Procurement Guidelines

Patients First

Sawai Pharmaceutical Co., Ltd.
August 2016

Procurement Guidelines
Basic Procurement Principles ······································································· 1
Basic Procurement Policies ········································································· 1
Guideline Texts ························································································ 1
1 Impartial and Fair Transactions ····························································· 1
1.1
1.2
1.3
1.4
1.5
1.6
1.7

Prohibition against Unfair Competitive Inhibition Acts, etc.
Prohibition against Abuse of Superior Bargaining Position
Prohibition against Corruption and Bribery
Prohibition against Giving or Receiving of Improper Advantage
Respect for Intellectual Property
Prevention and Early Detection of Improper Practices
Proper Management of Export Shipping

2 Human Rights and Labor ······································································ 3
2.1
2.2
2.3
2.4
2.5
2.6
2.7

Prohibition against Inhumane Treatment
Prohibition against Discrimination
Prohibition against Forced Labor
Prohibition against Child Labor
Respecting Employees’ Right to Organize
Working Hours
Appropriate Wages

3 Health and Safety ················································································· 6
3.1
3.2
3.3
3.4
3.5
3.6
3.7
3.8
3.9

Safety in the Workplace
Safety Measures for Machinery and Equipment
Hygiene in the Workplace
Occupational Accidents and Disease Resulting from Employment
Giving Due Consideration to Physically Demanding Work
Health and Safety in Facilities
Employee Health Management
Education and Training for Safety and Hygiene
Emergency Measures

4 Concern for the Environment ································································ 9
4.1
4.2
4.3
4.4
4.5
4.6

Report on Implementation and Outcomes of the Environmental Activities
Environmental/Government Permits
Control of Chemical Substances
Minimization of Impact on the Environment (Drainage, Emissions, Sludge, etc.)
Waste Reduction (3R’s)
Effective Utilization of Resources and Energy

5 Product Quality and Safety ··································································· 11
5.1
5.2
5.3
5.4

Securing Product Safety
Quality Management System
Control of Chemical Substances Contained in Products
Provision of Accurate Information on Products and Services

6 Information Security ············································································· 13
6.1
6.2
6.3

Protection from Threats to Computer Networks
Prevention of Leakage of Personal Information
Prevention of Leakage of Confidential Information about Clients and Third Parties

7 BCP (Business Continuity Plan) ····························································· 14
7.1

Disaster-Preparedness Measures

8 DISCLOSURE OF INFORMATION ··························································· 148.1Disclosure of Information to Stakeholders

9 SOCIAL CONTRIBUTION ······································································· 15
9.1

Contribution to the Community

These guidelines were prepared with reference to JEITA Supply Chain CSR Promotion Guidebook (2006)(JEITA: Japan Electronics and Information Technology Industries Association)

Basic Procurement Principles
In order to realize our corporate philosophy, “Patients First” we will carry out procurement
activities by fairly selecting suppliers, based on quality, stable supply and economic
rationality, whether in Japan or overseas.
In order to practice transactions evoking sympathetic responses from people, we will build
up our relationship of trust with suppliers and aim at continuing to grow together.

Basic Procurement Policies
1.

Transactions evoking sympathetic responses

2.

Strict information management

3.

Modest transaction relationships

Guideline Texts
1 Impartial and Fair Transactions
1.1 Prohibition against Unfair Competitive Inhibition Acts, etc.
Suppliers are requested to refrain from practices that restrict fair, transparent, andfree competition.

“Restrictive trade practices” refers to prior agreements with companies in the same
trade about the prices for products or services, quantities, sales areas, etc., (cartels). It
also refers to prior arrangements with other bidders about the winning bidder and thesuccessful tender price (collusive bidding).

1.2 Prohibition against Abuse of Superior Bargaining Position
Suppliers are requested to refrain from practices that create disadvantage for theirown suppliers (sub-suppliers, from Sawai's perspective) by abusing their superiorbargaining position.

