T Y. A C C O U N T A B I L I T Y.

CEO MESSAGE
Daiichi Sankyo’s mission is to contribute to the enrichment of quality of lifearound the world through the creation of innovative pharmaceuticals andthrough the provision of pharmaceuticals addressing diverse medical needs.
The business environment facing the pharmaceutical industry continues to evolve around theworld. In the midst of these changing conditions, we are working to realize our 2025 vision of
being a Global Pharma Innovator with a competitive advantage in oncology, while recognizingthat we have multiple responsibilities to our many stakeholders, including patients, healthcare
professionals, business partners, shareholders, employees and society.
In order to realize our 2025 vision, we need to act in accordance with our Core Values ofInnovation, Integrity and Accountability, which are our common basic values and the criteria
by which we make decisions. The Daiichi Sankyo Group Employee Code of Conduct serves
as a guideline for “Integrity” and provides a foundation for our culture of ethics and compliance.
I expect our executives and employees to act in compliance with not only applicable laws,
regulations and industry codes, but also this Daiichi Sankyo Group Employee Code of Conductand our global, regional and local Company policies and procedures, which provide detailed
requirements based on this Code of Conduct.
Sunao Manabe
Representative Director, Executive Chairperson & CEO© 2020 | Daiichi Sankyo Group Employee Code of Conduct

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CONTENTS
Introduction ............................................................................................4
Patients ...................................................................................................5- Aspiring to Improve Patient Quality of Life...............................................6- Patient Safety & Adverse Event Reporting ..............................................6- Product Quality ......................................................................................6- Access to Healthcare .............................................................................6- Relationships with Patients & Patient Organizations................................7- Conduct of Clinical Trials/Studies............................................................7- Access to Clinical Trial/Study Information & Transparency.......................7
Society ....................................................................................................8- Sustainability ..........................................................................................9- Human Rights ........................................................................................9- Environmental Stewardship ....................................................................9- Animal Welfare .......................................................................................9- Ethical Engagement .............................................................................10- Involvement in Community & Social Contribution ..................................10- Stakeholder Relations & Social Media...................................................10

Healthcare Professionals and Business Partners...............................11- Appropriate Partners ............................................................................12- Interactions with Healthcare Professionals ............................................12- Promotion & Advertising .......................................................................12- Anti-Bribery & Anti-Corruption ..............................................................12
Stakeholder Reliability .........................................................................13- Accurate Books & Records ..................................................................14- Anti-Trust & Fair Competition................................................................14- Insider Trading......................................................................................14- Conﬂicts of Interest...............................................................................15- Information Security .............................................................................15- Business Intelligence ............................................................................15- Privacy .................................................................................................15- Safeguarding Corporate Assets............................................................15
Executives and Employees ..................................................................16- Conduct in the Workplace ....................................................................17- Discrimination & Harassment................................................................17- Workplace Safety .................................................................................17- Growth & Development ........................................................................17
Reporting of Violations of This Code...................................................18© 2020 | Daiichi Sankyo Group Employee Code of Conduct3

INTRODUCTION
The Daiichi Sankyo Group Employee Code of Conduct (the “Code”) isa global policy that speciﬁes the principles by which all Executives andEmployees are expected to conduct their work, and is aligned with theDaiichi Sankyo Group Corporate Conduct Charter.
The purpose of the Code is to establish uniform standards of fairness, ethics
and integrity, by which all Executives and Employees will operate. The Codeapplies to executives, directors, ofﬁcers, employees, temporary workers(whether full-time or part-time), and any individual hired or contracted by
Daiichi Sankyo Group companies (collectively, “Executives and Employees”
or “We”). In this Code, references to “Daiichi Sankyo” or the “Company” include
Daiichi Sankyo Company, Limited, and all its afﬁliates worldwide. In addition
to the principles contained in our Business Partner Code of Conduct, we
encourage our business partners to adhere to the principles outlined in this Code.
The Code further requires Executives and Employees to conduct our businessaccording to the framework established in this Code as well as our Core
Values of Innovation, Integrity and Accountability, while abiding by applicablelaws, regulations, industry codes, and our global, regional and local Company
policies and procedures. This requirement applies equally to our interactions
with stakeholders such as patients, healthcare professionals, business
partners, shareholders and society.

OuR CORE VALuES OF InnOVATIOn,
InTEGRITy AnD ACCOunTABILITy ARE THE
CRITERIA By WHICH WE MAkE DECISIOnS© 2020 | Daiichi Sankyo Group Employee Code of Conduct

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PATIENTS

5© 2020 | Daiichi Sankyo Group Employee Code of Conduct

PATIENTS

THE PuRPOSE OF THE CODE IS TO ESTABLISH unIFORM
STAnDARDS OF FAIRnESS, ETHICS AnD InTEGRITy

Aspiring to Improve Patient Quality of LifeWe research, develop, manufacture and provide products aimed to deliver value to ourpatients and improve their quality of life.
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Patient Safety & Adverse Event Reporting
We collect, review and evaluate safety information on our drug products in a timely
manner. We also report this information to regulatory authorities, as required, andpromote proper use of our drug products.
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Product Quality
In delivering value to patients, we research, develop, manufacture and provide productsthat meet strict quality and regulatory requirements.
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Access to Healthcare
Pharmaceutical products only have meaning if they are accessible to patients. We
continually evaluate our global programs to assist patients who face access barrierscaused by social factors such as public health and income inequality, geographic, andﬁnancial factors, when receiving or in need of treatment. We believe that improving
access to healthcare can help solve an important part of the global health crisis.

