Sawai Pharmaceutical Anti Bribery and Corruption Policy
Aiming to realize sustainable development of healthy society and economy, regulations are being tightenedin countries all over the world on bribery, corruption or other forms of misconduct that could impede faircompetition. As Sawai Pharmaceutical is engaged in pharmaceutical company with a deep relationship topeople's lives, we believe that “a healthy society and its sustainable development” are the foundation of why
we exist, and that we can achieve our sustainability only if we can maintain a solid relationship of trust withall stakeholders. To this end, we have established the Anti Bribery and Corruption Policy (hereinafterreferred to as this "Policy").
1．

Prohibition of bribery to Government Officials

No board members, corporate officers and employees of Sawai Pharmaceutical Co., Ltd. (hereinafterreferred to as "Officers and Employees") shall provide, offer, or promise to provide any illicit money, bribes,entertainment, gifts, benefits, or other favors※Note 1 (hereinafter collectively referred to as "Improper
Benefits") to public officers, public employees or persons in a position similar thereto, regardless of whether
they are domestic or of foreign governments (hereinafter referred to as " Government Officials").
2．

Prohibition of facilitation payment※Note 2

Officers and Employees shall not pay facilitation payments in Japan or any other countries.
3．

Business Partner※Note 3

Officers and Employees shall not instruct, abet, or assist Business Partners to provide Improper Benefits(including facilitation payments, the same shall apply hereinafter) to Government Officials. We shall neveroverlook such behavior and shall refuse to pay any commissions or compensation to our Business Partners
on such behaviors. In addition, before retaining a Business Partner, we shall make background check of thenominee to the extent practically possible, and request them to submit us a written pledge stipulating anti
bribery and corruption provisions, or conclude a contract including such effect.
4．

Request for bribery by Government Officials

Officers and Employees shall firmly refuse any request for Improper Benefits from any Government
Officials, whether in Japan or any other countries, and shall notify such request to the our company’s
compliance officer, who shall notify appropriate authorities, if they deem it necessary.
5．

Entertainment or gifts to other than Government Officials

Any entertainment, gifts, benefits, or other favors given to other than Government Officials in Japan or any
other countries must be complied with the laws and in compliance with the socially accepted standards ofeach country.

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6．

Receiving Entertainment or gifts

Officers and Employees, whether in Japan or any other countries, shall never receive excessive
entertainment or gifts along with their business beyond the ranges of social courtesy.
7．

Prohibition of improper accounting

Officers and Employees shall not engage in off-balance-sheet transactions, fictitious transactions, otherfalse transactions, or any transaction that may cause misunderstanding. In addition, for all transactions orprocessing of assets, we shall prepare and maintain accurate and fair accounting records such as books,
records and account bills in a timely manner.
8．

Education

Sawai Pharmaceutical shall implement education and training for Officers and Employees on anti briberyand corruption. The education and training shall be conducted according to the education and training
plans to be established each fiscal year.
9．

Periodic audits and reviews

Through periodic audits, Sawai Pharmaceutical shall examine compliance with this Policy and the internal
regulations in terms of the prevention of bribery and corruption, and shall confirm whether the internal
system for the prevention of bribery and corruption works effectively. Based on the results of the audits,
Sawai Pharmaceutical shall continuously review the effectiveness of such anti bribery and corruption system,
including this Policy, and shall make improvements as necessary.
10．

Disciplinary Action

Sawai Pharmaceutical shall take strict disciplinary action against Officers and Employees who violate thisPolicy and the internal rules in terms of the prevention of bribery and corruption.
――――――――――――――――――――――――――――――――――――――――――――――※Note 1: Examples of improper benefits or other favors
Cash vouchers, gift cards, invitations (professional sporting events, theatrical performances,travel, etc.), donation and employment opportunities (including those for relatives)※Note 2: Facility payments refer to small payments made to low-ranking Government Officials withoutdiscretionary authority in order to facilitate and expedite routine administrative procedures.
Facility payments are prohibited in many countries as bribery because they may interfere withthe efficient operation of government agencies, thereby undermining economic development
and the rule of law.
※Note 3: “Business Partner(s)” means all third parties, regardless of their names, including delegates,advisors, consultants, brokers, agents, collaborators, and joint ventures (JVs), which we may use
2for the purpose of facilitating transactions and operations and which are reasonably likely tocome into contact with Government Officials. Contracts with Business Partners must containprovisions prohibiting them from providing Improper Benefits to Government Officials andconditions under which the Contracts may be terminated in the event of violation of suchprovisions, in order to prevent bribery through Business Partners.
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Supplementary Provisions
This Policy shall be under the jurisdiction of Vice President of Corporate Administration Division ofSawai Pharmaceutical.
The amendment and repeal of this Policy shall require the resolution of the Sawai Pharmaceutical Boardof Directors.
Enacted on June 18, 2018
Amended on February 27, 2023 and enforced on April 1, 2023

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