Shionogi established the Shionogi Group Anti-Corruption/Anti-Bribery Policy on April 1, 2014. In the same year, to enhance the effectiveness of the Policy, it conducted a questionnaire survey and interviews on all of its organizations and group companies to identify the risks of anti-corruption and anti-bribery problems. Reflecting the results of the surveys, the Guidelines for the Prevention of Corruption/Bribery for Shionogi Business Partners were formulated, which have been being applied to date.

Also, we periodically provide education mainly on the Unfair Competition Prevention Act (Article 18), the US Foreign Corrupt Practices Act (FCPA) and the UK Anti-Bribery Act for all employees (including part-timers and contract employees)*. Departments that have many opportunities to come in contact with healthcare providers, who are quasi-government employees, are considered as high-risk organizations, and we conduct education for such departments concerning the Shionogi Prescription Drug Promotion Code and the like on a regular basis.

* The rate of attendance of the education programs (online training) in fiscal 2019 was 99.1% on the Unfair
Competition Prevention Act (Article 18), and 97.1% on the US FCPA and the UK Anti-Bribery Act.