Astellas strictly prohibits bribery and corruption in any aspect of its business, consistent with the organization’s commitment to conducting its business with ethics and integrity. One critically important compliance priority is to manage bribery and corruption risk arising from the engagement of third parties that provide services on our behalf.

Astellas must contract with third parties across the globe to conduct its business but recognizes that these relationships can raise bribery and corruption risk, particularly if the third party engages with healthcare professionals or government officials on our behalf.

A core principle of our anti-bribery/anti-corruption compliance program is to ensure that the Company does not allow third parties to engage in activities that we prohibit for our own employees. To adhere to this principle and mitigate and manage this risk arising from third parties providing services on our behalf, Astellas has a process in place to conduct bribery and corruption compliance due diligence assessments on third parties interacting with healthcare professionals or government officials on our behalf.

From this assessment, Astellas can determine the level of bribery and corruption risk it will be taking on by contracting with the third party and take appropriate measures to manage this risk. Such measures include requiring the third party to implement its own bribery and corruption compliance policy and program, train its employees on bribery and corruption compliance, and allow Astellas to oversee the third party’s bribery and corruption compliance program.