“Abuse of a superior bargaining position” refers to such practices as taking advantage
of one’s superior position as a purchaser or consigner and unilaterally determining
trading conditions, altering them, or imposing unreasonable requests or obligations.
Suppliers are requested to refrain from abusing their superior bargaining position.
Suppliers should conduct procurement transactions that are honest, fair, and impartial,
and are based on formal agreements with their suppliers (sub-suppliers, from Sawai's
perspective). When conducting business in countries that have legislation regarding
abuse of superior bargaining position, suppliers are requested to comply with all suchlaws (for example, Japan’s Act Against Delay in Payment of Subcontract Proceeds, etc.,1

to Subcontractors).

1.3 Prohibition against Corruption and Bribery
Suppliers are requested to maintain healthy and normative relationships withgovernmental and administrative bodies and to refrain from bribery or illegal political
donations.

“Bribery” refers to the act of offering benefits to public officials or equivalent persons(hereafter referred to as “public officials”) in order to gain a business advantage.
Examples of such benefits include money, hospitality, gifts. Examples of businessadvantages expected in return include a business license, an acquisition orcontinuation of trading, or access to non-disclosure information. Hospitality or gift-giving
to public officials can constitute bribery even if no business advantage is sought inreturn.

1.4 Prohibition against Giving or Receiving of Improper Advantage
Suppliers are requested to refrain from giving to or receiving from their stakeholders
any improper advantage.

“Stakeholders” are defined as parties that can be affected directly or indirectly by thecommercial activities of a business. “Giving or receiving of improper advantage” refers
to the following types of practices:-

Giving to or receiving from clients benefits that could be construed as bribes. For
example, a gift, award, or prize money, etc., that exceeds the bounds determined bylaw or fair competition rules; or money, goods, or hospitality that exceeds thebounds of social courtesy.

-

Giving improper advantage to an antisocial force that adversely affects public orderand healthy activities (examples of such include gangs, criminal syndicates, andterrorist organizations, etc.)-

Insider trading by which stock of a company is traded based on non-disclosure
information about the operations of a client, etc.

1.5 Respect for Intellectual Property
Suppliers are requested to refrain from infringing upon intellectual property rights.

“Intellectual property rights” (IPR) refers to patent rights, utility model rights, design
rights, trademark rights, copyrights. It also refers to rights that are stipulated by laws
and regulations on other intellectual property or rights related to trade secrets pertaining2

to interests that are protected by law. Before developing, producing, selling or providing
any product or service, suppliers are requested to fully investigate the intellectual
property of third parties concerned. Utilizing a third party’s intellectual property without
permission constitutes an infringement of IPR, except in cases where there is ajustifiable reason. Illegally reproducing computer software or other copyrighted works
also constitutes an infringement of IPR.
Likewise, illegally obtaining and utilizing the trade secrets of a third party also
constitutes an infringement of IPR.

1.6 Prevention and Early Detection of Improper Practices
Suppliers are requested to conduct activities designed to prevent improper practices
and to establish an early detection system.

“Activities to prevent improper practices” refers to efforts to train and raise awarenessamong staff and create a healthy workplace climate. “An early detection system” refers
to a system of measures designed to detect and rectify improper practices at an earlystage. Examples of such measures include the following:– Establishing an in-house and external hotline for reporting improper practices so that
top management can be alerted at early stage.
– Safeguarding the anonymity of whistle-blowers and protecting them as necessary.
– Responding swiftly to improper practices, and appropriately conveying the outcomesto the whistle-blower.

1.7 Proper Management of Export Shipping
Suppliers are requested to establish clear controls on the shipment of goods andtechnologies regulated by laws.

“Goods and technologies regulated by laws” refers to parts, finished products,
technologies, facilities, and software etc., that are subject to export restrictions inaccordance with international agreements such as the Wassenaar Arrangement (The
Wassenaar Arrangement on Export Controls for Conventional Arms and Dual-Use
Goods and Technologies). In some cases, authorization from supervisory authorities isrequired as part of the export shipping process.

