The Meiji Group complies with the laws, regulations and social rules of each country in order to ensure all transactions are proper and to promote fair, transparent, and free competition. To increase awareness and strengthen compliance further, we established internal regulations based on our Corporate Behavior Charter and Meiji Group Behavior Charter and work to improve internal training. We conduct business holding ourselves to high ethical standards and shall continue to develop to be a company trusted by society.

The Meiji Group has Compliance Regulations as well as related rules and committees in place, and implements/introduces a whistleblowing system.

At Meiji Co., Ltd., our approach is based on the idea that risk management and compliance are closely related to one another, and we have set up a Compliance & Risk Management Committee to promote a variety of activities and programs. We promote activities to nurture and foster compliance awareness to ensure that compliance is the cornerstone of our operations and that those operations are conducted fairly and faithfully.

Meiji Seika Pharma Co., Ltd. has established the Compliance Program Guidelines and the Meiji Seika Pharma Code of Practice. As professionals who work in a business and with products that concern the health and lives of people, we require all executives and employees to act in accordance with high ethical standards.

KM Biologics Co., Ltd. has established a Risk Compliance Committee chaired by the president to promote compliance and manage risks. The "Compliance Program Guidelines" stipulate that as a person engaged in a life-related company that handles products related to people's health, we should act with a high degree of ethics, including bioethics, as well as legal compliance. Also, KM Biologics Co., Ltd. is accelerating the project to win back trust in order to raise compliance awareness among workers on site. We implemented a structural reform in order to strengthen the auditing function, ensure independent auditing, clarify responsibilities and authority by introducing Meiji-style plant management systems and clarify the reporting and communication routes. These reforms will help the organization identify and address issues early on. As a member of the Meiji Group, we will establish compliance system with higher standards.

The Meiji Group formulated Meiji Group Anti-Corruption Policy in March 2019 in order to remain a transparent and sound corporate group that is trusted by society. In May 2019, we became a signatory to the UN Global Compact and we comply with Principle 10: Business should work against corruption in all its forms, including extortion and bribery. We translated this policy into English, Chinese, Spanish, Thai, Indonesian and Hindi to raise employee awareness, not only in Japan but overseas as well. We will continue internal training and other efforts to improve employee understanding. In FYE March 2023, we conducted employee training for all Group employees in Japan, focusing on the topics of "Definition of Corruption and Meiji Group Anti-Corruption Policy" and "Causes and Effects of Bribery and Preventive Measures."

Meiji Group Anti-Corruption Policy (PDF: 14KB)

For overseas Group companies generally thought to have higher risks than in Japan, in addition to conventional operations audits, we also have established a structure for conducting audits specifically designed to reduce fraud and other management risks (referred to as "governance audits"). Governance audits are used to confirm frameworks and management related to fraud prevention, including promotion of Meiji Group Policy awareness, anti-corruption, separation of duties, whistleblowing systems, and risk management systems. The use of external experts ensures audit efficiency and efficacy. Audit results are reported to audited companies and also shared with the Group CEO and other relevant officers, corporate auditors, and each operating company. Through these initiatives, we are working to strengthen our internal systems, and fraud checks and prevention.

Governance Audits of Overseas Group Companies

The Meiji Group has established measures to promote the prevention and early discovery of any violations of legal code, the Meiji Group Code of Conduct, and the Meiji Corporate Behavior Charter. We maintain an internal whistleblowing system for employees that includes an internal hotline as well as an external consultation desk staffed by an attorney or other qualified professional to ensure independence from Company management.

The Meiji Group explicitly prohibits the unjust treatment of whistleblowers in Company rules and regulations concerning internal reporting. We also protect whistleblowers by enabling anonymous reporting. Reported information is handled strictly as confidential information and is shared with relevant committees at each company. These committees then examine reported information and respond accordingly. Once an internal whistleblowing system reveals a breach of compliance, we will promptly take corrective measures and take appropriate disciplinary action (disciplinary dismissal, demotion, suspension from work, pay reduction, etc.) against those involved in such breaches.

The Board of Directors of Meiji Holdings regularly receives reports on the operating status of the whistleblowing structure to ensure appropriate management.
The Meiji Group provides employees with cards containing whistleblowing hotline information. This information is also posted to our intra site to promote awareness of the whistleblowing system among employees.

