Common Questions and Answers

About EthicsPoint® NAVEX Global
Reporting – General
Reporting Security & Confidentiality
Reporting Additional Information
Reporting - FAQ For Astellas Employees

ABOUT EthicsPoint® NAVEX Global

What is EthicsPoint®?

EthicsPoint®, a NAVEX Global product, is a comprehensive and confidential reporting tool allowing management and those raising concerns to work together to address potential compliance concerns (such as fraud, abuse or other misconduct) to cultivate an ethical and positive business environment for Astellas products and services.

Why do we have EthicsPoint to report concerns?

An effective reporting system supports our goal of fostering a culture of integrity and ethical decision-making for both employees and business partners. EthicsPoint is a key part of that reporting system. Promoting and supporting this culture helps our employees by promoting a positive work environment and helps our business partners by reinforcing our expectation that they work on our behalf in an ethical and compliant fashion.

REPORTING – GENERAL

May I report using either the Internet or the telephone?

Yes. With EthicsPoint, you have the ability to report a compliance concern via either the telephone or the Internet. EthicsPoint also gives you the option of reporting anonymously (where permitted by local laws).

When is EthicsPoint Available to Take Reports?

EthicsPoint is available 24 hours a day, 365 days a year.

Can I still file a report if I don’t have access to the Internet?

If you don’t have access to the internet or are uncomfortable using a computer, you can call the toll-free hotline which is available 24 hours a day, 365 days a year. In the United States, you can dial 1-855-685-7717. You can also dial directly from outside the United States; country-by-country dialing instructions are listed in the “Report a Concern BY PHONE” tab on this website.

What should I do if the telephone number is not working?

If the telephone number listed in the “Report a Concern BY PHONE” tab on this website is not functioning, please make your report online through this web site. Please indicate in the report that the telephone number did not work.

What should I do if the country I am in is not listed above?

If there is no service for your location, please make your report online through this web site. Please indicate in the report that dialing instructions for the country you are located in were not available. If you wish, you can request that someone contact you directly to discuss your concerns further.

What type of situations should I report?

EthicsPoint is designed for anyone to report actual or potential instances of non-compliance with the Astellas Group Code of Conduct, Astellas Business Partner Code of Conduct, Astellas policies and procedures, and applicable laws, regulations and industry codes, as well as any suspected unethical behavior or business practice by an Astellas employee or business partner.

REPORTING SECURITY & CONFIDENTIALITY

It is my understanding that any report I send from my computer or device generates a server log that shows every website my computer or device connects with. Won’t this log identify me as the report originator?

EthicsPoint does not receive any information regarding your computer or device, nor does it generate or maintain any internal connection logs with IP addresses. EthicsPoint does not keep track of, pursue, or provide Astellas with any information about your identity that you do not provide.

If you feel uncomfortable making a report on your computer or device, you have the option of using a different computer or device that is not associated with you (such as one located at an Internet café, the library, at a friend’s house, etc.) through the EthicsPoint secure website.

Can I file a report from home and still remain anonymous?

All reports – whether from home, a neighbor’s computer, or any Internet portal – may remain anonymous, where permitted by local laws. An Internet portal never identifies a visitor by screen name, and EthicsPoint strips away identifying information, such as an IP address, so that anonymity is maintained.

I am concerned the information I provide through EthicsPoint will ultimately reveal my identity. How can you assure me that will not happen?

EthicsPoint is designed to protect your identity because it does not collect, maintain, or transfer any identifying information that you do not provide. Further, Astellas will not seek to learn your identity if you wish to remain anonymous, as permitted by local laws.

Where do these reports go? Who can access them?

Reports are entered directly to a secure server. Reports are available only to specific individuals within Astellas who are responsible for evaluating, investigating and resolving reported compliance concerns, based on the nature and location of the incident. Each of these report recipients has had training in keeping these reports confidential.

Is the telephone toll-free hotline also confidential and anonymous?