2 Human Rights and Labor
2.1 Prohibition against Inhumane Treatment
3Suppliers are requested to respect the human rights of employees and to prohibit
abuse, harassment, and any other cruel and inhumane treatment.

“Cruel and inhumane treatment” refers to abuse, physical punishment, sexual
harassment, and abuse of authority (for example, verbal abuse or high-handed
behavior, often referred to in Japan as “power harassment.”).

2.2 Prohibition against Discrimination
Suppliers are requested to eliminate discrimination in hiring and employment
practices of employees, and to strive for equal opportunity and fair treatment.

“Discrimination” refers to the practice of treating a person differently or not giving themthe same opportunity as others with respect to recruitment, promotion, rewards andparticipation in training based on factors other than their ability, suitability for the job,and performance, all of which would be considered “reasonable factors.” Discrimination
is based on “unreasonable factors” such as race, ethnicity, nationality, birthplace, color,age, gender, sexual orientation, disability, religion, political views, union membership,and marital status. If equality of opportunity or fair treatment are impaired by the resultof health examinations, etc., it can also be construed as discrimination.

2.3 Prohibition against Forced Labor
Suppliers are requested to employ all employees of their own free will with noemployee being subject to forced labor.

“Forced labor” refers to all types of employment performed not based on labor contracts
but on a non-voluntary basis.
Examples of forced labor include the following:– Forcing someone to work against their will.
– Bonded labor in which the person is restricted from leaving the employment becauseof a debt owed to the employer.
– Slave labor in which the person performing the work has been trafficked.
– Being restricted from leaving the employment.
– Imposing a duty on the employee to deposit their identification cards, passport, or
work permit.

2.4 Prohibition against Child Labor
Suppliers are requested to refrain from employing as employees children who areunder the minimum age of employment, and assigning any work that would impair achild’s development.
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“Child labor” generally refers to the employment of persons who are under the minimum
age of employment as specified by the International Labor Organization (ILO),
Conventions and Recommendations on Child Labor, or the failure to duly protect young
employees.
Examples of practices that run afoul of the prohibition against child labor in Japan
include the employment of persons who upon reaching the age of 15 years old have notpassed the first March 31 date, and violations of laws designed to protect young
employees. The law protects young employees from work that would pose a threat totheir health, safety, or moral integrity by, for example, setting restrictions on nighttime
work and dangerous work. Overseas business operations will be deemed to be using
child labor if they involve the employment of persons who are under the minimum ageof employment, or if they violate duty of protection as determined by local laws.
If the country concerned has no such law, then business operations in that country will
be deemed to be using child labor if they violate the ILO provision on the minimum ageof employment (15 years is the minimum age for child work: ILO ConventionNo.138.).

2.5 Respecting Employees’ Right to Organize
Suppliers are requested to respect employees’ right to organize in order to bringabout negotiations between labor and management over working conditions or wage
standards, etc., of employees.

“Respect employees’ right to organize” means honoring employees’ freedom toassociate, participate in a labor union in accordance with laws, stage protests, andparticipate in workers’ council, and to do these things without fear of retaliation,
intimidation, or harassment.

2.6 Working Hours
Suppliers are requested to appropriately manage employees’ working hours, days
off, and leave to ensure that employees’ working hours are within the bounds
stipulated by law.

“Appropriately manage employees’ working hours” refers to the following:– Ensuring that scheduled working days are within the bounds stipulated by law.
– Ensuring that working hours per week are within the bounds stipulated by law. This
also applies to overtime except in cases of emergency.
– Providing employees with days off and annual paid leave in accordance with work
rules and laws.
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2.7 Appropriate Wages
Suppliers are requested to pay employees no less than the legal minimum wages,
and to refrain from practicing improper wage reduction as a means of disciplinary
action.

“Minimum wages” refers to the minimum level of wages as determined by thewage-related laws of the country concerned. As used here, the term includes thepayment of other allowances, including overtime compensation and legal payments.
“Improper wage reduction” refers to wage reductions that violate labor-related laws, etc.

