Anti-Bribery and Corruption Global Policy

PurposeThe purpose of this Policy shall be to comply with laws and regulations and the maintenance of fairrelations with society as set forth in the ONO Group Code of Conduct in the context of anti-bribery andcorruption.

Definition of Terms
Terms used in this Policy are defined as follows:(1) Laws and regulations mean the law, government ordinances, ministerial ordinances,codes, directives, guidelines, and treaties of each country or region.
(2) ONO Group mean Ono Pharmaceutical Co., Ltd. and its consolidated subsidiaries.
(3) Employees, etc. mean officers and employees of each company and other persons who areunder the control and direction of each company.
(4) Public Official means a person engaged in the public service of a government or local
government, dedicated employee of a government-related organization, a person engaged
in the affairs of a public corporation, or to whom authority has been delegated by thegovernment or other related entities.
(5) Money and other benefits mean not only property benefits but also anything sufficient tosatisfy the demands and desires of a person. Therefore, all tangible and intangible
benefits fall under this category, including not only money and properties, but alsofinancial benefits, lending of houses and buildings without consideration, entertainmentand hospitality, and the provision of collateral and other property benefits, as well as nonproperty benefits such as job positions.
(6) Facilitation Payment means a payment to avoid unreasonable and discriminatory
disadvantageous treatment, for example, a small payment to a low-ranking public official
to facilitate administrative procedures related to licensing or customs clearance.
(7) Third parties mean all those that enter into contracts with ONO Group companies.

Scope
This Policy shall apply to all Employees, etc. of the ONO Group (except for TOYO Pharmaceutical Co.,
Ltd. and BEE BRAND MEDICO DENTAL.CO.,LTD.)

Anti-Bribery and Corruption Practices
ONO Group Employees, etc. shall practice anti-bribery and conduct their corporate activities inaccordance with this Policy and the anti-bribery policies established by each corporation.

Anti-Bribery and Corruption Promotion Framework
In order to promote the prevention of bribery, each ONO Group company shall appoint a responsible
person to carry out the duties assigned.

Prohibition of Bribery and Corruption(1) No ONO Group Employees, etc. shall directly or indirectly provide, or offer or promise toprovide, any money or other benefits to a counterparty, including Public Officials, whether
within or outside Japan, as consideration for any fraudulent acts by the other party, inorder to illegally obtain business interests, or to acquire or facilitate business for thecompany, with the intent to induce the counterparty to perform a fraudulent act, whileknowing that the receipt of money, etc. by the counterparty constitutes a professional
misconduct on the part of the counterparty.
(2) No ONO Group Employees, etc. shall directly or indirectly demand, promise to receive, oraccept any money or other benefits as consideration for any fraudulent acts by ONO
Group Employees, etc., within or outside Japan, in order for the counterparty to illegallyobtain business interests, or to acquire or facilitate business, with the intent to induce
ONO Group Employees, etc. to act fraudulently in the performance of their duties, whileknowing that the receipt of money, etc. by ONO Group Employees, etc. constitutes a
professional misconduct on the part of the ONO Group's Employees, etc.

Business Entertainment and Gifts(1) ONO Group Employees, etc. shall, when offering or receiving entertainment or gifts to orfrom a business partner, comply with laws and regulations and internal policies, if any,and shall do so in a manner that is not ostentatious or excessive in light of sociallyaccepted norms.
(2) ONO Group Employees, etc. shall, when offering or receiving entertainment or gifts to orfrom a business partner, obtain approval from the manager of each organization.
(3) ONO Group Employees, etc. shall keep accurate records of payments related toentertainment and gifts.

Facilitation Payment

(1) ONO Group Employees, etc. shall deny any request for Facilitation Payments; provided,
however, that the minimum necessary payment that is unavoidable due to lack of otherrealistic means is permitted, to avoid a real and unreasonable harm to life, body, or
personal property, such as the case of assault if the facilitation payment is not made.
(2) ONO Group Employees, etc. shall report any requests for Facilitation Payments to theirsupervisors and to their respective corporate officers in charge of compliance if theyreceive such requests. For payments that fall under the minimum required under thepreceding paragraph, an after-the-fact report will suffice.

Contract Procedures(1) When appointing a third party, the contract shall include an anti-bribery clause to ensurethat third party does not engage in any act of bribery or corruption; provided, however,that the clause may be omitted with approval of the ONO Group's legal division. Inaddition, ONO Group Employees, etc. shall share ONO Group's anti-bribery standards
with the third parties and request them to comply with such standards.
(2) In appointing third parties, the head of each organization shall conduct anti-bribery due
diligence.

Prevention of Accounting Frauds(1) All transactions involving company property shall be journalized to the appropriate
accounts and shall be recorded and organized in an orderly and clear manner.
(2) ONO Group Employees, etc. shall establish appropriate internal controls within the ONOGroup to prevent and detect bribery.
(3) ONO Group Employees, etc. assigned to accounting duties in their respective
organizations and the ONO Group Finance & Accounting division shall take care not tooverlook signs of bribery when making monetary payments and recording transactions.

Awareness Raising and Education
Each ONO Group company shall be responsible for conducting anti-bribery enlightenment andeducation/training for its Employees, etc. This enlightenment and education/training shall be conducted inaccordance with the education/training plan established by each corporation.

Disciplinary Action
Disciplinary action against Employees, etc., in violation of this Policy, shall be in accordance with theRules of Employment or other regulations of each corporation.

Reporting(1) If ONO Group Employees, etc. discover any violation of this Policy, or suspect a violation,
they shall report to:[1] Supervisor;[2] Company executives; or[3] Compliance Hotline/Desk of each corporation(2) In bribery investigation based on a report from ONO Group Employees, etc., the ONOGroup shall not disclose the name of informant, the nature of consultation, or any otherprivacy related matters to anyone other than the necessary persons concerned.
(3) ONO Group Employees, etc., who have reported the matter with integrity as stipulated inParagraph (1) of this Article, shall not be treated disadvantageously.

Investigation of Bribery and Corruption
Officer in Charge of Compliance of Ono Pharmaceutical Co., Ltd. shall investigate the ONO Group's
anti-bribery practices on a regular basis or as needed. In addition, Officer in Charge of Compliance may
request an internal audit of the ONO Group to the Senior Director of Business Audit Department of Ono
Pharmaceutical Co., Ltd.

Supplementary Provisions(1) This Policy shall be established on April 1, 2017 and come into force on the same day.
(2) Revision and retirement of this Global Policy shall apply for the final decision after deliberation and approvalby the Board of Directors of Ono Pharmaceutical Co., Ltd.