Compliance

Basic Approach to Compliance

Over the years, the Group has earned the reputation of being trustworthy. We believe it is the trust placed in us that has helped us grow to what we are today. To take the Group to the next level, we must meet the wants and expectations of customers and all other stakeholders as a public institution of society. To make it possible, we have established a clear code of conduct that guides each employee toward responsible, legally compliant behavior.

Compliance Promotion System

Based on the recognition that the promotion of compliance is one of the most important management issues, in 2020 we established a Compliance Committee chaired by the President and Chief Operating Officer. The Committee comprehensively promotes compliance with social norms and the strengthening of corporate ethics, and promptly reports important compliance matters the Committee is involved in to the Board of Directors. In March 2023, we created a Compliance Division to reinforce the compliance promotion system.

Initiatives to Instill Compliance Awareness

ROHTO Group Action Agenda for Compliance

Compliance Awareness Survey

We conduct employee awareness surveys to ascertain current awareness and confirm effectiveness by tracking changes over time and to periodically review compliance-related standards of conduct. In fiscal 2021, the survey targeted managers and leaders. We plan to expand the target in the future.

Training for managers and all members

Compliance training is provided according to positions with the aim of instilling responsibility and values appropriate for each role.
Moreover, in 2022 we started providing all members with compliance training that consists of lectures and tests, to bring home the importance of legal compliance and ensure their understanding of Rohto's compliance system. In fiscal 2023, the ROHTO Group Action Agenda for Compliance, a booklet, was distributed to all members to increase their understanding of compliance and to publicize the contact points. The topics covered by compliance training for all members include drug-induced suffering, which used to be taught to members of the relevant sections only. We will continue working to enhance
members' understanding of compliance on a Group-wide basis.

Rohto Group Action Agenda for Compliance

Greater dissemination of compliance information

We issue the monthly Compliance Newsletter for all employees with the aim of sharing information on overall compliance, including legal matters and harassment. In addition, we endeavor to provide opportunities for them to familiarize themselves with various cases, for example by having a compliance quiz in our email newsletter every month. In fiscal 2023, we issued a total of 48 email newsletters. In addition, by producing videos in-house and disseminating information using the videos every month, we strive to entrench compliance knowledge and raise awareness in daily life. Managers are given compliance case studies every week as they are required to uphold high ethical standards and have greater knowledge.

Anti-corruption

Our goal is to create a truly healthy and progressive society. To that end, we prohibit participation in bribery, discrimination, harassment, conflicts of interest, insider trading, money laundering, and other corrupt practices. We do not respond to any act of obstruction or harassment, or any request for unfair benefits. We do business in over 115 countries. Overseas, we must abide by the laws and common sense of the local country and follow the culture and customs of that country. However, we do not follow practices that are considered wrong by international standards, such as bribery. Through our corporate activities, we will strive to contribute to the economic, social, and cultural development of the country in which we operate.
ROHTO signed the United Nations Global Compact in 2018. We are committed to addressing corporate social responsibility even more than before, and will respect and comply with Principle 10, "Companies should work to prevent corruption in all forms, including forbearance and bribery, "as well as strive to realize the sustainability of society as a whole. We will also seek the consideration of our domestic and overseas suppliers.
This policy is also applied to the selection of business partners, such as suppliers and business partners, and when due diligence is conducted, it is always checked for its own guidelines. In addition, even after the start of trading, we are prohibited from receiving all unreasonable rewards and gifts.

In order to prevent all corruption, including not only monetary matters such as bribery, but also non-monetary convenience, ROHTO Pharmaceutical has a complete internal reporting system (Rohto Group Alert Line). Here, it is promised that the whistleblower will not suffer any disadvantage by being able to speak first to a third-party outside lawyer. The Internal Audit Office collects information promptly in the event of an internal report by a subsidiary or group company, including overseas, in order to establish a group-wide risk management system. These policies and systems are described in the ROHTO Group Action Agenda for Compliance and communicated to all employees.

UN Global Compact

Data related to corrosion prevention

There were no cases in which employees were terminated due to corrupt practices such as bribery in fiscal 2023. In fiscal 2023, there were no cases of legal actions taken as a result of corrupt practices, such as bribery, or costs incurred for settlement.

Tax Transparency

Our Group properly understands and respects the tax laws and regulations of the countries and regions in which we operate, as well as the spirit thereof, and fulfills our tax liability appropriately. We will implement highly transparent and appropriate tax procedures, work to optimize tax expenses, and contribute to the development of local communities and the enhancement of corporate value.

ROHTO Group Tax Policy

Political Contributions

Our group did not make any political contributions in fiscal 2023.

Internal and External Reporting Systems

Flow Chart for Addressing Whistleblowing Received at Consultation Desk

Whistleblowing System

We have set up a ROHTO Hotline, as an internal reporting system for employees to consult and report illegal or potentially illegal activities, including harassment and corruption in the workplace. The ROHTO Hotline is connected to an outside law firm to ensure that whistleblowers are not subjected to any disadvantages, thereby providing a system for dealing with issues that are difficult to resolve within the workplace. From January 2022, we strengthened the whistleblowing system by expanding the ROHTO Hotline to incorporate 10 domestic Group companies and it became known as the ROHTO Group Hotline.

Rohto Group Alert Line

External Reporting System

We have also created a Business Partner Alert Line, a compliance contact point where the officers and employees of our business partners can consult or report on the compliance violations of our Group personnel. We hope that this contact point for external partners will help us detect and rectify compliance violations at an early stage by informing us of compliance issues that the Group itself is unaware or ignorant of.

Business Partner Alert Line