Chapter1　Purpose

The purpose of this Global Policy is to ensure compliance with applicable laws and to maintain fair and transparent relationships with society with respect to the prevention of bribery, corruption, and fraud, based on the Compliance Global Policy.

Chapter2　Definition of Terminologies

Article1The terms used in this Global Policy are defined below.

1. “All Policies” mean Global Policies and other Policies (including rules, detailed rules, and other items equivalent to Individual Entity Policies).
2. “Applicable Laws and Regulations” mean all laws, cabinet orders, ministerial ordinances, municipal ordinances, rules, guidelines, policies, notifications, and other public norms related to the business activities of the ONO Group.
3. “Bribery” means the act of promising, offering, giving, or receiving Monetary or Other Benefits to or from Public Officials or private individuals, for the purpose of improperly influencing another person’s judgment or actions in order to obtain improper business advantages in connection with domestic or international commercial transactions.
4. “Corporate Officer in charge of Compliance” means an individual appointed within OPHQ who oversees the proper establishment and operation of the Compliance Program across the entire ONO Group.
5. “Corruption” means any form of conduct, whether involving Public Officials or private individuals, where a person improperly uses their position, power, or authority to unlawfully or wrongfully provide benefits to themselves, their organization, or any other party. This includes Bribery and some types of Fraud.
6. “Employees” mean directors, officers, regular employees, contract employees, and other employees of the ONO Group, including temporary staff and fixed-term employees.
7. “Facilitation Payment” means a payment made to avoid unreasonable, discriminatory, or disadvantageous treatment, typically a small payment to a Public Official intended to expedite administrative processes such as licensing or customs clearance.
8. “Fraud” means acts involving falsification, concealment, or breach of trust, as well as violations of industry codes or internal policies. Examples include, but are not limited to, embezzlement, bid-rigging or cartel arrangements, false advertising, and concealment of legal violations.
9. “Global Policy(ies)” mean a fundamental policy or policies formulated by OPHQ which embody ONO Group's principles.
10. “GxP-SOPs” mean written procedures established by each entity to standardize each process of research, development, manufacturing, marketing, distribution and others for pharmaceutical products in accordance with the standards, including, but not limited to GCP, GMP, GVP, required by the laws, regulations, and ministerial ordinances applicable to the pharmaceutical business in each country. GxP-SOPs are managed by each relevant function.
11. “Individual Entity Policy” means basic regulatory requirements, authorities, responsibilities, procedures, and methods of operation, consistent with the principles of the Global Policy, that are established and applied by each entity.
12. “Manual(s)” mean a procedural document or documents other than GxP-SOPs, which describe specific procedures, activities, and implementation guidelines for departments and entities involved in relevant operations when Employees perform their duties.
13. “Monetary or Other Benefits” means anything of value to another person or entity. This includes money and tangible assets, financial advantages, free use of houses or buildings, entertainment or hospitality, provision of collateral, and other property-related benefits, as well as any and all tangible or intangible benefits such as positions or status in the course of employment.
14. “ONO Group” means Ono Pharmaceutical Co., Ltd. and each of its Subsidiaries.
15. “OPHQ” means a global headquarters function of Ono Pharmaceutical Co., Ltd.
16. “Public Official(s)” means any person engaged in public duties for a national or local government, any individual exclusively employed by a government-related agency, and/or quasi any government or public institution, any person performing duties for a public enterprise, or any individual vested with authority delegated by a government or similar entity.
17. “Subsidiary(ies)” means an entity or entities in which Ono Pharmaceutical Co., Ltd. directly or indirectly holds a majority of voting rights (more than 50%) or otherwise exercises equivalent substantial control. Indirect ownership includes all entities in a continuous chain of control, such as subsidiaries and sub-subsidiaries.
18. “Third Party(ies)” means any and all entities or individuals that conduct business with the ONO Group (excluding ONO Group entities), regardless of whether a contractual relationship exists or whether the counterparty is a legal entity or an individual.

Chapter3　Scope

This Global Policy applies to each ONO Group entity and their Employees. In the event of any discrepancy between this Global Policy and Individual Entity Policy or Manual, the more restrictive provision shall prevail.

Chapter4　Basic Principle

Article1Implementation of Anti-Bribery, Anti-Corruption, and Anti-Fraud Measures

1. Each ONO Group entity shall, in accordance with the Compliance Program stipulated in the Compliance Global Policy, promote the establishment, operation, and continuous improvement of organizational structures and mechanisms designed to prevent Bribery, Corruption, and Fraud.
2. Employees shall conduct business activities in compliance with this Global Policy and the Individual Entity Policy for anti-Bribery, anti-Corruption, and anti-Fraud measures.

Article2Prohibition of Bribery, Corruption, and Fraud

1. Employees shall comply with all applicable laws related to anti-Bribery, anti-Corruption, and anti-Fraud; cross-border legislation such as the U.S. Foreign Corrupt Practices Act (FCPA) and the U.K. Bribery Act (UKBA); Applicable Laws and Regulations to each ONO Group entity; and the Individual Entity Policies and Manual established in accordance with these laws and codes. Employees shall not, regardless of country or region, engage in, attempt, or carry out any form of Corruption or Fraud, including the prohibition of providing bribes set forth in paragraph 2 and the prohibition of accepting bribes set forth in Paragraph 3.
2. Employees shall not, directly or indirectly, offer, promise, or provide Monetary or Other Benefits to any counterparty, including Public Officials, regardless of country or region, for the purpose of unlawfully obtaining business advantages or securing business opportunities or conveniences for the company, or with the intent to induce the counterparty to perform improper acts in the course of their duties. Employees shall not make such offers or promises of Monetary or Other Benefits as consideration for improper acts, nor provide Monetary or Other Benefits with the knowledge that the counterparty’s receipt of such benefits constitutes an improper act.
3. Employees shall not, directly or indirectly, solicit, agree to receive, or accept Monetary or Other Benefits from any counterparty, regardless of country or region, where such Monetary or Other Benefits are intended to induce Employees to perform improper acts in the course of their duties, or as consideration for such acts, or with the knowledge that the receipt of such Monetary or Other Benefits by Employees constitute an improper act.

