List of Guidelines and Policies

Tsumura and group companies strive to be a value-creation company. To contribute to the health of the general public through KAMPO, we have formulated a quality policy consisting of the following principles.

• Providing a stable supply of high-quality, reliable products.
• Ensuring data reliability to guarantee the quality, efficacy, and safety of our pharmaceuticals.
• Complying with laws and regulations related to pharmaceuticals.
• Listening to the voices of our customers and striving to continually improve the quality of our products.
• Realizing stable procurement of safe crude drugs.
• Securing the reliability of research and provide research results appropriately.
• Offering appropriate training to all our executives and employees, and cultivating human resources distinguished by a high degree of awareness.
• Adequately allocating our management resources to help achieve these principles.

In order to gain public understanding of our collaborations with patient organizations, Tsumura endeavors to improve the transparency and credibility of the relationship between its corporate activities and patient organizations.

The mission of TSUMURA & CO. (“Tsumura”) is to ensure continuous stable supply of high-quality Kampo formulations and crude drug formulations as well as crude drugs and other products, popularize them, and establish and expand markets for such products by enhancing their functions and performance, with the objective of contributing to Japan’s healthcare service and people’s health while promoting patient involvement in medical research. To fulfill this mission, Tsumura needs to understand and address the needs and concerns of patients and their families for every possible area of activities related to pharmaceuticals and patients, including promoting the proper use and safety measures of pharmaceuticals.
To this end, we have a growing number of opportunities to collaborate with patient organizations that represent the voices of patients and their families. Meanwhile, the government sector and healthcare industry have begun listening to voices of patients more attentively, and many more patient organizations are being invited to send representatives to participate in committees and study groups hosted by the administrative authorities.
As patient organizations are increasing their influence and making their voices heard through these trends, it is becoming more important for pharmaceutical companies to ensure transparency in their collaborations with patient organizations in order to gain public understanding about the relevant activities.
Tsumura commits to building trustful relationships with patient organizations to promote collaboration in every possible area of our activities by holding high ethical standards, respecting the independence of the partner organizations, and ensuring mutual understanding of the purpose and content of collaboration activities.

TSUMURA & CO.

Tsumura is committed to maintaining and improving the transparency of its business activities and relationships with medical institutions/medical service providers and to enhancing its credibility when collaborating with them.

Tsumura has established the Tsumura Transparency Guidelines to ensure the transparency of its business activities and relationships with medical institutions and other medical service providers. Under these Guidelines, Tsumura will disclose to the public information on its business activities involving medical institutions and other medical service providers.
Needless to say, Tsumura must collaborate with medical institutions and other medical service providers at every stage of its business, from research to manufacturing and marketing of pharmaceuticals and other products.
It is therefore crucial to secure the transparency of our relationships with these partners and gain public understanding of how collaboration between the pharmaceutical industry and medical institutions/medical service providers contributes to the development of the life sciences, including medical and pharmaceutical sciences, and that these collaborations are conducted according to high ethical standards.
The Ministry of Education, Culture, Sports, Science and Technology, the Ministry of Health, Labour and Welfare, the Japanese Association of Medical Sciences, and other organizations in Japan as well as overseas, have already started working on conflict of interest management, and Tsumura has decided to participate in these efforts.
In line with the Transparency Guidelines, Tsumura will strive for greater transparency in its business activities.
We would appreciate your understanding and cooperation in the formulation and implementation of these Guidelines.

Tsumura & Co.

The Tsumura Group will procure safe, reliable and high-quality crude drug materials and other materials in a stable manner based on its Corporate Value, "The Best of Nature and Science." For such procurement, we will conduct fair and equitable transactions while giving due consideration to our social responsibility regarding human rights, labor standards and others. In our procurement activities, we will also implement measures for environmental protection and sustainability in cooperation with other companies in the supply chain, thereby creating value for society as a whole and contributing to the creation of a sustainable society. To this end, we will follow the procurement policy as described below, for which we ask for the understanding and support of all those engaged in our supply chain.