3 Health and Safety
3.1 Safety in the Workplace
Suppliers are requested to assess safety risks in the workplace and to use
appropriate designs, techniques, and control measures to secure safety.

“Safety risks in the workplace” refers to the potential risks of accidents or injuries tohealth occurring in the course of work. Examples of risks include electricity or othertypes of energy, flammable material, vehicles, slippery/easy-to-stumble floors, andfalling objects.
Examples of “appropriate designs, techniques, and control measures” include thefollowing:– Using sensors to monitor hazardous areas.
– Using the safety hasp to isolate hazardous machinery from power sources(lock-out).
– Affixing a tag to the locked machinery indicating that it should not be turned on(tag-out).
– Providing protective equipment such as glasses, hard hats, and gloves.

3.2 Safety Measures for Machinery and Equipment
Suppliers are requested to establish appropriate safety measures with respect tomachinery and equipment used by employees.

As used here, the phrase “appropriate safety measures” refers to the practice ofmanaging machinery and equipment so as to prevent accidents and health problems
occurring in the course of work. Examples of such include the following:– Adopting safety mechanisms such as fail-safe, foolproof, and inter-lock.
– Installing safety devices and protective barriers.
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– Carrying out periodic inspection and maintenance.

3.3 Hygiene in the Workplace
Suppliers are requested to identify situations in which employees are exposed toharmful organisms, substances, noises, or odors, and to establish appropriate
measures.

Examples of “harmful” substances include chemical substances such as smoke, vapor,
mist, dust, and substances that are toxic, radioactive, or cause chronic disease (suchas lead and asbestos). Noises and odors can also be construed as “harmful” if they areparticularly problematic.
Examples of “appropriate measures” include the following:– Identifying and assessing situations where employees are exposed to harmful
substances or conditions.
– Establishing and enforcing safety management criteria.
– Providing appropriate training.
– Providing protective devices.

3.4 Occupational Accidents and Disease Resulting from Employment
Suppliers are requested to understand the situation concerning occupational
accidents and disease resulting from employment, and to establish appropriate
measures.

Examples of “appropriate measures” include the following:– Encouraging employees to declare accidents and disease.
– Keeping records of accidents and diseases.
– Providing emergency measures as necessary.
– Conducting surveys on accidents and disease.
– Taking proactive steps to eliminate the causes of accidents and disease.
– Facilitating an injured employee’s rehabilitation and return to work.
– Subscribing to workers’ compensation insurance.
– Undertaking administrative procedures as stipulated by law.

3.5 Giving Due Consideration to Physically Demanding Work
Suppliers are requested to specify physically demanding work and to appropriately
manage workloads to prevent accidents or disease.

Examples of “physically demanding work” include the following:– Heavy labor such as lifting and carrying heavy objects.
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– Repetitive or lengthy operations such as product assembly or data entry.
“Appropriately manage” refers to such measures as allowing workers to take short
breaks, providing them with auxiliary tools, and ensuring that the workload is sharedappropriately.

3.6 Health and Safety in Facilities
Suppliers are requested to appropriately safeguard health and safety in facilities
provided to employees (company housing, cafeterias, and restrooms, etc.).

“Facilities provided to employees” refers to workplace facilities (including restrooms,
water coolers, locker rooms, and cafeterias) and facilities external to the workplace(such as company housing).
Health and safety in such facilities is safeguarded by, for example, ensuring that they
are clean and sanitary, and that they have safe drinking water, fire safety systems,
ventilation and temperature control, emergency exits, safe ways to store personal
belongings, and access to emergency medical treatment.

3.7 Employee Health Management
Suppliers are requested to carry out appropriate health management with respect toall employees.

“Appropriate health management” refers to efforts made to prevent or detect early on
diseases among employees by providing at the very least medical checkups as perstandards set by law. It is also necessary to prevent health problems associated withoverwork and give due consideration to mental health care.

