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## Anti-Bribery/Anti-Corruption Initiatives 

Globally, countries have enacted laws and other measures to target corruption and bribery. In some countries, new stricter laws have been implemented. For example, authorities in both the U.S. and the U.K. have increased enforcement efforts regarding bribery of foreign government officials. Anti-corruption is one of the ten principles of the United Nations Global Compact, to which Astellas is a signatory. 

Against this backdrop, Astellas has strengthened its process to prevent bribery and other forms of corruption. Specific steps include establishing Global Anti-Bribery and Anti-Corruption Policy, which elaborates on the rules and principles designed to prevent bribery and corruption set forth in the Astellas Global Code of Conduct. We also have enhanced regional anti-bribery and anti-corruption policies and procedures, and enhanced third party due diligence guidelines. Additionally, we are conducting ongoing global training which includes continued training for chief compli- ance officers at our bases in Japan, Asia/Oceania, EMEA and the Americas, as well as enhanced global and regional training to our employees. Each of these measures has effectively strengthened awareness of global anti-bribery and anti-corruption regulations. 

Astellas Global Compliance System 

## Transparency Guideline and the Sunshine Act 

Astellas conducts basic medical and pharmaceutical research and clinical development of new drugs in collabo- ration with physicians, researchers, universities, and other research and medical institutions in bringing innovative medicines to patients worldwide. It is therefore important to reassure stakeholders that the business activities of pharma- ceutical companies are founded in a high sense of ethics and are intended to contribute to the advancement of medicine and pharmacology. To this end, pharmaceutical and medical device companies are required to provide information on their payments to physicians and medical institutions. In Japan, this disclosure is stipulated by the guideline of the Japan Pharmaceutical Manufacturers Association (Transparency Guideline), while in the U.S. it is set out in the Sunshine Act. There are also similar laws and regulations in other countries. Following these laws and guidelines, Astellas has established a structure for collecting and organizing this information swiftly and appropriately. Having done so, we then disclose it publicly, report it to the authorities, or take other steps as required in a timely and appropriate manner. 

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