1. Compliance with Laws and International Norms of Behavior
   We will comply with both domestic and overseas laws and regulations, have a high sense of ethics and respect international norms of behavior.
2. Fair and Equitable Transactions and Procurement
   We will select the best suppliers in a fair manner and engage in fair transactions with them.
3. Consideration of Human Rights, Labor Issues, and Occupational Health and Safety
   We observe the Tsumura Human Rights Policy and address the following issues:
   • （1）Eliminate discrimination and harassment on the basis of race, nationality, ethnicity, gender, age, religion, thoughts and beliefs, sexual orientation and identity, academic background, mental and physical disabilities, diseases, and other factors, and never tolerate any form of harassment
   • （2）Prohibit child labor and forced labor
   • （3）Respect the right to freedom of association and collective bargaining
   • （4）Reduce overtime hours and pay above minimum wage standards
   • （5）Develop a healthy and safe work environment
   • （6）In countries and regions facing the violation of above-described basic human rights on a routine basis, pursue internationally accepted methods for respecting basic human rights
4. Assurance of Quality and Safety
   Based on the TSUMURA Quality Policy, we will further enhance our quality assurance system and work to procure items that provide high quality, efficacy and safety in a stable manner, which will help to ensure the quality and safety of our own products and services. To this end, we will obtain necessary information as required.
5. Consideration of the Global Environment
   In order to contribute to the creation of a sustainable society, we address the following issues to conserve the global environment based on the Tsumura Basic Environmental Philosophy and Policy.
   • （1）Reduce greenhouse gas emissions
   • （2）Use energy and water resources efficiently
   • （3）Prevent water and air pollution
   • （4）Reduce and reuse waste
   • （5）Reduce plastic usage
   • （6）Conserve biodiversity
6. Information Security
   Based on the TSUMURA Quality Policy, we will further enhance our quality assurance system and work to procure items that provide high quality, efficacy and safety in a stable manner, which will help to ensure the quality and safety of our own products and services. To this end, we will obtain necessary information as required.
7. Contribution to Society and Local Communities
   Both in and outside Japan, we will respect the social customs and cultures of each region in which we operate, promote business activities based on mutual trust, and engage in activities to contribute to the development of a sustainable society.

1. Basic Policy
   The Tsumura Group, as a corporate group committed to its Purpose of “Lively Living for Everyone,” recognizes ensuring the health and safety of all people working for the Group and its supply chains as a cornerstone of corporate management.
   Based on this recognition, we endeavor to improve occupational health and safety and create a healthy and safe workplace environment.
2. Action Guidelines
   We are committed to ensuring occupational health and safety following the action guidelines as described below.
   • Compliance
     We will comply with laws and regulations related to occupational health and safety that are applicable in each country and region, as well as the relevant voluntary rules established by each Group company.
   • Education and awareness-raising
     We will conduct education and awareness-raising activities related to health and safety to provide all employees with opportunities to have a better understanding and review their own behavior in this regard.
   • Risk management
     We will develop hazard and risk awareness, and conduct activities to identify, assess and reduce risks on an ongoing manner.
   • Communication
     We will share with employees information related to health and safety in a timely and appropriate manner, and respect their opinions and suggestions by utilizing them to make improvements.
   • Health promotion
     We will help employees promote their health management and perform health practices to maintain mental and physical health.
   • Collaboration and cooperation
     We will enhance collaborations with organizations inside and outside of the Group, including partners, to promote cooperation for ensuring the health and safety of all people engaged in its business activities.
   • Continuous improvement
     We will review our health and safety activities on a regular basis, identify areas for improvement, and carry out improvement plans, aiming to constantly achieve a better workplace environment.

The Company shall endeavor to build a trust relationship with its various stakeholders through continuous, appropriate, proactive information disclosure.

Information Disclosure Standards

1. Timely Disclosure of Important Information
   We disclose information in conformance with relevant laws and regulations, such as the Financial Instruments and Exchange Act, as well as the Timely Disclosure Rules established by the Tokyo Stock Exchange, where Tsumura's stock is listed.
2. Voluntary Disclosure
   We also proactively disclose information to which the aforementioned Timely Disclosure Rules do not apply if we judge the contents of that information to be useful for making investment decisions, taking into consideration timeliness and fairness.

Tsumura discloses information via the Timely Disclosure Network (TDnet). Disclosed information is promptly posted to Tsumura's website.