3.8 Education and Training for Safety and Hygiene
Suppliers are requested to provide education and training in a language
understandable to employees concerning safety information of pharmaceuticals andtheir intermediary bodies and any other hazardous substance and occupationalsafety.

“Safety information” refers to SDS (Safety Data Sheet) or similar information and topreparing the environment in which employees can easily refer to such information.
Education and training should be provided thoroughly and continuously for appropriate
use and handling method, storage method and disposal method, etc., depending on thenature of each employee’s job (related laws, manufacturing equipment, handling
substances and employee composition, etc.).
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3.9 Emergency Measures
In order to protect the welfare of employees, suppliers are requested to prepare
emergency measures as a precaution against possible disasters or accidents, and toensure that they are fully understood throughout the workplace.

Examples of “emergency measures” include the following:– Issuing an alert when disaster strikes.
– An employee notification system.
– Clarification of evacuation procedure.
– Setting up of evacuation facilities.
– Storing emergency medical products.
– Installation of a fire alarm system and fire extinguishers.
– Securing an external communication method.
– A recovery plan.
Examples of ensuring that these measures are “fully understood throughout theworkplace” include the following activities:– Providing emergency training to employees (including evacuation drills).
– Displaying emergency response procedures in places where they can be easily
accessed by employees.

4 Concern for the Environment
4.1 Report on Implementation and Outcomes of Environmental Activities
Suppliers are requested to a disclose report on implementation and outcomes ofenvironmental activities as necessary.

As used here, the term “environmental activities” means developing an environmental
policy, implementing the necessary measures to realize such a policy, and maintaining
these measures, reviewing and revising them as necessary. In this way, environmental
activities should follow the PDCA cycle (Plan, Do, Check and Action) and becontinuously improved.
Examples of “outcomes of environmental activities” include the following:– Progress made toward environmental conservation.
– Emissions of air, water, and soil pollutants.
– Resource consumption volume.
– Volume of waste generated.
– Impact to environment from daily operations in factories and business sites.
Outcomes should be periodically assessed by establishing a system for facilitating
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environmental activities, appointing the appropriate personnel, and making continuousrecords. Such records should show outcomes according to environmental management
indicators, level of attainment, and other environmental indices. Outcomes should be
disclosed by releasing environmental reports, integrated reports, CSR reports, etc., tothe public, and reporting to stakeholders as necessary.

4.2 Environmental/Government Permits
Suppliers are requested to obtain permits from governmental bodies in cases where
they are required by local laws, and to submit the necessary reports to such bodies.

The following are examples of Japanese laws that require companies to appoint officers
with certain qualifications:– Waste Management and Public Cleansing Law: Specially Controlled Industrial
Waste Manager.
– Act on the Rational Use of Energy: Qualified Energy Manager (in factories that use acertain level of energy).
– Air Pollution Control Act: Pollution Prevention Manager (in factories that emit
chemical substances, dust, and exhaust fumes).
Companies in Japan are also obligated to appoint officers in charge of toxic/deleterious
substances, specified chemical substances, and hazardous materials.
Depending on the type of business and location, companies may be required toundergo an environmental impact assessment and obtain a permit for facilities handlinghazardous material.

4.3 Control of Chemical Substances
Suppliers are requested to control hazardous chemical substances that are used in
manufacturing processes and have been specified in laws and regulations of thecountry concerned.

“Control hazardous chemical substances that are used in manufacturing processes”
refers to the control of chemical substances used in products. It also means
ascertaining the volumes of chemical substances discharged to the environment,
reporting such data to governmental bodies, and making efforts to reduce them toacceptable levels.

4.4 Minimization of Impact on the Environment (drainage, emissions, sludge)
Suppliers are requested to comply with laws and regulations on drainage, emissions
and sludge in the country concerned, and to make further improvements to voluntarystandards as necessary.
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“Voluntary standards” refers to voluntarily-set goals to reduce impact on theenvironment at least to the levels stipulated by laws and regulations. While the basic
aim is to prevent environmental damage from occurring, there is always room for further
improving standards by, for example, improving the monitoring, control, and processingof drainage, emission, and sludge with a view to reducing the output of such.

