OUR hhc MISSION GUIDES HOW WE ACT AS A COMPANY

As a human health care company, corporate responsibility is a part of who we are. Everything we do — as a company and as individuals — is focused on earning and maintaining trust with patients, their families and caregivers, our colleagues, stakeholders, business partners and the communities we serve.

HERE’S OUR CORPORATE OBJECTIVE:

To be a human health care company capable of making a meaningful contribution under any health care system while observing the highest legal and ethical standards in our business activities. — Eisai Compliance Handbook

As a statement of our commitment to ethics and compliance, Eisai has set forth a Charter of Business Conduct for all affiliates throughout the world.

To further ensure that our directors, officers and employees exhibit integrity and a positive image that reflects our mission and values, Eisai has established a Comprehensive Compliance Program (CCP). It incorporates the elements of:

  • United States Department of Health and Human Services (HHS) Office of Inspector General (OIG) Compliance Program Guidance for Pharmaceutical Manufacturers
  • U.S. Department of Justice's Evaluation of Corporate Compliance Programs
  • Pharmaceutical Research and Manufacturers of America (PhRMA) Code on Interactions with Healthcare Practitioners

Our CCP also complies with the requirements of Chapter 8, Section 119400 of the California Health and Safety Code. View our declaration of compliance

Eisai insists that all of our employees, contractors and agents comply with our Comprehensive Compliance Program.

8 ESSENTIAL WAYS WE MAINTAIN THE HIGHEST ETHICAL STANDARDS

  • 1 — STAY EVER-VIGILANT ABOUT COMPLIANCE

    Our CCP is overseen by the Chief Ethics and Compliance Officer. The Compliance Officer is a member of the Executive Committee and regularly reports to that committee and the Global Compliance Committee regarding implementation of the Compliance Program. These committees provide input and oversight of compliance initiatives and ongoing programs on a regular basis. In addition to the oversight provided by these committees, the Compliance Officer reports regularly to the U.S. Board of Directors.

  • 2 — ESTABLISH COMPREHENSIVE POLICIES

    Eisai’s Compliance Handbook sets forth the legal and ethical standards and values that guide all Eisai colleagues worldwide in their daily activities.

    Additionally, Eisai has adopted policies to address our legal and regulatory requirements, including policies to ensure that all interactions with health care providers (HCPs) focus on appropriate informational, scientific and educational exchanges.

  • 3 — EDUCATE AND TRAIN

    Eisai’s learning program is designed to help our employees understand their legal and ethical obligations and specific requirements that impact their daily job responsibilities. In addition, we’ve created a communication and training program to ensure that colleagues are up to date on their training requirements and know how to access policies and procedures that impact their jobs.

  • 4 — ENCOURAGE HEALTHY, FREE-FLOWING INTERNAL DIALOGUE

    The channels of communication run both ways at Eisai.

    We keep our employees informed about policy changes, new compliance initiatives and training programs through:

    • Internal communications
    • Company intranet postings
    • Communications from senior management that are cascaded through the organization

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    We also strongly encourage employees to ask questions and raise concerns, and we want them to do so freely and without fear of repercussions. That’s why we created a toll-free, anonymous disclosure program — our Compliance Helpline (1-800-467-1391.) It’s managed by Ethics Point, our 3rd party provider, and is available 24/7 to any employee who has a compliance- or ethics-related question or wants to report in good faith a suspected violation.

  • 5 — CONSTANTLY AUDIT AND MONITOR

    We follow OIG Guidance in managing the way we audit and monitor compliance because regulatory requirements, business practices and other factors change frequently. We review our monitoring program each year and augment it regularly to ensure that it’s focused on significant business activities and risks.

  • 6 — ENFORCEMENT OF STANDARDS

    Our policies clearly state the consequences of violating law, regulations and company policies, as well as failure to report instances of non-compliance to state and federal authorities, where required or appropriate. Although each situation is unique and considered on a case-by-case basis, we’re unwaveringly committed to taking appropriate disciplinary action to address misconduct and deter future violations.

  • 7 — TAKE CORRECTIVE ACTION

    Our responsibility as a human health care company is to act swiftly and decisively to address and deter misconduct. As a result, we’re committed to responding promptly to potential violations of law, regulations or company policies, and to taking appropriate disciplinary and corrective actions whenever and wherever necessary.

  • 8 — MAINTAIN TRUE TRANSPARENCY

    We’re committed to meeting our obligations regarding disclosures, including payments and/or other transfers of value provided by Eisai or our agents to certain health care professionals and health care organizations. We comply with an array of global transparency laws, codes, regulations and disclosure requirements, including:

    We’re also strong proponents of clinical trial transparency, and we publicly disclose information about our qualifying studies on the National Institutes of Health’s database of privately and publicly funded clinical studies conducted around the world.

WE COMPLY WITH THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

To understand what personal information we collect, use and disclose about California residents, view our Privacy Policy. If you’re a California resident and would like to make a request to access or delete your information, please be sure to upgrade your browser to Google Chrome, Mozilla Firefox, Apple Safari or Microsoft Edge and visit our California Residents Only portal, or call our toll-free number, 1-833-746-2910.

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EISAI IS COMMITTED TO POSITIONING COMPLIANCE (OBSERVANCE OF LEGAL AND ETHICAL STANDARDS) AS THE CORE OF ALL OUR EVERYDAY BUSINESS ACTIVITIES AND STRIVING TO FULFILL CORPORATE SOCIAL RESPONSIBILITIES.

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From Eisai’s Articles of Incorporation, 2005, First Section