Page 10 - Shionogi flipbook NEW

10
Anti-Bribery
Bribery has no place at Shionogi. We never offer items of value in order to secure an improper business advantage—whether we are working with government of cials, healthcare professionals or any other individ- ual or business. We comply with all anti-bribery laws around the world and understand that these laws also apply to individuals and companies who conduct business on our behalf.
Together, we:
• Do not promise items of value in order to gain an unfair business advantage.
• Never hide or attempt to cover up a payment.
• Monitor third parties carefully, ensuring that their conduct complies with our policies.
• Always record payments and transactions accurately and on time.
TO MAKE IT CLEAR:
Bribery is a crime, and the laws don’t just apply to our actions—they also apply to anyone who is conduct- ing business on Shionogi’s behalf, including third-party vendors, law rms, lobbyists, and consultants.
BE MINDFUL:
Government Of cials and Employees
Bribery of foreign government of cials and employees is strictly prohibited and is a criminal violation under U.S. laws, including the Foreign Corrupt Practices Act (FCPA). Remember that Health Care Professionals (HCPs) and allied healthcare professionals who are employed by a government agency, university, or hospital are considered government employees.
When conducting business internationally, keep in mind that other countries have similar laws to the FCPA.
Insider Trading
We must exercise care whenever we have access to information about Shionogi that is not available to the public. We comply with all insider-trading laws and never trade or provide tips to trade stock of any company, including Shionogi and our business partners, on the basis of material inside information.
Trade Control Issues
Foreign trade control laws regulate how we import and export
our products, services, information, and technology. Governments around the world restrict or prohibit business with certain persons, companies, and countries based on national security and policy inter- ests. At Shionogi, we must understand how these laws apply to our business and comply with them at all times.