We are firmly committed to the prevention of corruption and bribery across all areas of the organisation's operation. Our ethos is to operate without bribery or corruption, and to clearly communicate this ethos to all personnel and applicable third parties with whom we interacts to achieve our objectives. We are committed to conducting our operations in a lawful, ethical and professional manner. Moreover, we comply with the provisions of the Sumitomo Dainippon Pharma Group Anti-Corruption Policy and with applicable laws relating to bribery and corruption, including the UK Bribery Act 2010. To this end, we implement measures which aim to reduce the risk of bribery and corruption from occurring, as far as reasonably possible. Such measures include operating a Compliance Committee; completing a Risk Assessment to identify any 'vulnerable' areas and to inform appropriate risk mitigation; developing, implementing and maintaining adequate internal policies, rules and procedures to prevent bribery and corruption; and ensuring that all staff receive training relating to anti-bribery and anti-corruption matters.
Our Compliance Committee monitors the organisation's anti-bribery and anti-corruption provisions (including compliance with the Sumitomo Dainippon Pharma Group Anti-Corruption Policy) on an on-going basis, and reviews provisions on an annual basis, or more frequently if required. We seek advice from external specialists (including legal advisers), as needed. Relevant policy provisions also extend, via written agreements with third parties, to activities undertaken by others acting on our behalf.
We ensure that any suspected case of corruption or bribery is properly investigated and, where appropriate, invoke disciplinary measures and take prompt action to remedy a proven case and prevent any further occurrence. Such action may include termination of employment and / or termination of a contract with a third party, where this is appropriate.