Yes – so long as anonymous reporting is permitted by local laws. You will be asked to provide the same information you would provide in an Internet-based report, and the EthicsPoint employee will type your responses directly into EthicsPoint. Reports submitted by calling the phone numbers listed under the “Report a Concern BY PHONE” tab on this site have the same security and confidentiality measures applied to them during delivery as Internet-based reports.

What if I want to be identified with my report?

There is a section in the report where you may identify yourself.

REPORTING ADDITIONAL INFORMATION

What if I remember something important about the incident after I file the report?

When you file a report, either using the Internet or by dialing one of the listed phone numbers, you receive a unique report key and are asked to select a password. With the report key and your password, you can return to EthicsPoint, either by Internet or telephone, and access the original report. At that point, you can add more details.

What if you have questions for me concerning my report?

EthicsPoint allows Astellas to post questions for you or share other information concerning your report, even if you report anonymously. We ask you to please check EthicsPoint regularly to see if any questions have been posted. Checking back periodically will provide the opportunity for dialogue that allows situations not only to be identified but also resolved, no matter how complex.

Are these follow-ups on reports as secure as the first one?

All EthicsPoint correspondence is held in the same strict confidence as the initial report. If you initially chose to remain anonymous, any follow-up communications will remain anonymous (where permitted by local laws).

REPORTING – FAQS FOR ASTELLAS EMPLOYEES

If I have a compliance concern, shouldn't I just report it to my manager or Human Resources and let them deal with it?

As an Astellas employee, when you observe behavior you believe is an actual or potential compliance violation, you are obligated to report it. There are a number of ways you can do so, including contacting your manager, Human Resources, Ethics & Compliance, Legal, or a member of our management team. In addition, you can always use the E&C Helpline, EthicsPoint, which will allow you to report a compliance concern 24 hours a day, 365 days a year, and gives you the option of reporting anonymously (where permitted by local laws). To the extent you are comfortable doing so, however, Astellas encourages you to reveal your identity and provide as many details as possible to help facilitate a robust investigation.

Why should I report what I know? What’s in it for me?

Compliance and integrity are core Astellas values. Central to those values is the responsibility to act in an ethical manner and to speak up if something is not right or someone is not acting compliantly. By working together, we can maintain our commitment to ethics and integrity and maintain a productive work environment.

Does management really want me to report compliance concerns?

Absolutely. In fact, the Astellas Code of Conduct requires Astellas employees to promptly report any known or suspected instances of non-compliance. You know what is going on in our company - both good and bad – and may know of an activity that may be cause for concern. Your reporting can minimize the potential negative impact on our company and help ensure that Astellas conducts its business throughout the world in accordance with applicable laws and high ethical standards.

Isn’t this system just an example of someone watching over me?

EthicsPoint does not monitor our employees. Instead, it is one of multiple reporting avenues that Astellas offers for individuals to report any known or suspected compliance concerns. It helps ensure that we live up to our commitment to do business in an ethical and compliant manner. You are encouraged to seek guidance on ethical dilemmas, provide positive suggestions, or communicate compliance concerns. Effective communication is critical in today’s workplace, and EthicsPoint is a great tool to enhance that communication.

We have carefully chosen the best reporting tool to meet our compliance obligations while maintaining a positive reporting environment.

I am aware of some individuals involved with unethical conduct, but it doesn't affect me. Why should I bother reporting it?

Ethics is a part of our culture at Astellas. All unethical conduct, at any level, ultimately hurts the company and all employees, including you. One only has to consider recent corporate scandals to see the disastrous effects non-compliant behavior can have on a company. If you know of any incidents of misconduct, actual or potential compliance violations, or ethical concerns, you have a duty to yourself and your coworkers to report it. It is the right thing to do.

I am not sure if what I have observed or heard is a violation of company policy or involves unethical conduct, but it just does not look right to me. What should I do?

File a report using any available reporting channel – your manager, Human Resources, Ethics & Compliance, Legal, or the E&C Helpline – so your concerns can be properly understood. We would rather that you report a situation in good faith that turns out to be harmless than let possibly unethical or noncompliant behavior go unchecked because you were unsure.