4.5 Waste Reduction (3R’s)
Suppliers are requested to set voluntary targets for waste reduction and to pursue
continuous waste reduction.

“Waste” refers to materials that are no longer needed at the factory or business site,
and as such are discharged into the environment. Examples of “continuous waste
reduction” activities include formulating voluntary targets for reducing the volume ofwaste output, drawing up plans to achieve these targets, and vigorously executing suchplans. It is important to always be mindful of the “3 R’s” –Reduce (reducing thegeneration of waste), Reuse (reuse), and Recycle (recycling).

4.6 Effective Utilization of Resources and Energy
Suppliers are requested to set voluntary targets for resource-conservation andenergy-conservation, and to strive to effectively utilize resources and energy on an
ongoing basis.

“Resource-conservation” refers to steps taken toward the effective utilization of
resources. Examples of such steps include the following.
– Reducing the amount of materials used in the manufacture of products.
– Utilizing recycled resources.
“Energy-conservation” refers to steps taken toward the rational utilization of thermaland electrical energy. Cutting down on wasteful energy consumption will ensure theeffective utilization of fuel such as oil, natural gas, coal, and coke.

5 Product Quality and Safety
5.1 Securing Product Safety
For pharmaceuticals and raw materials and manufacturing devices thereof, etc.,
suppliers are requested to ensure that the products satisfy safety standards
established under laws and regulations in the countries concerned.

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When undertaking product design, suppliers are requested to ensure that the design issufficiently safe, and to conduct marketing with full awareness of their responsibility asa manufacturer. Suppliers should also comply with laws, standards, and norms
concerning product safety. As the laws concerning product safety, there are thePharmaceuticals and Medical Devices, etc., Act, GXP, FSSC 22000, REACH
Regulations, UL, Product Liability Act, Electrical Appliance and Material Safety Act,
Consumer Products Safety Act, Household Goods Quality Labeling Act, etc. The safety
standards are provided for in detailed regulations of the laws and JIS, etc. “Securing
product safety” refers to such practices as managing traceability (understanding the
raw materials and parts used to make the product, and the manufacturing processes
involved) and resolving product safety issues promptly.

5.2 Quality Management System
Suppliers are requested to establish and run a quality management system.

“Quality Management System”(QMS) refers to a comprehensive management systemfor promoting quality assurance activities, and it involves organizational structures,planning activities, division of responsibilities, practices, procedures, processes, andmanagerial resources.
The term “quality assurance activities” means developing a quality assurance policy,
implementing the necessary measures to realize such a policy, and maintaining thesemeasures, reviewing and revising them as necessary. In this way, quality assurance
activities should follow the PDCA cycle (Plan, Do, Check and Action) and becontinuously improved. Key examples of the certification of QMS include the ISO 9000
family, ISO 15378, ISO 22000, and ISO 13485.
The requirements for manufacture and sale of pharmaceuticals are to establish thepharmaceuticals product quality system, determine the basic policy for “quality” tooperate it effectively and to carry out continuous improvement of the quality and stablesupply of pharmaceuticals.

5.3 Control of Chemical Substances Contained in Products
With respect to all of their products, suppliers are requested to control chemical
substances specified in the laws of countries in which the products concerned are
manufactured, imported to, or used.

“Controlling chemical substances contained in products” involves confirming whether aproduct contains any chemical substances that are prohibited or controlled in local laws,
and in the case that it does, ascertaining the volume(s) of the substance(s) it contains.
It also involves complying with any obligations to report or display information about
12such substances, and applying for registration or submitting the product for testing if
necessary.

5.4 Provision of Accurate Information on Products and Services
Suppliers are requested to provide consumers and clients with accurate information
about their products and services.

