Corporate Activities Based on the Chugai Code of Practice
The IFPMA Code of Practice states in its Foreword, “There is no doubt that this industry brings great value to society in helping to improve global health but we are deeply conscious we can never rest on our laurels. All who work in it, over two million employees, are properly held to higher standards than most because the very nature of our business requires us to win and retain patient trust. Trust is the life-blood of our industry. It goes without saying that key ethical and safety values must be embedded within this highly regulated industry.”
Chugai has established a basic policy on promotion activities for pharmaceuticals and interactions with medical institutions, healthcare professionals, patient groups, etc. It has also established a Code of Practice, a global policy that aims to constantly ensure high ethical standards and transparency in corporate activities, to be accountable, and live up to the trust placed in us by society.
In Japan, we are a proactive participant in the Fair Trade Council of the Ethical Pharmaceutical Drugs Marketing Industry, the entity which issues the pharmaceutical industry’s voluntary guidelines, and in the Code Compliance Committee of the Japan Pharmaceutical Manufacturers Association. We have also established our own Chugai Code of Practice, and promote ethical corporate behavior not only in our promotional activities but also in the interactions between all of our officers and employees with researchers, healthcare professionals and patient groups.
In our activities to provide information on pharmaceuticals, we provide healthcare consumers and healthcare professionals with accurate and appropriate information essential to the selection and use of pharmaceuticals. The labeling and advertising of pharmaceuticals are regulated by the Pharmaceutical and Medical Device Act and other applicable laws and regulations, The Guidelines for Prescription Drug Marketing Information Provision from the Ministry of Health, Labour and Welfare (MHLW), as well as applicable laws and regulations and pharmaceutical manufacturers’ associations codes of practice in each country. The information that we provide conforms to these regulations.
It is necessary for the proper use of pharmaceuticals and improvement of treatment techniques to properly work for collaboration with healthcare professionals and medical institutions. We will work to increase the transparency of our involvement in the collaborative activities, and properly disclose related costs for the purpose of increased social recognition and trust.
Education and training are important in order to promote corporate activities with high ethical standards. We regularly provide officers and employees with education and training on the Chugai Code of Practice in addition to each country’s applicable laws and regulations and pharmaceutical manufacturers’ associations codes of practice.
In addition, we have participated in numerous industry initiatives, including the International Federation of Pharmaceutical Manufacturers and Associations, The Federation of Pharmaceutical Manufacturers’ Associations of JAPAN, The Japan Pharmaceutical Manufacturers Association, the Pharmaceutical Manufacturers’ Association of Tokyo, The European Federation of Pharmaceutical Industries and Associations, Japan, The Fair Trade Council of the Ethical Pharmaceutical Drugs Marketing Industry, Risk/Benefit Assessment of Drugs-Analysis & Response Council, and the Japan Pharmaceutical Information Center. We support the relevant codes and guidance stipulated by each organization.
Efforts to prevent corruption
In order to eliminate unlawful acts in pursuit of immediate benefits and unethical acts that abuse loopholes, Chugai prohibits bribery, graft, and other corrupt acts in the Chugai Group Code of Conduct.
Specifically, it has established an Anti-Bribery Policy, and prohibits bribery and facilitation payments (small payments made to domestic or foreign public officials for the purpose of expediting general administrative or clerical services) to business partners, including public officials and healthcare professionals, either directly or indirectly through third parties.
Regarding entertainment, gifts, and invitations, employees are required to comply with the laws and regulations of each country, regardless of whether they are spending their own money, and they are prohibited from providing cash, cash vouchers, prepaid cards, gift cards or other cash equivalents.
When conducting transactions with all suppliers, including agents and other intermediaries, we conduct risk assessments on the content of these transactions to prevent corruption. For high-risk transactions, memorandums are signed with the officers, employees, delegates, distributors, agents, consultants and other subcontractors of the client prohibiting them from either directly or indirectly engaging in corrupt acts such as bribery, buy-offs, embezzlement, misappropriation, or any other illegal act intended to induce transactions. In addition, among suppliers that are important to our business activities, we send check lists to and conduct in-depth risk assessments on those that are located in regions where the risk of corrupt acts is relatively high.
As a member of the non-profit organization Transparency International Japan, the Chugai Group is working to gather information on risks of bribery and corruption worldwide, and periodically makes revisions to its bribery and corruption risk map.
Education and training are provided regularly in CCC and Human Rights Training, a compliance training program held twice a year for officers and all employees. E-learning materials have also been posted on the intranet, allowing officers and employees to study them when needed.
The CCC Hotline and Chugai Speak-Up Line have been established as points of contact to provide consultation for and receive reports from officers and employees regarding anti-corruption. Issues reported are investigated impartially and with strict confidentiality to find a solution while respecting the opinion of the person who made the consultation. Company rules prohibit retaliation or any other disadvantageous treatment of employees who seek consultation or make reports.
Policies regarding anti-corruption efforts and activity progress are reported to and deliberated by the Compliance Committee. They are also reported to the Executive Committee and the Board of Directors for instructions.
In FY 2020, no one was subject to disciplinary dismissal for violating anti-corruption policies.
CCC and Human Rights Training
Chugai conducts annual training for all employees. In the first half of the year, the content focuses on corporate ethics, and in the second, on respect for human rights.
In the first half of 2020, education was provided on the themes of strengthening measures to prevent harassment and the harmful effects of medicines. In regards to education on strengthening measures to prevent harassment, participants gained an understanding of the purpose and main content of the amendments to the Power Harassment Prevention Act, which came into effect in June 2020, and learned what was important to make the workplace harassment-free.
In the education on the harmful effects of medicines, participants learned about past cases concerning the harmful effects of medicines and the reality of health damage. Participants also confirmed what each employee can and should do while being mindful of preventing health damage from pharmaceuticals to the greatest extent possible.
In the second half, participants confirmed the importance of each one of us being mindful of the key points as we maintain autonomous compliance in order to continue to act with integrity as before, even as our work style and work environment change due to the spread of the COVID-19.
In addition, it has been reported that discrimination is more likely to occur in the presence of social anxiety and dissatisfaction, as is currently the case with an economic recession and an infectious disease pandemic threatening mankind. Participants confirmed that there were forms of discrimination and prejudice that stem from social groups and social categories as causes other than an individual’s stereotypes. They also learned that it was important to create a workplace free of discrimination by having each individual show mutual respect toward others who they might engage with during the course of their work both inside and outside the company.
CCC Hotline and Chugai Speak-Up Line
The CCC Hotline and Chugai Speak-Up Line is available to provide consultation for and receive reports from the Chugai Group employees and other individuals regarding laws, Company rules, the CCC or related matters. Issues reported are investigated impartially and with strict confidentiality to find a solution while respecting the opinion of the person who made the report.
Company rules prohibit retaliation or any other disadvantageous treatment of employees who seek consultation or make reports via the hotline. The goal of using the CCC Hotline to respond to problems or other matters that are difficult to discuss and resolve in the workplace is to create a reassuring work environment for all employees.
In addition, in-house area counselors and an external hotline have been set up to handle issues regarding harassment.