Compliance

Compliance System

At Terumo, the Internal Control Committee, which is responsible for enacting the Internal Control System within the Terumo Group in accordance with the "Internal Control System Design Basic Policy" approved by the Board of Directors, shall deliberate and make decisions regarding important policies related to compliance, and regularly report the status of these activities to the Board of Directors and Audit/Supervisory Committee. The Chief Legal Officer (CLO), in cooperation with the compliance officers of the Terumo Group companies who are in charge of promoting compliance related activities, promote a variety of measures including creating related rules, performing training and education, and monitoring to quickly discover and ascertain compliance issues. In the event that any significant compliance violations, etc. occur, a handling team shall be immediately organized under the direction of the chairperson of the Internal Control Committee, and that team shall, in addition to handling and resolving the occurrence, report and make proposals to the Internal Control Committee regarding the cause and recurrence prevention measures.

Anti-bribery and corruption

All Terumo associates observe the "Terumo Group Code of Conduct" and the "Terumo Global Anti-corruption and Anti-bribery Policy" in all dealings with public institutions, related officials and the employees of public medical institutions. These codes aim to ensure that all business is conducted in a transparent, fair, and honest manner. Full compliance is expected under Japan's Unfair Competition Prevention Act, the US Foreign Corrupt Practices Act, and other anti-bribery laws within the countries and regions where Terumo Group operates.

Those efforts will not be successful by ourselves only, and cooperation from business partners is essential. Therefore, Terumo has established "Terumo Global Third Party Anti-corruption and Anti-bribery Policy" for the business partners who has necessity to cooperate, and is requesting the business partners to comply with the policy.

Prohibition of Collusion and Cartels

In recent years, the anti-competitive practices such as collusion, action as a cartel, or other kinds of violations of competition laws have been uncovered and subjected to strict punishment. To help ensure that it does not contribute to such activities, Terumo established the “Terumo Group Global Antitrust Policy” in January 2015. In addition, the Terumo Group conducts cartel prevention training for associates in Japan and overseas in a Group-wide effort to maintain free and fair competition.

Whistle-blowing System

When we are aware of compliance issues, taking appropriate measures, such as investigation, preventive action, disciplinary action and/or recurrence prevention measure are important. For such actions to be taken, it is necessary to ensure that any associate can report any compliance concern within the company without a fear of retaliation against the report. This is why Terumo established the “Terumo Global Compliance Violations Reporting and Anti-Retaliation Policy”. Under the Policy, Terumo builds and operates a whistle-blowing system in which Group Employees can, upon discovering compliance violations, etc., can report problems out of their usual line of authority. Further, the divisions operating the whistle-blowing system shall report on its status to the President of Terumo Corporation, the Internal Control Committee, and the Audit/Supervisory Committee as appropriate.

Combating Anti-social Forces

Avoiding relationships with anti-social forces is one of Terumo's corporate responsibilities. We, therefore, strictly refuse to become involved in any relationship with anti-social forces and engage in no transactions with companies, other organizations, or individuals with ties to anti-social forces. Furthermore, we work with law enforcement authorities and other agencies to combat anti-social forces.

Status of Efforts to Combat Anti-social Forces

  • The General Affairs Department coordinates responses to inappropriate demands by anti-social forces, and the prevention of such inappropriate demands has been made the specific responsibility of a designated associate within the General Affairs Department.
  • We have established a system for cooperating with law enforcement authorities, Tokubouren (NPO assisting companies in combating corporate blackmailers), legal advisers, and others, and acting on their advice and guidance.
  • We have established a system for properly sharing information on anti-social forces with the groups mentioned above, and centrally managing it in the General Affairs Department.
  • We have prepared the Manual for Combating Anti-Social Forces and are promoting thorough understanding of its contents among everyone working at Terumo.
  • We provide executives and associates with relevant information in a timely manner, conduct training, and take the steps, as well, to promote awareness of the importance of combating anti-social forces.

Appropriate Relationships with Healthcare Professionals

Terumo abides by the "Fair Competition Code" of the Japan Fair Trade Council of the Medical Devices Industry, "Code of Practice” of the Japan Pharmaceutical Manufacturers Association, “Promotion Code" of the Japan Federation of Medical Devices Associations, and other industrial regulations to ensure that it follows appropriate promotion practices for medical devices and pharmaceuticals. As there are more and more global business opportunities, we established the "Terumo Global Ethical Interactions with Healthcare Professionals Policy” based on the principles under the codes of ethics of internationally reputable industrial associations, in addition to "Terumo Code of Practice". We keep developing and improving continuous in-house education for associates in order to promote awareness and thorough understanding of appropriate relationships with Healthcare Professionals. Going forward, we will continue to abide by these guidelines and practices.

Those efforts will not be successful by ourselves only, and cooperation from business partners is essential. Therefore, Terumo has established "Terumo Global Third Party Anti-corruption and Anti-bribery Policy" for the business partners who has necessity to cooperate, and is requesting the business partners to comply with the policy.

Making the Relationship between Corporate Activities and Medical Institutions Transparent

To communicate Terumo's contribution to life science and the high ethical standards with which we conduct our business activities, we formulated our "Transparency Guideline for the Relationships between Corporate Activities and Medical Institutions" and "Transparency Guideline for the Relationships between Corporate Activities and Patient Organizations."

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