Policy and Concept
The basis for the Sumitomo Corporation Group’s compliance is to win the trust of society by practicing the Activity Guideline that states: “complying with laws, rules and ethics in conducting the company’s affairs”.
Accordingly, SPE follows Sumitomo Corporation Group’s principles of “Giving First Priority to Compliance,” which means that compliance takes priority over all activities of the Group and that SPE must never violate compliance as a result of giving priority to the pursuit of profit, and “Reporting Compliance Issues Immediately” or “Immediate Report,” which means, in the event of a compliance problem, employees must report the situation without delay to their line manager, including the management level personnel, or to the relevant department of the Corporate Group.
Summit Pharmaceuticals Europe S.r.l. has its own Compliance Manual and conducts regular reviews to ensure its relevance and effectiveness that outlines the internal procedures and guidelines that all employees must follow to ensure adherence to laws, rules, and ethical standards. The manual emphasizes the importance of compliance in conducting the company’s affairs and sets out specific rules and regulations for various aspects of the business.
Speak-up System
The Whistleblowing Procedure at Summit Pharmaceuticals Europe S.r.l. is a crucial component of the company’s commitment to maintaining high ethical standards and transparency. This procedure allows employees to report any unethical or illegal activities confidentially, ensuring that the company can address and rectify issues promptly. By providing a secure and anonymous channel for reporting, the Whistleblowing Procedure helps to foster a culture of accountability and integrity within the organization. For more detailed information on the Whistleblowing Procedure, please refer to the relevant section on our website.
Appropriate responses to compliance violations and preventive measures
In case of a compliance problem, SPE promptly takes steps to establish the facts and clarify the causes of the incident. Based on the outcome, SPE takes corrective measures, disciplinary action, and recurrence preventive measures.
All employees are engaged to report any suspected compliance issues, for the benefit of the Company.
Employees may report the compliance issue to Internal Control and Compliance Committee.
Initiatives
Continuous education program initiatives
The Compliance Manual, which explains particularly important issues, such as compliance of competition law, security trade control and anti-bribery/corruption, is communicated to all employees of Sumitomo Corporation Group.
Both Sumitomo Corporation and SPE, implement various education programs for all employees and provide e-learning programs about the theme according to the current situation for all employees, in order to promote and deepen understanding of compliance.
Anti-bribery/corruption initiatives
Based on the principle of “Giving First Priority to Compliance”, Sumitomo Group and SPE implement strict measures to prevent all forms of corruption. Specifically, SPE has established Rule for Prevention of Bribery: ban to obtain or retain a financial or other Advantage for itself or Company, such as entertainment, gifts, invitations.
No member of SPE may:
- Bribe, directly or indirectly;
- Accept bribes
- Allow an intermediary to carry out any of the above.
All employees must act honestly and with integrity at all times.
In addition, taking into account revisions to the laws and regulations of each country, advice from various external specialists and changes in other social circumstances and other factors, Sumitomo Corporation and SPE continuously reviews their internal rules, guidelines, and manuals. SPE established and implemented a system appropriate for the bribery risk level of the Company, and offers ongoing employee education, such as internal seminars, and works constantly to prevent bribery and corruption.
Measures for ensuring compliance with laws concerning antitrust and fair competition
SPE carefully checks compliance with laws concerning antitrust/fair competition as stated in Compliance Manual. Additionally, SPE endeavours to ensure, by measures such as regular internal training, that antitrust/competition laws are observed.
Security trade control and logistics compliance
SPE implemented various measures, on a continuing basis, to ensure that the Company complies with treaties and international frameworks related to international trade and with trade security control to prevent weapons or products and technology for civilian use that could be converted to military use from falling into the hands of states or non-state organization (terrorists) which may develop weapons of mass destruction. SPE also provides training sessions, instructions and monitoring as needed to ensure compliance.
Prevention of insider trading
To prevent unfair business practice, SPE policy states that employees will not take any action that would cast doubt on the honesty and integrity of the Company. Putting a value on trust is also one of the business principles of SPE.
“Unfair Business Practices” include:
- Obtaining confidential information or trade secrets of third parties through unlawful or
improper means - Using trademarks or trade names similar to, or easily confused with, well established marks
of third parties - Putting or displaying false or misleading information on products
- Circulating false or defamatory information relating to competitors
To ensure compliance SPE also provide, on a regular basis, internal training courses to raise awareness.
The Sumitomo Corporation Group Tax Principles
According to the principles, the Group and SPE adhere to the tax and related laws and regulations of each country, thus not conducting any transaction whose purpose is solely or mainly for tax avoidance or tax mitigation, and endeavour to enhance tax compliance.