Article3Entertainment, Gifts, and Travel Expenses

In principle, employees shall not provide or accept any entertainment or gifts. However, the provision or acceptance of entertainment, gifts, or travel expenses may be conducted as an exception, if such actions are allowed in the relevant jurisdiction and within the scope defined by Individual Entity Policies. Even in such exceptional cases, these actions must comply with Applicable Laws and Regulations, as well as All Policies, and must not be excessive or extravagant by generally accepted social standards.

Article4Facilitation Payments

1. Employees shall refuse any request for a Facilitation Payment. However, where there is no other realistic means of avoidance due to extortion or similar circumstances involving a risk of unlawful harm to life, body, or personal property, a minimal payment that is unavoidably made may be permitted. In such case, such payment shall not constitute a violation of this Global Policy; however, Employees shall promptly report the payment to their supervisor and the Compliance Supervisory Function of each ONO Group entity.
2. Employees shall promptly report any request for a Facilitation Payment to their supervisor and the Compliance Supervisory Department of each ONO Group entity.

Article5Engagement, Oversight, and other Management Activities of Third Parties

1. Each ONO Group entity shall ensure proper oversight and management of Third Parties to prevent any violations of the prohibitions set forth in Article 2 of Chapter 4. Each ONO Group entity shall include anti-Bribery and anti-Corruption clauses in contracts, conduct risk-based due diligence when engaging a Third Party and upon contract renewal, and implement other necessary measures to prevent Bribery, Corruption, and Fraud in transactions with Third Parties. The responsible persons for conducting due diligence and the specific methods thereof shall be defined in each entity’s Individual Entity Policy.
2. Employees shall include anti-Bribery and anti-Corruption clauses in contracts when engaging Third Parties to ensure that such parties do not engage in Bribery, Corruption, or Fraud. However, subject to meeting certain conditions, Employees may omit such clauses with the prior approval of the Legal function of each ONO Group entity. Employees shall also communicate ONO Group’s standards for preventing Bribery, Corruption, and Fraud to Third Parties and request their compliance.
3. Each ONO Group entity shall conduct anti-Bribery, anti-Corruption, and anti-Fraud due diligence when considering acquisitions, investments, or partnerships with other companies.

Article6Accurate Accounting and Record Management

1. Each ONO Group entity shall classify all transactions related to company assets under appropriate accounting categories and record and organize them in a clear and orderly manner so as to accurately and completely reflect the true nature of such transactions. Each ONO Group entity shall not make any false, inaccurate, or misleading records, including, without limitation, the concealment of purpose, fictitious transactions, or the overstatement or understatement of amounts.
2. Each ONO Group entity shall establish proper internal controls designed to prevent and detect Bribery, Corruption, and Fraud.
3. Employees of the ONO Group who are responsible for administrative, accounting, or payment-related functions at each organization shall exercise due care when processing payments and recording transactions to avoid overlooking any signs of Bribery, Corruption, or Fraud.

Article7Awareness and Training

Each ONO Group entity shall provide awareness programs and education and training to its Employees on the prevention of Bribery, Corruption, and Fraud. Such awareness and training shall be implemented in accordance with the education and training plans established by each ONO Group entity.

Article8Disciplinary Action

Each ONO Group entity shall take disciplinary action in accordance with its employment regulations when Employees violate this Global Policy.

Article9Reporting or Whistleblowing

1. Employees shall promptly report any violation of this Global Policy, or any suspicion of such violation, to one of the following: Their immediate supervisor Senior management of each ONO Group entity or OPHQ The compliance whistleblowing or consultation channel of each ONO Group entity
2. Employees shall maintain strict confidentiality regarding all reports and investigations. Employees shall not disclose the reporter’s identity, the content of the report, or any privacy-related information to anyone other than those who are authorized and required to know such information for the purpose of investigating Bribery, Corruption, or Fraud.

Article10Mitigation of Bribery, Corruption, and Fraud Risks

Each ONO Group entity shall regularly conduct risk assessments to identify and address potential risks related to Bribery, Corruption, and Fraud at an early stage and shall implement measures to mitigate such risks.

Article11Investigation of Anti-Bribery, Anti-Corruption, and Fraud Measures

The Corporate Officer in charge of Compliance shall periodically, or as necessary, conduct investigations into the implementation status of anti-Bribery, anti-Corruption, and anti-Fraud measures within the ONO Group. The Corporate Officer in charge of Compliance at OPHQ may also request the head of OPHQ Internal Audit Department to conduct internal audits covering the ONO Group.

Article12Compliance Requirements

1. Each ONO Group entity shall, in consultation with the OPHQ Responsible Department, establish its Individual Entity Policy or Manual as necessary, which is consistent with this Global Policy and is in compliance with the Applicable Laws and Regulations.
2. Each ONO Group entity may, in consultation with the OPHQ Responsible Department, delegate the establishment of such Individual Entity Policy or Manual to another ONO Group entity, or apply a common Individual Entity Policy or Manual together with other ONO Group entities.

Supplementary Provisions

1. This Global Policy was approved by the Management Committee on March 29, 2017, and shall take effect on April 1, 2017.
2. When revising or abolishing this Global Policy, the proposal shall undergo deliberation and approval by the Board of Directors, followed by submission for Ringi approval.

Revision on July 1st, 2026