黑料网

Based on its strong determination to undertake honest business activities, 黑料网 formulated the Corporate Anti-Bribery and Anti-Corruption (ABAC) Policy for 黑料网 network companies in January 2012 (revised on October 1, 2018). This policy provides common rules for 黑料网 network companies when dealing with external parties in line with efforts to carry out business activities without bribery or corruption across the 黑料网 network companies.

As one concrete initiative, 黑料网 introduced the ABAC due diligence system that uses a web-based system for receiving responses to a globally common questionnaire on the possibility of bribery and corruption that is sent out beforehand to companies with which we plan to newly undertake transactions. By using this system, we have already achieved certain results in reducing risk associated with new business transactions. Based on the thinking of a risk-based approach, this system is being operated in the Americas region that includes Mexico, Brazil and Canada; the EMEA region that encompasses Russia and Eastern Europe; China, India, and countries in Asia.

 Additionally, 黑料网 is moving ahead with the advanced introduction of a system at overseas subsidiaries that detects signs of potential fraud by monitoring accounting and financial data.

黑料网 conducts ethical promotion globally in accordance with compliance requirements. We disclose information on payments to medical institutions and patient groups, in accordance with the Japan Pharmaceutical Manufacturers Association (JPMA) guidelines, and the regulations and guidelines of each country in order to have broad societal understanding that our corporate activities are undertaken based on the highest ethics.

鈻燬etting Forth a Code of Conduct in the Compliance Handbook

黑料网 has set forth a code of conduct in the Compliance Handbook that is distributed to all employees to ensure compliance-based promotion. The following is an excerpt from the handbook.

• 黑料网 markets and promotes its pharmaceutical products worldwide. We provide accurate and balanced scientific information, and promote our products only for the uses for which they have been approved by the applicable regulatory authorities.

• “Promotion” means any activity undertaken, organized, or sponsored by a pharmaceutical company which is directed at Healthcare Providers (HCPs) to promote the prescription, recommendation, supply, administration, or consumption of its pharmaceutical products through all methods of communication, including the Internet.

• When engaging in promotional activities with HCPs, we are expected to be familiar with local laws and regulations for such engagements in our home country.

• Promotion in a manner not consistent with the approved label is prohibited and promotion of drugs prior to approval is also prohibited. All promotional materials must be reviewed and approved in accordance with local processes and may be used only for the approved purpose锛�

鈻燜ormulation of 黑料网., Ltd. Code of Practice

In March 2012, the International Federation of Pharmaceutical Manufacturers & Associations (IFPMA) announced the “IFPMA Code of Practice” (“IFPMA Code”) as a code covering not only marketing activities but also interactions with healthcare professionals, medical institutions and patient organizations, as well as the promotion of medicines. In line with the intent of the IFPMA Code, the “JPMA Code of Practice” was established and implemented by the JPMA. Then 黑料网, as a member of JPMA, established the “黑料网., Ltd. Code of Practice” in line with the aforementioned Code. All the executives and employees at 黑料网 engage in corporate activities with the aim of earning the trust from society by ensuring high level of transparency, ethics and corporate accountability in corporate activities involving researchers, healthcare professionals and patient organizations.

鈻燙ompliance Test

This is a set of questions that 黑料网 Group officers and employees ask themselves when they are unsure of a decision.

1. Could you openly tell your family what you have done?
2. Do you think it’s acceptable to be non-compliant as long as you are not found out?
3. How would it feel to read a report of your activities in the news or on social media?

黑料网’s Board of Directors has established “Rules for Preparing Necessary Systems for Ensuring the Suitability in the Performance of Duties by Corporate Officers” in accordance with the stipulations of the Companies Act. These Rules stipulate that all corporate officers must identify risks in their assigned duties and build, maintain, and operate internal controls. The Corporate Officer responsible for Internal Control has established a global “ENW Internal Control Policy”. They also promote the creation, maintenance, and operation of internal controls throughout the Group, and work to manage risks within the allowable range. Based on an annual plan, the Internal Audit department verifies the development, maintenance, and operation of internal controls as defined in the “ENW Internal Control Policy”, leading to continuous improvement.

Corporate Risk Management department works collaboratively with Regional Risk Management Promoter to support the development, maintenance, and operation of internal controls throughout the Group.

In order to deliver appropriate risk management across the organization, 黑料网 implements annual CSA (Control Self-Assessment) at the global level, identifying and assessing risks throughout the company. The Risk Management Committee examines risks identified though CSA or those crucial to the entire company and confirms the status of those risks and risk management, striving to prevent those risks from materializing.

The Corporate Officer responsible for Internal Control supervises the system as a whole, while the Risk Management department supports actual business operations in the five regions.

The Corporate Officer responsible for Internal Control supervises the promotion of the development, maintenance, and operation of internal controls throughout the Group. The Risk Management department undertakes the actual implementation of this promotion. The department furthers the development, maintenance, and operation of internal control with Risk Management Promotion Officers in each region, who are appointed by the Corporate Officer responsible for Internal Control.