Compliance / Risk management

We implemented, in April 2020, a three-line defense system in which the executive function and audit function each perform their separate roles while also working in close cooperation.

With compliance and risk management serving as a foundation for our business activities, we aim to achieve ongoing growth and increases in our corporate value while practicing management with a group perspective.

We established the Suzuken Corporate Ethics Charter and Corporate Ethics Charter Guidelines to clarify the basic code of conduct that each and every employee should practice in a proactive and independent manner.

Group executives, executive officers, counselors, trustees, and employees learn about compliance via e-learning and other means every year as part of efforts to instill the idea of compliance. After learning, each person pledges to always be cognizant of the fact that compliance comes first and to not commit any violations. Furthermore, discussions of compliance topics are conducted in the workplace.

In order to further bolster risk management, the Suzuken Group has established the Risk Management and Compliance Committee, which works under the Board of Directors and is responsible for managing risks across the Group.

To ensure that the risk management system works effectively and efficiently, the Group has established three practices committees and one expert committee under the Risk Management and Compliance Committee.

The practices committees are established in each business segment in which Suzuken and its Group companies are involved to handle practical matters regarding overall risks and compliance. The Review and Supervisory Practices Committee for Sales Information Provision Activities is also established to deliver proper sales information provision activities in an integrated manner with sales and production in accordance with the Guidelines for Prescription Drug Marketing Information Provision. Furthermore, the Antimonopoly Act Compliance Expert Committee is established as Antimonopoly Act compliance is one of the top priority items in the governance of the Group’s distribution business segment.

The subcommittees examine risks in view of the characteristics of each segment, identify risks that should be shared within the Group and addressed as high priority, and work to strengthen risk management capabilities focusing on risk prevention and mitigation as well as promotion of compliance measures.

A criminal complaint was lodged against the Company alleging violations of the Antimonopoly Law in the submission of a bid to the Japan Community Health care Organization (JCHO). In June 2021, the Tokyo District Court issued a ruling ordering us to pay a fine for the violation, and we received a cease and desist order and an order for payment of surcharge from Japan’s Fair Trade Commission in March 2022.

Also, in November 2021, the Company’s subsidiary Shoyaku Co., Ltd. was subjected to an on-site investigation by the Japan Fair Trade Commission in regard to suspected violations of the Antimonopoly Law in the submission of a bid to the National Hospital Organization (NHO).

The Company and Shoyaku both accept with all seriousness and sincerity what has occurred and are cooperating fully with the Japan Fair Trade Commission’s investigation. We will do our utmost to regain trust by thoroughly implementing compliance measures aimed at preventing recurrence.

The Corporate Ethics Hotline has been established to supplement legal and regulatory compliance systems. The Group employees and those involved in the Group’s business activities must report through the Corporate Ethics Hotline when they become aware that an act of violation of a law, regulation or the Articles of Incorporation, or any action that would damage the Group brand has been conducted or is about to be conducted at the Company and the Group companies.

Through this internal reporting system, risks are detected at an early stage and corrective measures are promptly taken.

The Pharmaceutical Affairs Supervisory Office, which reports directly to the president, engages in management and oversight of matters concerning pharmaceutical laws and regulations, and of the provision of pharmaceutical information. The office focuses on helping supervising pharmacists working in pharmacies and other locations comply with the Law on Securing Quality, Efficacy and Safety of Products Including Pharmaceuticals and Medical Devices, Guidelines for Prescription Drug Marketing Information Provision, and other regulatory and best-practice provisions. It also works to improve quality by promoting compliance with GDP Guidelines. Working with Group companies, the office helps to strengthen compliance.

In our Corporate Ethics Charter Guidelines, we have established fair, just, and transparent transactions and equal relationships, together with legal and regulatory compliance, as standards of conduct, and we work to prevent corruption and other types of improprieties.

Along with compliance training aimed at instilling in directors, executive officers, counselors , trustees, and employees the importance of compliance, we also regularly conduct training on anti-corruption laws in other countries.

Based on our awareness that a company is a public organ of society, and in accordance with highest ethical standards, Suzuken has a strong commitment to fulfilling its social responsibilities. We are resolutely opposed to anti-social forces and groups that threaten public order and safety.

Our Corporate Ethics Charter and Corporate Ethics Charter Guidelines, which are important standards of conduct, define the proper attitude and specific measures for dealing with improper or illegal demands from anti-social forces and groups. Through education and training via internal communication systems and other channels, we make all directors, executive officers, counselors , trustees, and employees aware of how to deal with these demands.

The Risk Management and Compliance Committee, which builds and manages close relationships with external expert organizations and includes the risk managers of subsidiaries among its members, studies risks associated with the Suzuken Group. This committee shares information about anti-social forces obtained from external specialized organizations and other sources so that everyone can be alert. To prevent any damages in the event that an anti-social element becomes a customer or shareholder and makes improper or unjust demands, we will endeavor to conduct appropriate corporate surveys and promptly collect information about anti-social forces from specialized external organizations and other sources.

Information that is collected, accumulated, transferred, or provided is an asset of extreme importance for business activities. To properly protect information assets and respond to risks, the Group has established its Information Security Policy. We are also systematically establishing information security measures to help ensure the proper operation and management, development, and use of information systems and networks, and are enhancing employee awareness through regular training. The information security organization is composed of the Board of Directors, employees responsible for information security, the Risk Management and Compliance Committee, and other participants. Led by the Compliance Department, it is working to protect information assets against improper use and abuse and striving to strengthen information security, including cyber security, to minimize potential losses.

With information security risks rising with the advance of digitalization, we will raise the security level for the entire Group by revising our Information Security Policy when necessary and strengthening our information security systems, as we construct new business models that respond to digitalization.