Providing “accurate information” involves the following:– Ensuring the accuracy of information about products or services, including
specifications, quality, and handling.
– Ensuring the accuracy of information about substances contained within products
and their components.
– Ensuring that promotional material such as catalogs and advertisements do notcontain any phrases that are inaccurate or would cause misunderstanding among
consumers and clients, or any content that slanders or infringes the rights ofcompanies or individuals.

6 Information Security
6.1 Protection from Threats to Computer Networks
Suppliers are requested to establish protective measures against threats to computer
networks to prevent any harm arising in their company or other companies.

Examples of “threats to computer networks” include viruses, worms, and spyware.
If a computer connected to the Internet gets infected by a virus, etc., there is a risk thatclient information and other sensitive information stored on that computer will be leaked.
The infected computer may also attack another company’s computer system, which
would bring about serious damage such as an operational standstill and loss ofconfidence.

6.2 Prevention of Leakage of Personal Information
Suppliers are requested to appropriately manage and protect the personal
information of clients, third parties, and employees.

“Personal information” refers to information about a living individual that includes the
person’s name, date of birth, or any other detail by which the person can be identified(including such information that will allow easy reference to other information andthereby enable the identification of the specific individual.)“Appropriate management of personal information” refers to the establishment and13operation of a comprehensive framework for the management of personal information.
This includes the creation of regulations and guidelines to be observed by employees,
the drawing up of plans, the implementation of programs, internal audits, and reviews
based on such a framework.
“Appropriate protection” means ensuring that personal information is not improperly or
unjustly obtained, utilized, disclosed, or leaked.
6.3 Prevention of Leakage of Confidential Information about Clients and Third

Parties
Suppliers are requested to appropriately manage and protect confidential information
regarding clients and third parties.

“Confidential information” generally refers to information that is displayed in a written
document (including electromagnetic or optically recorded data) after it is agreed thatsuch information is confidential, or information that is disclosed orally after notice has
been made as to the confidential nature of such information.
“Appropriate management of confidential information” refers to the construction andoperation of a comprehensive framework for the management of confidential
information. This includes the creation of regulations and guidelines to be observed by
employees, the drawing up of plans, the implementation of programs, internal audits,and reviews based on such a framework.
“Appropriate protection” means ensuring that confidential information is not improperlyor unjustly obtained, utilized, disclosed, or leaked.

7 BCP (Business Continuity Plan)
7.1 Disaster-Preparedness Measures
Suppliers are requested to establish BCP (Business Continuity Plan).

A “BCP” (Business Continuity Plan) is a disaster-preparedness measure for ensuring
the continuation of important business in disaster situations. Examples of “disastersituations” include natural disasters such as major earthquakes and pandemics. Having
a BCP will enable smooth recovery from a disaster situation. Another advantage is that
preparing such a plan will prompt analysis of risks of business operations, which maylead to managerial improvements.

8 Disclosure of Information
148.1 Disclosure of Information to Stakeholders
Suppliers are requested to proactively disclose information to stakeholders
irrespective of whether or not such disclosure is mandated by law.

Examples of information that should be disclosed to stakeholders include the following:– Business activities.
– Financial information.
– Business performance.
– Risk information (such as information on damage from large-scale disaster,
occurrence of events that adversely impact the environment or society, and serious
infringements of laws or regulations.)
An example of proactive information provision is promptly disclosing information about
serious risks and providing such information to clients.

9 Social Contribution
9.1 Contribution to the Community
Suppliers are requested to voluntarily carry out activities designed to contribute to thedevelopment of the local and global community.

“Activities designed to contribute to the development of the local and global community”
refers to schemes that use corporate resources to support the community. The
following are typical examples of social contributions:– Social contributions made through applying the company’s original business modeland its technology.
– Non-monetary social contributions made through using the company’s facilities orhuman resources.
– Social contributions made through monetary donations.
Social contributions involve the following types of activities:– Cooperating with the local community in times of disaster.
– Voluntary activities performed by employees.
– Monetary or non-monetary contributions to NPO’s or NGO’s.
– Providing useful information.
Suppliers should determine the extent of the contributions they can make and thencarry them out proactively.

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