Astellas takes a strong stance against corruption. Astellas strictly prohibits bribery and corruption in any aspect of its business and is committed to complying with all applicable laws, including anti-corruption laws, consistent with its commitment to conducting its business with ethics and integrity.

This is a core commitment of Astellas embodied in the Astellas Group Code of Conduct and the Astellas Group Policy on Anti-Bribery and Anti-Corruption Compliance. In addition, Astellas is a signatory to the United Nations Global Compact, including its 10th Principle Against Corruption, and the Tokyo Principles for Strengthening Anti-Corruption Practices.

Astellas’ Chief Ethics & Compliance Officer has overall responsibility for overseeing and implementing Astellas’ global compliance program, including its anti-bribery and anti-corruption (ABAC) program, with the assistance of the Global Compliance Committee. The Chief Ethics & Compliance Officer, in turn, has designated Ethics and Compliance professionals with global and regional responsibilities for Astellas’ ABAC program.

Astellas’ ABAC program is designed to provide reasonable assurance of compliance with Astellas’ commitment against corruption. The program consists of ABAC policies and procedures, trainings and communications, risk assessments, monitoring and auditing, reporting and investigation activities.

Astellas has ABAC policies and procedures that embody its commitment against corruption.  These policies and procedures are consistent with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and other applicable local anti-bribery and corruption laws and regulation. Astellas prohibits all forms of bribery and corruption, including facilitation payments.

Astellas requires all employees to complete annual ABAC training. This training is available in 22 languages. Astellas additionally provides specialized ABAC training to target audiences based on their functions or roles in the company, as well as where we have identified risks and needs.

As described above, Astellas conducts compliance risk assessments and compliance monitoring, including on aspects of its ABAC compliance program. Astellas Ethics & Compliance also works closely with the Astellas Legal Department to investigate potential incidents of ABAC non-compliance and with the Astellas Internal Audit Department on the audit of Astellas affiliates and third parties covering activities that may involve ABAC risks. Astellas continuously seeks to improve its ABAC program based on these activities to assure the program remains effective and up-to-date in addressing changing risk.

Astellas has established an internal control environment designed to comply with J-SOX regulatory requirements to ensure financial reporting integrity as well as fraud prevention and detection. Its financial controls provide complementary assurance of compliance with its anti-corruption commitment.

A core principle of our ABAC compliance program is to prohibit third parties from engaging in activities that we prohibit for our own employees. This principle is embodied in the Astellas Group Policy on Anti-Bribery and Anti-Corruption Compliance and the Astellas Business Partner Code of Conduct. To adhere to this principle and mitigate and manage the risk arising from third parties providing services on our behalf, Astellas has established a process to conduct bribery and corruption compliance due diligence assessments on third parties interacting with healthcare professionals or government officials on our behalf. In addition, Astellas periodically exercises audit rights over third parties, and has risk-based ABAC clauses for contractual arrangements with third parties.