SUSTAINABILITY POLICY

Approach to Sustainability

MEDIC PHAMA PRODUCTS PTD LTD.’s Sustainability

MEDIC PHAMA PRODUCTS PTD LTD., is working on social issues by fighting disease and improving healthcare through its business activities as a medical device manufacturer and by contributing to the realization of a sustainable society. To realize its management philosophy, MEDIC PHAMA PRODUCTS PTD LTD., is working in all areas, including products, services, technology, financial standing and quality of its employees, to earn the trust of customers and all stakeholders including shareholders, business partners and society.

MANAGEMENT PHILOSOPHY

We contribute to the world by fighting disease and improving health with advanced technology, and create a fulfilling life for our employees.

To realize its management philosophy, the Company aims at achieving sustained growth and establishing reliance as a Company that is highly evaluated by the customers, shareholders, clients and society in all aspects including products, service, technology, financial strength, quality of employees, and other points.

MEDIC PHAMA PRODUCTS PTD LTD., Group is committed to establish and maintain a robust and effective compliance program with zero tolerance for any misconduct and violation of applicable laws and regulations. In order to enjoy perpetual growth as a company with social significance, each and every one of us must ensure compliance and act based on high ethics with good sense as a member of society.

  1. Our Compliance Policies

MEDIC PHAMA PRODUCTS PTD LTD., is fully committed to a program of sound ethics and rigorous legal compliance. Aside from being the “right” thing to do, these principles ensure that MEDIC PHAMA PRODUCTS PTD LTD., does not lose one of its most valued assets—the trust of its customers, business partners, and stakeholders.

MEDIC PHAMA PRODUCTS PTD LTD.’s commitment to ethical and responsible actions is embodied by its Code of Ethics and Conduct (the “Code”). The Code requires all executives, employees, part-time employees, temporary employees, etc. (collectively, “Employees”) to comply with all laws, regulations, and Company policies.

The Code further requires Employees to abide by ethical standards and respect social justice. Employees are obligated to clearly explain the purpose and contents of the Code to customers, distributors, and business partners.

The Company’s Charter of Conduct sets forth guidelines by which the Company and its Employees must abide. These guidelines ensure that the Company’s business activities comply with the Company’s Management Philosophy. The Board of Director has adopted these policies, ensuring that these values are promoted from the highest levels of the Company. These policies are subject to refinement or change as the Board deems appropriate.

  1. Compliance Organizational Framework

The Compliance Committee is an organization consisting of directors, officers, and senior managers designated by the Board of Directors. The Compliance Committee ensures and enhances compliance by (i) establishing and amending the Company’s compliance policies; (ii) supervising, evaluating, assessing, reviewing, and continuously improving the compliance program of the Company; (iii) coping with important compliance issues; and (iv) studying, assessing, addressing, and implementing other compliance matters.

The Chief Compliance Officer (CCO) is responsible for management, operation, and implementation of the compliance program throughout the Company.

The Divisional and Local Compliance Officers are empowered and authorized to implement, ensure, and enhance the compliance program in each division or subsidiary. The CCO carefully selects these individuals and regularly communicates with them to verify that global policies are implemented.

III. Internal Reporting System

The Company’s reporting system is an integral component of its strong compliance culture. Employees are required to report any violations of laws, regulations, or Company policies. If Employees do not feel comfortable reporting to their supervisors, they have the option to use an internal or external hotline service.

All integrity compliance-related matters reported through these systems are investigated by the CCO, in coordination with Local Compliance Officers as necessary. Furthermore, the CCO reports all such matters to the Compliance Committee.

The Company forbids all forms of retaliation against individuals who make reports in good faith. However, to alleviate any concerns of reporting Employees, the Company accepts anonymous reports.

  1. Preventing Corruption

MEDIC PHAMA PRODUCTS PTD LTD., Code of Ethics and Conduct prohibits any act of illegal bribery or corrupt act towards Japanese and foreign public officials, and ensures compliance with laws and regulations preventing corruption in every region in which MEDIC PHAMA PRODUCTS PTD LTD., engages in business, including bribery and corruption-related laws in Japan, the Foreign Corrupt Practices Act (FCPA) in the United States, and the Bribery Act in the United Kingdom. Furthermore, MEDIC PHAMA PRODUCTS PTD LTD., has established the Anti-Corruption Policies, which prescribe detailed rules and procedures to prevent bribery, and ensures thorough adherence thereto. The Company also asks business partners including overseas distributors to understand and cooperate for MEDIC PHAMA PRODUCTS PTD LTD.’s anti-corruption efforts through providing the MEDIC PHAMA PRODUCTS PTD LTD., Code of Ethics and Conduct and educational materials for the anti-corruption.