Organizational Governance Compliance

Compliance Promotion System

The Mitsubishi Tanabe Pharma Group has in place a Groupwide compliance promotion system overseen by its Compliance Promotion Committee, which is chaired by the Chief Compliance Officer. Compliance promotion personnel (appointed in each unit) meet semiannually (overall/individually). These meetings are held to enhance cooperation with each site, heighten sensitivity to risk associated with compliance and potential scandals, share information on related problems, and enhance the capacity of workplaces to address compliance issues. In fiscal 2018, there were no major compliance violations.

Mitsubishi Tanabe Pharma Group Compliance Promotion Structure
Declaration of Compliance
  1. 1We conduct our business with high ethical standards and in a professional manner as a global healthcare company.
  2. 2We respect human rights, and promote safe and healthy working environments.
  3. 3We comply with legal requirements and regulations that apply to our businesses and corporate activities.
  4. 4We work actively to protect the global environment and strive to realize the harmonious co-existence of the Company and society.
  5. 5We strive to trade and transact business in a fair manner at all times.
  6. 6We appropriately manage company information and data, and work to ensure that Company information and data is disclosed in a timely and reasonable manner.
  7. 7We appropriately manage and efficiently use company assets.

Compliance Training

The Group conducts the following training programs for the purpose of fostering a strong sense of ethics, raising awareness of compliance requirements, and cultivating greater awareness of compliance-related issues among all employees.

Groupwide compliance training:
E-learning for all Group employees intended to enhance rigorous compliance as well as human rights awareness the foundation of business operations in order to realize the corporate philosophy and vision.
Divisional compliance training:
We offer divisional training that focuses on specific topics relevant to each division, principally for compliance implementation personnel, including managers and staff.
Compliance and risk management check:
Through e-learning we confirm understanding of such matters as laws, regulations, and internal rules. This enables officers and employees to act in accordance with consistent evaluation standards.

List of Training Sessions Held in Fiscal 2018

Times held Number of participants
Groupwide compliance training Once a year 5,376
Divisional compliance training Once a year 5,385
Compliance and risk management check Twice a year July 2018 5,300
February 2019 5,137

Hotlines

The Mitsubishi Tanabe Pharma Group's internal and external hotlines allow employees and managers to obtain consultation and make reports about any actual or possible violation of laws, ordinances, or social conventions. The use of the hotlines leads to the prevention or reduction of scandals, etc., before major problems develop. In addition, reports on recent trends and issues warranting special mention are included in regular compliance training sessions, which helps promote use of the hotline and prevent recurrence.

Number of Hotline Consultations Handled in Fiscal 2018

Workplace environment Working
condition /
human resources
Embezzlement /
misappropriation
Laws regulations, and rules Other Total
9 2 0 4 7 22

Compliance at Group Companies Outside Japan

The Group has bases in North America, Europe, China, South Korea, Taiwan, ASEAN, and Israel. We are sharing policies that are important in Group management while considering the values of each country, such as the cultures, laws, and business practices. In this way, we are advancing the compliance and risk management of Group companies.
We have appointed Chief Compliance Officers at overseas Group companies and the Group consults regularly with relevant departments concerning action programs to strengthen compliance and risk management systems at subsidiaries outside Japan.

Implementation of Employee Attitude Survey

This survey is conducted with the objective of understanding employee satisfaction by asking Mitsubishi Tanabe Pharma Group employees questions regarding their thoughts about their work, the workplace environment, and other matters. In fiscal 2018, the response rate was 95.3%, with 5,121 responses.
This survey includes compliance awareness. In this way, we are tracking and periodically observing awareness on a Companywide level. We are utilizing the results to advance compliance by providing them to each division as feedback. Furthermore, we are working to increase compliance awareness among employees through such means as Companywide compliance training.

Corporate Behavior Charter Day

Taking into account the gravity of the Medway Issue and the related quality control problem (Pharmaceutical Affairs Act violation and GMP ministerial ordinance violation), and recognizing the need to prevent any further incidents of misconduct, the Mitsubishi Tanabe Pharma Group has introduced an annual Corporate Behavior Charter Day, which offers employees the opportunity to review the Group's Charter and reflect on their individual conduct. In fiscal 2019, we held a lecture on compliance at the head office and relayed it by video conference to our main domestic offices. With a keen desire not to forget past Company misconduct, our representative director gave a lecture this fiscal year. Annual compliance meetings were held at all Group workplaces in Japan. At these meetings, employees discussed the lectures' content, read the Compliance Guidebook and affixed their signature to pledges in which they vow to conduct themselves in accordance with the Corporate Behavior Charter and Declaration of Compliance.

Fiscal 2019 Corporate Behavior Charter Day lecture
President's message and a lecture by our representative director

Corporate Behavior Charter Cards

Corporate Behavior Charter Cards are distributed to employees.

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