The information disclosed by Tsumura includes forecasts based on the future outlook and plans of the company accordance with Tsumura's judgment at the time of disclosure. Risks and uncertainties are inherent factors in these forecasts, so actual business performance and results may differ.

In order to prevent the leaking of financial results and ensure fairness in our information disclosures, Tsumura has a "quiet period" that lasts for about one month prior to the reporting announcement date of each quarter, and we refrain from responding to questions and media inquiries related to unpublished results (financial information and company business activities that include research and development).

Tsumura, a corporate group committed to pursuing "The Best of Nature and Science," conducts business activities in harmony with nature to conserve the global environment and promote healthy living.

Tsumura Basic Environmental Policy

1. Environmental conservation efforts
   Recognizing that protecting our irreplaceable Earth is a critical issue, we conduct our business activities in harmony with nature.
2. Establish and improve the environmental management system
   We have established an environmental management system and are working to continuously improve it. Under this system, we set environmental goals, conduct environmental management activities, evaluate the results, and conduct voluntary audits.
3. Reducing Environmental Impacts and Promoting Resources Recycling
   At each stage of our business activities, we will actively conduct measures to contribute to reducing environmental impacts by diminishing greenhouse gas emissions and improving efficiency to achieve sustainable energy use while minimizing pollution. Also, we will facilitate the efficient use of resources, especially by reducing water usage, and waste reduction and reuse with the aim of helping to create a recycling-oriented society.
4. Consideration for biodiversity
   We strive to conserve biodiversity so that we and future generations can continue to enjoy the blessings of nature.
5. Compliance with environmental laws and regulations
   We comply with environmental laws, regulations, agreements, and voluntary industry standards and work to strengthen our environmental conservation activities.
6. Environmental education and awareness-raising activities
   We actively conduct environmental education and awareness-raising activities to ensure that every person in the Tsumura Group practices environmental conservation responsibly and continuously, pursuant to our environmental philosophy and policy.
7. Information disclosure
   We disclose information on our environmental conservation efforts to the greatest extent possible.
8. Participate in social contribution activities
   We work to conserve the environment and participate in social contribution activities through our Kampo and herbal medicine businesses.

1. Basic Principle
   The Tsumura Group will respect human rights in support of the following international norms concerning human rights (hereinafter, "the international norms"):
   • International Bill of Human Rights (Universal Declaration of Human Rights and International Covenants on Human Rights)
   • ILO Declaration on Fundamental Principles and Rights at Work established by the International Labour Organization (ILO)
   • Ethical Principles for Medical Research Involving Human Subjects (Declaration of Helsinki)
2. Scope of Application
   This policy will be applied to all directors, officers and employees of the Tsumura Group. We also ask for the understanding and support of this policy to the Tsumura Group's business partners, suppliers and others (hereinafter, "the related parties") and will work with them to promote respect for human rights.
3. Responsibility to Respect Human Rights and Relief Measures
   The Tsumura Group, based on the recognition that its business activities could have direct/indirect impacts on human rights, will promise never to infringe upon human rights and will also strive not to be complicit in the violation of human rights by related parties. In the event that it is suspected that our own business activities have had a negative impact on human rights, that we were complicit in having a negative impact on human rights, or that any of the related parties had a negative impact on human rights in relation to any of the businesses, products and services of the Tsumura Group, we will implement relief measures in line with international norms.
4. Education
   The Tsumura Group will continue to provide its directors, officers and employees with appropriate education to raise their individual awareness of the importance of respecting human rights, and build a corporate culture that encourages them to take actions with respect for human rights and prevent human rights violations.
5. Due Diligence for Human Rights
   The Tsumura Group will identify the negative impacts that it could have on human rights through its own business activities and will build a due diligence system for human rights in order to prevent or mitigate such impacts and implement it on a continual basis.
6. Dialogue and Consultations
   The Tsumura Group will make use of the knowledge provided by external experts in implementing measures in line with this policy. We will also foster dialogue and consultations with related stakeholders regarding the potential and actual impacts that could be caused to the human rights of people engaging in the Group's business activities.
7. Compliance with Applicable Laws and Regulations
   The Tsumura Group will comply with the laws and regulations enforced in each country and region where it operates. We will also work to implement measures to respect international norms to the maximum extent if there is a contradiction or inconsistency between the norms and the laws, regulations, behavioral norms, culture and customs prevailing in each country and region.
8. Information Disclosure
   The Tsumura Group will appropriately disclose information on its measures to respect human rights on its website and via other media.

