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## Promoting Compliance 

In addition to requiring all employees to observe applicable laws and regulations, we believe that providing employees specific criteria for making decisions is necessary to uphold high ethical standards in our business activities. Such criteria must be continuously reviewed and modified as appropriate to accommodate changes in society and systems. 

Using this basic approach, we have the Astellas Charter of Corporate Conduct, which specifies the Company’s business philosophy (raison d’être, mission, beliefs). We also have the “Astellas Global Code of Conduct” as a code that uniformly applies to Astellas employees throughout the world. The Astellas Global Code of Conduct provides employees worldwide with a set of specific rules that fol- lows our business philosophy and the Astellas Charter of Corporate Conduct. 

## Global Compliance Initiatives for 2014 

However, since it is not possible for the Astellas Global Code of Conduct to encompass all of Astellas’ global busi- ness activities, we have codes of conduct and policies spe- cific to each region or country that take into account local requirements, enabling our compliance programs. 

In fiscal 2013, Astellas has strengthened compliance and the Global Compliance Committee focused on 14 matters that would benefit from a global approach (e.g. anti-bribery/ anti-corruption, conflicts of interest, transparency and anti- harassment). In establishing the Global Compliance Initiatives for 2014 (see the table below), the Committee gave approval for representatives from each region to form a task force to create global policies and create a globally-unified training plan, among other measures. 

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