Compliance Policy

1. Relationships with Customers

1. Provide optimal solutions, service, and support
   We will always adopt the perspectives of our customers to identify their needs, and provide the best possible solutions, service and support to assist their growth.
2. Engage in fair and honest business practices
   We will comply with all laws and regulations and engage in fair and honest business practices.

2. Relationships with Employees

1. Respect human rights
   We will respect each individual’s human rights. We will not use discriminatory language or behavior, and will not engage in sexual harassment or power harassment towards our employees.
2. Foster personal growth and personal development
   The OTSUKA CORPORATION Group will build and maintain the necessary infrastructure, systems and operations to enable employees to grow and achieve personal development through their jobs.
3. Provide fair and full compensation
   The OTSUKA CORPORATION Group will provide fair and full compensation to employees for work performed, based on their performance, behavior at work, and capacity to perform their duties.
4. Maintain health and safety of employees and the work environment
   The OTSUKA CORPORATION Group will help our employees lead physically and mentally healthy lives and will maintain proper safety and health standards in the work environment.

3. Relationships with Shareholders and Investors

1. Provide timely and appropriate disclosures of information
   We will comply with all relevant laws, regulations, stock exchange and other rules, and maintain continuous disclosure of all material information in an accurate, timely and fair manner. This compliance is crucial for us to “become a corporate group that is recognized and trusted as a valuable corporate citizen.”
2. Prohibit insider trading
   We will not engage in insider trading, as this would obstruct the sound operation and fairness of the securities market.

4. Relationships with Business Partners

1. Respect our business partners
   We will respect our business partners as important partners, and strive to build fair and principled relationships with them.
2. Prohibit gifts and entertainment that exceed social norms
   We will not provide gifts or entertainment for business partners beyond the bounds of socially-accepted norms. Neither will we accept gifts or entertainment from business partners.

5. Relationships with Society

1. Promote social contribution activities
   We will widely and actively promote social contribution activities, including support for local communities, with the aim of contributing to the creation of an enriched society.
2. Promote environment conservation activities
   We will strive to reduce the environmental burden associated with our business activities and provide environmentally-friendly products and services, in order to coexist in harmony with nature and society.

6. Other Relationships

1. Comply with antitrust laws
   We recognize the principles of fair and free competition, and will not engage in private monopolies, participate in cartels, or engage in unfair business practices.
2. Prohibit unfair competition
   We will not compete unfairly in the marketplace, including selling or manufacturing fraudulent products, improper acquisition or use of trade secrets, and other similar acts.
3. Establish appropriate relationships with regulatory and supervisory agencies
   We will make timely and appropriate reports to the relevant regulatory and supervisory agencies. We will not give gifts, entertain, or provide other benefits to members of public institutions.
4. Protect intellectual property
   We will protect the intellectual property of the OTSUKA CORPORATION Group while respecting the intellectual property of others.
5. Protect confidential information
   We will appropriately manage all information deemed to be confidential (including personal information, customer information and confidential information of the OTSUKA CORPORATION Group) and will not share such information with others without justifiable cause.
6. Reject antisocial forces
   We will take a firm stand against antisocial forces that threaten the safety and well-being of society, and will refrain from any relations with such forces.
7. Prohibit conflicts of interest
   We will clearly distinguish between work and personal life, conduct business honestly, and not engage in any acts that may conflict with the interests of the OTSUKA CORPORATION Group.

Compliance System

We have set up a Compliance Committee to implement and enforce our corporate compliance policy.

Compliance Committee Functions

Establish a plan for compliance training

1. Identify potential risks associated with business activities and formulate preventative measures
2. Establish a plan of action to deal with any compliance violations that may occur
3. Plan measures to prevent recurrence
4. Make proposals to the Board of Directors and implement approved policies and measures

Constituent Member

The Compliance Committee belongs to the Internal Control Committee.

Compliance Structure

1. Compliance Manual

The Compliance Manual presents the OTSUKA CORPORATION Group’s basic attitude towards compliance. We have established the Principles of Corporate Behavior based on the pledge in our Mission Statement to “fully comply with all prevailing laws and regulations, and maintain high ethical standards.” We aim to embed and enhance awareness of compliance through various training forums, including new employee training and new manager training.

2. Web Learning

All employees are required to take the following web learning courses to reinforce their basic knowledge.

1. Mission Statement
2. Compliance
3. Information Security
4. Harassment Prevention
5. P Mark

3. CP Licensing System

We operate a CP (compliance program) licensing system through web learning in order to encourage the reinforcement of knowledge about personal information protection and information security.

Initiatives to Ensure Compliance

OTSUKA CORPORATION has established internal and external helpdesks for consulting and reporting compliance infringements, with the aim of ensuring that we promptly discover and address compliance issues, and prevent their recurrence.

The OTSUKA CORPORATION Group has established the “Whistleblower Protection Regulations” in accordance with the Whistleblower Protection Act, and implemented Compliance helpdesks such as the Compliance Hotline. We make every effort to properly address any reports of infringements.

Privacy Protection

The identities of persons contacting the Compliance helpdesks, as well as the content of their conversations, will be kept strictly confidential. The Compliance helpdesks will protect persons contacting it from reprisals or other unfair treatment.

Anonymous Reporting and Consultation

The Compliance helpdesks will accept anonymous consultations, but may urge the person contacting the Compliance helpdesks to provide their real name wherever possible in specific cases where they are personally affected by the compliance issue.

Internal Compliance and Consultation Helpdesks

• Opinion Box (hotline to the President)
• Compliance Office (reception for the Compliance Hotline)
• Human Resources Development Department (Respond to requests received through the Women's Hotline and voluntary notifications that are difficult to consult on organizationally)
• “Harassment Hotline” external consultation hotline (consultation concerning harassment)
• ”Helpdesk Independent from Senior Management” external consultation hotline (for reports on compliance violations committed by corporate officers and employees)

Contact from Outside of the Company

Customer Service, Personnel & General Affairs Departments, and corporate website

Compliance-related Inquiries (OTSUKA CORPORATION Compliance Office)

Inquiries regarding compliance

Inquiries or reports (anonymous) regarding compliance