6© 2020 | Daiichi Sankyo Group Employee Code of Conduct

PATIENTS (continued)
THE DAIICHI SAnkyO GROuP EMPLOyEE CODE OF COnDuCT SERVESAS A GuIDELInE FOR “InTEGRITy” AnD PROVIDES A FOunDATIOn FOR
OuR CuLTuRE OF ETHICS AnD COMPLIAnCE

Relationships with Patients & Patient Organizations
We are committed to maintaining appropriate, transparent and fair relationships withpatients and patient organizations.
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Conduct of Clinical Trials/Studies
We conduct clinical trials/studies in an ethical and compliant manner in accordancewith international standards including the Declaration of Helsinki and the International
Council for Harmonisation of Technical Requirements for Pharmaceuticals for Humanuse (ICH) guidelines. We conduct clinical trials/studies in a manner that recognizes theimportance of safety and respects research participants, and we commit to maintaining
the conﬁdentiality of patient-identiﬁable data.
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Access to Clinical Trial/Study Information & Transparency
We recognize the public health beneﬁts that result from making appropriate clinical
trial/study information widely available to patients, healthcare professionals, researchers,
academicians and others, while maintaining patient privacy and conﬁdentiality. We
disclose our clinical trial/study information in an accurate, appropriate and timely manner.

7© 2020 | Daiichi Sankyo Group Employee Code of Conduct

SOCIETY

8© 2020 | Daiichi Sankyo Group Employee Code of Conduct

SOCIETY

Sustainability
We believe in creating and maximizing long-term economic, social and environmental
value. We do this in order to diligently address medical needs by delivering beneﬁcial,safe and reliable medicines and services, while responsibly minimizing the negativeenvironmental impact of our business operations.
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Human Rights
We are committed to respecting the human rights of all people and upholding highlabor standards.
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Environmental StewardshipWe believe environmental management is the fundamental measure of sustainability
and enhances our good corporate citizenship. We are committed to protecting ourenvironment.
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Animal Welfare
We minimize the use of animals for research by seeking alternatives wherever feasible.
When the use of animals for research is needed, we are committed to their humane
and respectful treatment.

9© 2020 | Daiichi Sankyo Group Employee Code of Conduct

SOCIETY (continued)

Ethical Engagements
We do not support or conduct business with antisocial forces, prohibited entities orgroups that may threaten the order or safety of society.
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Involvement in Community & Social Contribution
We actively engage in community activities and philanthropic programs focused onsocial causes.
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Stakeholder Relations & Social MediaWe actively, effectively and fairly disclose Company information to the public and engage
in an open and constructive dialogue with a wide range of stakeholders. We appropriately use social media to enhance our corporate value for the distribution of accurate
and truthful Company information.

OuR MISSIOn IS TO COnTRIBuTE TO THE EnRICHMEnT OF QuALITy
OF LIFE AROunD THE WORLD THROuGH THE CREATIOn OF InnOVATIVEPHARMACEuTICALS AnD THROuGH THE PROVISIOn OF PHARMACEuTICALSADDRESSInG DIVERSE MEDICAL nEEDS© 2020 | Daiichi Sankyo Group Employee Code of Conduct

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HEALTHCARE PROFESSIONALS& BUSINESS PARTNERS

11© 2020 | Daiichi Sankyo Group Employee Code of Conduct

HEALTHCARE PROFESSIONALS & BUSINESS PARTNERS

Appropriate Partners
We are committed to doing business with those healthcare professionals and business partners
who comply with applicable laws, regulations, industry codes and contractual terms, including
those related to human rights, workplace safety, the environment, child or forced labor, money
laundering and bribes. We do not employ, nor do business with, individuals, companies or otherentities who are debarred, excluded, or otherwise ruled ineligible by applicable laws and regulations.
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Interactions with Healthcare Professionals
In various ways, we interact with healthcare professionals; including when we exchange medical
information, conduct promotional activities, and engage in research and educational efforts. Whenengaging in such activities, we are committed to the highest standards of integrity.
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Promotion & Advertising
We are committed to providing truthful, accurate and fairly balanced promotional messages forour products and disease awareness information, regardless of the medium of delivery. We do
not permit or condone false or disparaging statements against our competitors or their products.
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Anti-Bribery & Anti-Corruption
We do not provide or accept any money, gifts or other beneﬁts, to or from any government ofﬁcial
or private party, for the purpose of securing an illicit or inappropriate business advantage.

