Management Compliance

Compliance Promotion Structure

The Mitsubishi Tanabe Pharma Group has in place a groupwide compliance promotion structure overseen by its Compliance Committee, which is chaired by the Chief Compliance Officer. Responsible persons for compliance / persons in charge of compliance (appointed in each unit) meet semiannually (overall/individually). These meetings are held to enhance cooperation with each unit, and share problems and heighten participants' sensitivity to risk associated with compliance and potential scandals, as well as enhance the ability of workplaces to address misconduct and compliance issues. In fiscal 2019, there were several compliance violations by employees and measures were taken to prevent recurrence.

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 it is timely and reasonably disclosed.
  7. 7We appropriately manage and efficiently use company assets.

Compliance Training

The domestic 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 is conducted 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:
Divisional training that focuses on specific topics relevant to each division is mainly conducted by 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 2019

Times held Number of participants
Groupwide compliance training Once a year 5,003
Divisional compliance training Once a year 4,889
Compliance and risk management check Twice a year July 2019 5,049
February 2020 4,876

Strengthening of Compliance Structure 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 of Group companies.

We have appointed Chief Compliance Officers at overseas Group companies. To strengthen compliance systems at Group companies outside Japan, we are pursuing a range of measures including the verification of reporting systems for the speedy sharing of information, and continuing education programs in consultation with each company.

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. In Japan, the lecture was relayed by video conference to all domestic branch offices, while overseas, explanations were provided to local employees based on the lecture materials.

At the annual compliance meetings, which are held every year at all Group workplaces in Japan, employees discussed the lecture content, read the Compliance Guidebook and signed pledges in which they vowed to conduct themselves in accordance with the Corporate Behavior Charter and Declaration of Compliance.

From fiscal 2019, we also held compliance meetings at overseas Group companies, and in the first year, the lectures were held based on the same content used in Japan.

FY2019 Corporate Behavior Charter Day
Compliance Meeting
(Mitsubishi Tanabe Pharma Indonesia)

Addressing Harassment

In the Declaration of Compliance, the Mitsubishi Tanabe Pharma Group states clearly that the Group "does not tolerate discrimination, harassment or any other behavior (such as sexual harassment and abuse of power) that violates basic human rights or inhibits the capabilities of any individual." As part of the Group's commitment to raising awareness and eliminating harassment in the workplace, this issue is addressed in groupwide compliance training, training for managers, and in training for new employees.

In July 2018, we issued the Harassment Prevention Guidebook and disseminated it in divisional training. We have added a harassment-related section to article 96 of the rules of employment (subject to disciplinary action), stipulating that sexual harassment includes discrimination or harassment based on LGBT*1 or other sexual orientation or gender identity, and that maternity harassment*2 and paternity harassment*3 are subject to disciplinary action. The Mitsubishi Tanabe Pharma Group believes that eliminating harassment is a key component of creating a comfortable work environment, which will in turn help boost the vitality and performance of the Group.

The Company has established, operates, and manages multiple harassment counseling services, such as internal and external hotlines and an external hotline to address difficulties and interpersonal relationships in the workplace.

  1. *1LGBT is a general term for sexual minorities. Based on the words Lesbian, Gay, Bisexual, and Transgender.
  2. *2Maternity harassment refers to harassment or unfair treatment of women in the workplace due to childbirth or childcare.
  3. *3Paternity harassment refers to harassment of men who actively participate in childcare.

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. Each hotline accepts anonymous reporting and requests for consultation. In principle, we respond to requests for consultations and reports made by members of the Group (including contract employees and temporary employees) and other relevant parties including business partners. Our policy for responding to matters pertaining to consultations and reporting concerning compliance violations is shown in the Code of Conduct below.

  1. 1Matters reported and consulted on will be responded to fairly and honestly strictly observing personal privacy.
  2. 2People who have consulted, reported or cooperated in surveys will not be treated unfavorably.
  3. 3We will not permit retaliation against anyone who has consulted, reported or cooperated in a survey.

In addition, we established a contact point (whistleblower line) for receiving inquiries about the laws, corporate ethics, and research ethics of the Group, or when employee misconduct or violations of the law occur or are highly likely to occur.

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 2019

Workplace environment Working condition / human resources Embezzlement / misappropriation Laws regulations, and rules Other Total
17 4 1 10 5 37

Protecting Customer Privacy

Mitsubishi Tanabe Pharma is committed to protecting its customers' personal information. In keeping with its strong sense of responsibility regarding this subject, the Company has released its Policy on Protecting Personal Information to the public. Toward this end, the Company uses only fair and reasonable methods to collect customers' personal information and utilizes this information only to the extent necessary to achieve the permitted purpose. In addition to this fundamental approach, it has taken the following initiatives with regard to the handling of personal information.

  1. (1)Established defined regulations regarding the protection of personal information
  2. (2)Issued the Personal Information Leak Prevention Manual
  3. (3)Instituted a structure for the protection of personal information, headed by a chief privacy officer (CPO) and staffed by privacy protection division managers and privacy protection personnel
  4. (4)Educated and trained employees; Supervised and audited subcontractors
  5. (5)Implemented robust data encryption and security measures on company computers