Number of reported cases or consultations through the Compliance Counseling Desk（FYE March 2023）

Breakdown	Number of Cases
Harassment	65
Personnel and Labor	91
Quality and Safety	11
Information Management and Accounting	5
Others	39
Total	211

Employees carry our Compliance Card, which includes the Corporate Behavior Charter and the contact details for our compliance counseling desk. The Meiji Group ensures strict adherence to the Corporate Behavior Charter. At the same time, the Group cultivates and entrenches compliance awareness by enhancing in-house education and training and disseminating information through our intranet.

Responsible promotion of ethical pharmaceuticals

The Meiji Group Pharmaceutical business embraces the mission of contributing to improving the health and welfare people around the world by developing innovative, highly effective, and safer pharmaceuticals. Critical to achieving this mission is maintaining strong ethical practices and transparency throughout our business activities. Furthermore, we must ensure appropriate interactions with researchers, medical professionals, and patient organizations, and engage in responsible promotional activities.

To ensure appropriate promotional activities, we maintain compliance with the Pharmaceutical and Medical Device Act and other relevant Japanese laws, and follow the laws, regulations, and guidelines of each country in which we engage in promotional activities for ethical pharmaceuticals.

In Japan, we used the Japan Pharmaceutical Manufacturers Association (JPMA) Code of Practice as the framework for creating our own Code of Practice. To supplement this Code, we also have outlined a Promotion Code, which reflects the principles of the Fair Trade Competition Code created by the Fair Trade Council of the Ethical Pharmaceutical Drugs Marketing Industry. We also established our Ethical Pharmaceutical Marketing Activity Regulations, which we based on the Ethical Pharmaceutical Marketing Activity Guidelines drafted by the Ministry of Health, Labour, and Welfare.

In our Promotion Code, we explicitly outline management duties and matters of compliance concerning promotional activities. Our Marketing Code for Ethical Pharmaceuticals outlines the organizational structure and role of the Marketing Supervisory Division, an entity that is independent of the Sales Division. This Code also outlines promotional procedures. When evaluating promotional materials, the Marketing Supervisory Division invites independent external experts from outside the Group to participate in their evaluation process.

Overseas, we conduct sales activities in compliance with promotion codes outlined by the respective industrial organizations of Indonesia, Thailand, and Spain where we have sales offices.

Employee education and internal audit concerning the promotion of ethical pharmaceuticals

To ensure the Group promotes are conducted in accordance with the Promotion Code and the Marketing Code for Ethical Pharmaceuticals, we regularly conduct training for all pharmaceutical sales division employees to ensure awareness.

To confirm compliance with the Promotion Code and the Marketing Code for Ethical Pharmaceuticals, an internal audit division conducts regular audits to confirm the adequacy of our compliance structure and activity processes, including promotional activities.
The Market Supervisory Division confirms the appropriateness of marketing representative (MR) activities by monitoring their activities, including accompanying MRs on sales visits to evaluate MR activities. The Market Supervisory Division also implements responses to MR activities as necessary.

Participation in industry initiative related to safe and responsible pharmaceuticals

To ensure the Group maintains membership in the following industry organizations as part of our efforts to ensure the safety of our pharmaceuticals. We partner with other companies towards establishing and promoting industry rules on matters such as the appropriate use of pharmaceuticals.

• The Federation of Pharmaceutical Manufacturers' Associations of Japan
• Japan Pharmaceutical Manufacturers Association
• Pharmaceutical Manufacturers' Association of Tokyo
• The Fair Trade Council of the Ethical Pharmaceutical Drugs Marketing Industry
• Council for the Proper Use of Medicine
• Japan Association of Vaccine Industries
• Japan Society of Quality Assurance
• Japan Blood Products Association

Transparency in corporate activities and relationships with medical institutions and patient organizations

Regarding interactions with researchers, medical professionals, patient groups, etc., each company has established its own Code of Practice for all directors and employees to ensure a high level of morality. The Pharmaceutical segment has also established Guidelines on Transparency of Relationships between Corporate Activities and Medical Institutions. Based on these guidelines, we disclose details of the academic research grants it provides.disclose details of the academic research grants it provides. These disclosures help illustrate the ways in which we contribute to progress in the life sciences, while adhering to the highest ethical standards.