1. Basic policy
   In all countries/territories where the Tsumura Group does business, we will comply with tax-related laws and properly pay taxes, thereby contributing to the finances and economies of each country/territory and the sustainable development of society. In accordance with the Tsumura Action Charter, which constitutes the guiding principles for our business activities, the Group will comply with this Tsumura Tax Policy and fulfill its social responsibilities with the highest ethical standards. We will endeavor to pay taxes appropriately while ensuring tax compliance and tax transparency.
2. Tax governance
   Our Chief Financial Officer (CFO) is responsible for the tax governance of the Group.
   The CFO is aware of the tax issues faced by each Group company and has put a system in place to handle them appropriately. Furthermore, the parent company's tax team assesses tax risks for the group as a whole and considers and directs the Group's response. Similarly, the tax team in each country manages tax risks of the country concerned, and reports any significant tax risks to the parent company's tax team for consideration and appropriate handling. As such, a system has been established that enables the parent company's tax team and the tax team in each country to respond appropriately to tax issues.
3. Tax compliance
   We recognize that being driven by motives to avoid taxes or engage in aggressive tax planning may compromise tax compliance. We place the highest priority on compliance with the tax-related laws of each country, and all officers and employees of the Group act in accordance with this Tsumura Tax Policy to ensure thorough compliance and pay taxes in a proper manner.
4. Tax risk management
   Tax risk is a risk that can lead to financial loss or loss of credibility, and encompasses compliance risk as well as risks associated with uncertain tax positions, changes in laws and regulations, and the perception of engaging in aggressive tax practices. The Group strives to identify tax risks in a timely and appropriate manner, and when significant tax risks are identified, the Group works to reduce them through consultation with tax authorities in each country, while also obtaining advice from outside experts.
5. Transfer pricing
   To ensure that we pay taxes properly in each country, we determine the prices applied in transactions among Group companies based on the arm's length principle, while taking into account the functions and risks of the Group companies. We endeavor to prevent double taxation through the appropriate allocation of income, but in the unlikely event that double taxation were to occur, we would strive to eliminate it through the application of international tax treaties or mutual consultations.
   We also prepare transfer pricing documents in accordance with the tax-related laws of each country and submit them to the tax authorities of each country as necessary.
6. Proper payment of taxes, preferential tax treatment, tax havens
   The Group always strives to pay appropriate taxes. We do not engage in tax planning that does not reflect actual business activities, as doing so could be construed as tax avoidance. We also do not make use tax-free or low-tax jurisdictions (tax havens) for the purpose of avoiding taxes.
7. Relationship with tax authorities
   We will file tax returns and pay taxes appropriately in accordance with the tax-related laws of each country. We strive to build good engagement with tax authorities by responding sincerely to requests for information from tax authorities and taking measures to prevent recurrence of matters for which we have received guidance.

Upholding "Lively Living for Everyone" as our Corporate Purpose, or ultimate business aspiration, and based on our Corporate Value of "The Best of Nature and Science," the Tsumura Group undertakes corporate activities in the Kampo medicine and crude drug business and related life/health industries.

We strive to maximize the value of the intellectual property our Group has acquired by investing in our businesses, and to provide patients, customers and the broader society with greater value by utilizing it.

To achieve these ends and earn the trust of society, our Group will endeavor to take proactive and strategic steps to create and acquire intellectual property rights, to use our intellectual property effectively and manage it strictly, and to respect the intellectual property of other companies.

April 2023

At Tsumura, we adequately protect the personal information of our customers, business partners, medical service providers, shareholders, employees, and other related persons used in the course of our business in compliance with the Act on the Protection of Personal Information and other applicable laws and regulations. To this end, we establish the following policy and maintain the necessary internal systems for ensuring the proper handling of personal information.

