ABOUT TAKEDA
ONCOLOGY

LIVING OUR
VALUES
EVERYDAY

The Takeda Global Code of Conduct and Reinforcement of the Global Ethics & Compliance Program

Takeda believes that, in addition to complying with all applicable laws and regulations, it is essential for Takeda employees and executives to conduct business in line with the highest ethical and moral standards. At Takeda, this is expressed through our Values—Takeda-ism (Integrity, Fairness, Honesty, Perseverance)—and our four priorities (Patient, Trust, Reputation, Business).

To set a standard, we established the Takeda Global Code of Conduct, which gives us a framework for achieving the ethical and moral standards we aspire to. It sets out the principles we must follow every day and helps us preserve the integrity that is ingrained in our heritage, and which underpins Takeda-ism and our four priorities. The Global Code of Conduct applies to all Takeda employees and enables all of us to make everyday decisions in line with our Values.

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SUNSHINE
ACT/OPEN
PAYMENTS
PROGRAM

The Physician Payments Sunshine Act ("Sunshine Act"), also known as the Open Payments Program, is a law that requires biopharmaceutical companies and other applicable manufacturers to report transfers of value made to physicians and teaching hospitals to the Centers for Medicare & Medicaid Services (CMS) on an annual basis.

The information reported is made available to the public by way of an online searchable database managed by CMS. The Sunshine Act impacts all physicians who have an active U.S. medical license, regardless of specialty.

The types of activities with transfers of values that must be reported include consulting services, meals, honoraria and research funding and grants. Other interactions where transfers of value also must be reported include informational presentations, speaking engagements and textbooks, which help educate physicians and allow them to stay current on new treatments, studies and emerging safety information.

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CORPORATE
COMPLIANCE

1. Written Standards of Conduct, Policies and Procedures

Takeda believes that, in addition to complying with all applicable laws and regulations, it is essential for Takeda employees and executives to conduct business in line with the highest ethical and moral standards. At Takeda, this is expressed through our Values—Takeda-ism (Integrity, Fairness, Honesty, Perseverance)—and our four priorities (Patient, Trust, Reputation, Business).

To set a standard, we established the Takeda Global Code of Conduct, which gives us a framework for achieving the ethical and moral standards we aspire to. It sets out the principles we must follow every day and helps us preserve the integrity that is ingrained in our heritage, and which underpins Takeda-ism and our four priorities. The Global Code of Conduct applies to all Takeda employees and enables all of us to make everyday decisions in line with our Values. The Code of Conduct is supplemented by more detailed compliance policies and procedures for individual business functions. These policies address risk areas relevant to pharmaceutical manufacturers, including but not limited to, those identified in the OIG Guidance and the PhRMA Code.

DOWNLOAD GLOBAL CODE OF CONDUCT

2. Our Compliance Officer and Compliance Committee

Takeda has a Global Ethics & Compliance Officer who is responsible for overseeing ethics & compliance activities across the Company. We also have a Compliance Committee, comprised of leaders in key areas throughout the company that meets to discuss best practices, monitor compliance activities and coordinate advice-seeking. Concerns or reports of wrongdoing as well as corresponding corrective actions, as applicable, are also discussed with the Compliance Committee.

3. Training

All new hires are required to complete basic orientation training within 90 days of employment on legal and compliance-related topics, processes and policies relevant to their positions and applicable quality guidelines and regulations.

Employees in the sales, marketing, medical affairs and medical organizations are also required to complete training on general science and product-specific information in addition to annual training in health regulatory compliance. Compliance training topics include but are not limited to the Anti-Kickback Statute, False Claims Act, OIG Guidance, PhRMA Code, FDA regulatory standards and ACCME's Standards for Commercial Support.

Training on identified risk areas are also conducted regularly at the sales and marketing organization meetings. This training is tailored specifically to respond to new compliance challenges faced by these organizations, and additional training programs are implemented in response to needs identified through ongoing monitoring and auditing.

4. Communicating Concerns: Hotline, Email and Reporting

Takeda encourages all employees to ask questions, seek guidance on ethical or legal issues and express any concerns regarding business-related conduct. We provide several channels for these types of communications, such as an external telephone hotline for reporting compliance concerns, where anonymity may be preserved at the caller's request. Employees also may address their questions or concerns to their manager, Human Resources, the Ethics & Compliance Department, the Legal Department or the Compliance Officer. Company policy is designed to protect employees from retaliation for raising concerns in good faith.

5. Monitoring and Auditing

Regulated activities are monitored and audited for compliance with applicable laws, regulations, guidelines and Company policies and procedures. The Quality Assurance group, the Ethics & Compliance Department, the Legal Department, the Compliance Officer and the internal audit functions formulate corrective action plans, working with the Human Resources department as necessary, to address concerns that are identified through monitoring and auditing.

6. Disciplinary Guidelines

We conduct regular performance reviews of employees and take compliance into consideration as an important component of performance. Failure to comply with the law, regulations or Compliance policies will subject employees to disciplinary action, up to and including termination of employment. Our company also has processes in place to screen individuals or entities excluded from participation in the federal healthcare programs or debarred by FDA. It is our policy to not employ such excluded individuals or entities.

7. Corrective Action

We strive to address issues that are identified or that are reported to us. Remediation of such problems may include disciplinary action, training, review or development of policies and procedures and/or mechanisms for monitoring or auditing.

California Health & Safety Code §§ 119400-119402

Per the requirements of California Health & Safety Code §§ 119400-119402, our company has established an annual dollar limit of $1500 for certain spending on individual medical or healthcare professionals licensed in California. The value of educational items and meals provided to healthcare professionals in connection with business and educational discussions with those individuals is included in this dollar limit. This dollar limit represents a spending maximum and not an average or goal and we reserve the right to change this limit at any time.

July 1, 2018 California Declaration of Compliance

To the best of its knowledge and based on its good faith understanding of the statutory requirements, Millennium Pharmaceuticals, Inc. (doing business as Takeda Pharmaceutical International Co.) declares that it is in compliance with its Program and the requirements of California Health & Safety Code §§ 119400-119402 in all material respects.

Vermont Prescriber Information

Click the links below to access the Vermont Prescriber Information for the following products:

Reporting

Comments, concerns and complaints regarding our ethics and integrity as displayed in our policies, practices, activities and events or individual conduct can be reported to our Ethics & Compliance HelpLine: 866-469-6566 or website: mpi.alertline.com

SUPPLIER
INFORMATION

Suppliers are critical for helping Takeda Oncology patients achieve better health. Whether you are a raw material supplier, a clinical research laboratory or a supplier of marketing services, your goods and services have an impact every day on the patients relying on Takeda Oncology's products and the Takeda Oncology employees whose passion is dedicated to improving patient health worldwide.

LEARN ABOUT OUR SUPPLIER POLICIES

TAKEDA’S PRICING
PHILOSOPHY

Our approach to pricing medicines reflects our strong commitment to bringing the right treatment options to patients who may benefit from them. When setting prices, we aim to make our medicines accessible to as many patients as possible, while recognizing the value they bring to patients, providers and the overall healthcare system.

VIEW TAKEDA'S POSITION ON GLOBAL PRICING

VIEW TAKEDA'S POSITION ON U.S. PRICING