12© 2020 | Daiichi Sankyo Group Employee Code of Conduct

STAKEHOLDERRELIABILITY

13© 2020 | Daiichi Sankyo Group Employee Code of Conduct

STAKEHOLDER RELIABILITY

Accurate Books & Records
We believe that the integrity of our Company information and data, such as accounting
records and our preclinical and clinical research data, is critical to maintaining credibility
with our patients, healthcare professionals, business partners, shareholders, andregulators. We are committed to accurately reporting all information, including ﬁnancial,clinical research, production and quality data and any other Company data that isreleased to the public, the government, shareholders, or any other entities.
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Anti-Trust & Fair Competition
Antitrust and competition laws promote fair competition and ensure our businesses
compete based on quality, price and service. We compete vigorously, independently,
and in compliance with the antitrust and competition laws of those countries in which
we do business.
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Insider Trading
We do not permit the use of material and non-public Company information, or that ofbusiness partners, as a basis for trading stock or securities in Daiichi Sankyo Company,
Limited, or the stock or securities of other companies. This includes a prohibition on
sharing material and non-public information with others (including family members,
friends, or signiﬁcant others).

THE CODE APPLIES TO ExECuTIVES, DIRECTORS, OFFICERS, EMPLOyEES,TEMPORARy WORkERS (WHETHER FuLL-TIME OR PART-TIME), AnD Any
InDIVIDuAL HIRED OR COnTRACTED By DAIICHI SAnkyO GROuP COMPAnIES
14© 2020 | Daiichi Sankyo Group Employee Code of Conduct

STAKEHOLDER RELIABILITY (continued)

Conﬂicts of Interest
We prioritize Company interests over our own business or ﬁnancial interests and avoid
situations in which our personal interests conﬂict with Company interests. If a potential conﬂict
of interest arises, we require it be reported according to Company policies and procedures. If
a potential conﬂict of interest exists, before acting, employees must seek direction on how toproceed in accordance with Company policies and procedures.
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Information Security
We maintain in conﬁdence all proprietary and conﬁdential information and trade secrets,
whether belonging to the Company or any third party with which we do business.
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Business Intelligence
We respect the conﬁdential and proprietary information of third parties. We do not accept orsolicit conﬁdential and/or proprietary information belonging to third parties without their consent.
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Privacy
We are committed to maintaining the conﬁdentiality of protected personal information ofpatients, clinical trial/study subjects, healthcare professionals, business partners, shareholders
and employees, and appropriately treat their personal information.
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Safeguarding Corporate Assets
We properly use and maintain Company assets and ensure that they are protected frommisuse, loss, theft and unnecessary waste. We appropriately maintain and protect Company
intellectual property.
© 2020 | Daiichi Sankyo Group Employee Code of Conduct

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EXECUTIVES& EMPLOYEES

16© 2020 | Daiichi Sankyo Group Employee Code of Conduct

EXECUTIVES & EMPLOYEES

Conduct in the Workplace
Our commitment is to support diversity in our workforce and in our leadership. We treat
Executives and Employees with respect, fairness and dignity. We respect and value our
Executives and Employees’ individual characteristics, perspectives, and their distinctive
backgrounds.
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Discrimination & Harassment
We are committed to maintaining a work environment free from intimidation, violenceor threats of violence. We do not tolerate discrimination or harassment against
Executives and Employees by other Executives and Employees, supervisors, managers,
business partners or healthcare professionals. We prohibit bullying including abusing
one’s position or role to harass another.
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Workplace Safety
We maintain a safe working environment that protects the health and welfare of our
Executives and Employees.
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Growth & Development
We provide equal employment and advancement opportunities for all Executives andEmployees according to each person’s qualiﬁcations. Our work environment allows
for the development of an individual’s skills and abilities, which enables the individual
Executive or Employee to grow within the Company.

17© 2020 | Daiichi Sankyo Group Employee Code of Conduct

REPORTING OF VIOLATIONS OF THIS CODE
If any Executive or Employee discovers any actual or potential violation of this Code, the person must
promptly report the matter to the responsible function(s) designated by each Company (such as
Compliance, Legal or Human Resources), or to the person’s manager, or via other mechanisms
established on a local/ regional level.
By reporting actual or potential problems, you are contributing to the Company’s ethical culture. There isno penalty for reporting in good faith something that turns out not to be a problem. Daiichi Sankyo Group
strictly prohibits retaliation against Executives or Employees who report actual or potential violation(s) of
this Code in good faith and/or Executives or Employees who assist in the investigation of
misconduct.

Revision Date : April 1st,2023
Responsible Department : Compliance & Risk Management Department, Daiichi Sankyo Co.,Ltd.

© 2020 | Daiichi Sankyo Group Employee Code of Conduct

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