1. Responsibilities as a company that provides products related to human life
   As a company that provides products related to human life, we handle personal information containing details of people's lives and health in an appropriate manner.
2. Secure management of personal information
   To prevent the loss, destruction, falsification, or unauthorized disclosure of personal information, we take appropriate information security measures, including measures against unauthorized access and malware.
3. Collection of personal information
   We collect personal information by lawful and fair means and do not use improper methods.
4. Use of personal information
   When collecting personal information, we clarify its intended use and use it within the scope of such intended use.
   We never provide personal data to third parties without obtaining the prior consent of the individual, except as permitted by law.
   If we outsource the handling of personal data to a third-party contractor, we exercise the necessary and appropriate supervision over the contractor to ensure the safe management of the personal data.
5. Response to requests for disclosure and complaints about personal data
   We respond appropriately to requests from individuals to provide notice of the intended use, disclosure or correction, or suspension of use of personal data pertaining to such individual, and to complaints about any personal data handled by us.
6. Commitment to continuous improvement
   To implement this Policy, we provide education and training to employees and officers of Tsumura (including directors, employees, part-time workers, and others) and related parties, audit the implementation status, and conduct continuous improvement activities.

Laboratory testing using animal models is necessary to assure the efficacy and safety of pharmaceutical products. At Tsumura, we have established our own Rules on Laboratory Animal Testing based on the Act on Welfare and Management of Animals, the basic guidelines of the Ministry of Health, Labour and Welfare, and the guidelines published by the Science Council of Japan. All laboratory animal tests at Tsumura are conducted in accordance with these Rules after the Animal Testing Committee has examined their scientific rationale and the animal welfare considerations (following the 3Rs: Replacement [availability of alternative methods], Reduction [minimization of the number of animals tested], and Refinement [consideration of pain suffered by subject animals]), and the head of the laboratory has approved the test.
All staff engaging in animal testing receive ongoing education focusing on animal welfare and ethics and conduct an annual self-review on the status of animal testing and lab operation.
In May 2014, for objective evaluation and confirmation that animal tests are being conducted properly, we underwent an on-site inspection by the Center for Accreditation of Laboratory Animal Care and Use of the Japan Health Sciences Foundation, and our lab was accredited and certified to be in compliance with the basic guidelines of the Ministry of Health, Labour and Welfare.
We also hold a memorial service at the Cenotaph for Laboratory Animals every year to encourage each person engaging in animal testing to express their gratitude for the contribution made by the animals and lament their loss.

The purpose of this Policy is to prevent the Tsumura Group and its employees and officers from engaging in or being involved in the act of corruption by requiring them to comply with the anti-corruption laws and regulations applicable in the countries where they conduct business while observing its Sustainability Charter.

1. Compliance with applicable laws and regulations
   The Tsumura Group will comply with the laws and regulations of the countries and regions where it conducts business activities, guidelines of related industries, and the Tsumura Code of Practice, which has been formulated based on such guidelines.
2. Prohibited acts
   • （1）Bribery
     The Tsumura Group will never provide, offer, or undertake to provide, directly or indirectly, monetary or non-monetary benefits to government officials or those in similar positions for the purpose of obtaining an unfair advantage. Also, we will never provide, offer, ask for, or receive monetary or non-monetary benefits to or from our suppliers or customers for the purpose of obtaining an unfair advantage.
   • （2）Unfair profit-sharing
     The Tsumura Group will never engage in acts constituting unfair profit-sharing, such as providing goods, money or other articles, directly or indirectly, to its stakeholders, including healthcare professionals, that may inappropriately influence their decision-making.
   • （3）Facilitation payment
     The Tsumura Group will never make facilitation payments (payment of small amounts to government officials to speed up an administrative service process).
3. Management of payment records
   The Tsumura Group will require its employees and officers to properly store vouchers for payments made to third parties during the course of business as evidence for such transactions performed, make relevant entries in the accounting book accurately and without omission, and ensure that the above processes are performed without fail.
4. Actions for violations, etc.
   If any one of its employees or officers violates this Policy, the Tsumura Group will take strict action according to internal rules of the Group company with which the violator is affiliated.
5. Education
   In order to ensure adequate understanding of and compliance with this Policy, the Tsumura Group will regularly provide education and training to its employees and officers to raise their awareness of a wide range of compliance issues, including the prevention of bribery and corruption.