About Santen’s Speak Up Portal
Reporting – General
Reporting Security & Confidentiality
About Santen’s Speak Up Portal
What is the Speak Up Portal?
The Speak Up Portal is a confidential reporting platform designed to help the people at Santen, its associates, stakeholders, and other interested parties report any wrongdoings and/or misconduct. It consists of an online portal, a mobile website and toll-free telephone lines through which potential violations of our Code of Practice or other internal and external regulations can be reported. The Speak Up Portal is available 24 hours a day, 7 days a week, and offers a translation service that can handle the language requirements of the global environment in which Santen operates.
Who Operates the Speak Up Portal?
To maximize the confidentiality of reports, the Speak Up Portal is run by NAVEX, on their EthicsPoint platform. NAVEX is a third-party company, that specializes in ethics and compliance programs. NAVEX’s primary responsibilities are to provide a service through which people can report concerns, actual or suspected wrongdoings within Santen, protect the identity of reporters who wish to remain anonymous, and provide translation services for those who wish to report an incident in their local language. Once a concern has been submitted to NAVEX via the Speak Up Portal, it will be forwarded to the relevant parties in Santen for further investigation and resolution.
Why do we need the Speak Up Portal?
There are many channels through which concerns or issues can be reported directly to Santen including your line manager, senior leaders, Human Resources, Legal and Compliance. However, we recognize that under certain circumstances individuals may be more comfortable utilizing a third-party service to alert Santen to potential violations and misconduct. As such, we offer the Speak Up Portal, which is managed by NAVEX, a third-party company, to encourage our people who may otherwise be reluctant to bring forth good faith reports of any potential violations and misconduct. As a 24-hour service the Speak Up Portal is convenient and available whenever an individual is ready to come forward. We have chosen this platform to promote a culture where our People feel safe to speak up so that together, we maintain a safe, healthy and successful working environment for everyone.
Reporting – General
What ways can I report a concern through the Speak Up Portal?
You have the ability to file a confidential, anonymous (if you like) report either by telephone or online (on your computer or mobile phone). To report a concern by phone you will speak with a NAVEX Communication Specialist who will ask you for several items of information, document your feedback, and ask follow-up questions for clarification. This process will take around 10 to 15 minutes. The online option or web intake process will walk you through a similar set of questions. In both cases, upon completion of your report the case information will be routed to the relevant parties in Santen for further review and investigation. For example, where the concern raised is about bullying and harassment at work, it will be routed to the HR team of the relevant location. Concerns reported through the Speak Up Portal are handled the same as those reported directly to the company.
NOTE: The Santen Speak-Up Portal is NOT an Emergency Service. Do not use this site to report an adverse event or product safety concern. Reports submitted through this service may not receive an immediate response. Report adverse events concerning Santen products within 24 hours of when you first received the information using appropriate Santen adverse event reporting channels. Always report information security and cyber security incidents (phishing, ransomware, data breach, loss or theft of equipment etc.) immediately to your regional IT HelpDesk, as per Global Information Security Policies.
Are there other ways I can report concerns besides the Speak Up Portal?
Absolutely. Ideally, you should bring any concerns forward to your direct line manager, or other members of our Management Team. However, reports can be made through several channels including Human Resources, Compliance, Legal, Internal Audit, etc.
If you are not sure if what you observed or heard is a violation of company policy, or involves unethical conduct, feel free to contact any of the resources above to discuss the situation and help determine the appropriate next steps. You can also consult the relevant local subject matter expert for further information.
What types of situations should I report?
The purpose of the Speak Up Portal is to document concerns about suspected or potential violations of Santen’s internal policies/regulations such as Santen’s Code of Practice, Whistleblower policy, or breach of the local law/regulations of the relevant location. This includes acts of corruption and bribery, conflicts of interest, acts of dishonesty and deceptive practices, inappropriate conduct, discrimination, harassment, and retaliation, data security and privacy breaches, workplace safety, misuse of computer or electronic communications, and concerns about environmental health and safety issues, antitrust, and securities laws.
All Santen employees have the responsibility to promptly report any potential violations as mentioned above and may do so via the Speak Up Portal. Reporters are protected from retaliation for concerns raised in Good Faith (believed to be true). Any report not made in good faith is not acceptable as it goes against the spirit of wanting to create a safe, healthy and successful work environment for everyone and will therefore be subject to disciplinary action.
Reporters are provided with a Report Key after they have submitted their concern and that allows for anonymous communication with a relevant party managing the case.
Why should I report what I know?
At Santen, we are committed to creating a conducive work environment that will allow our people to be at their best, where issues and concerns are raised and resolved promptly and effectively. We are committed to conducting business with honesty and integrity, and we depend on each of you to do what’s right. Our people act on behalf of the company, and we should all expect that we act with integrity, ethically, honesty and with trust and respect for each other. Santen’s success and reputation will depend on that. Protecting our reputation and values is fundamental to our continued success and growth. Speaking up helps stop or prevent unethical, illegal or other forms of misconduct that may jeopardize a safe, healthy and successful work environment for us all.
When someone’s actions violate our Code, our policies or procedures, or applicable laws or regulations, it can harm Santen. If a law is violated, the result could be civil or criminal action against Santen and the person responsible.
We take any potential violation seriously. Reports of potential misconduct are reviewed carefully and steps are taken to correct the situation, including disciplinary action when appropriate.
Being ethical and compliant in everything that we do is everyone’s concern. It is your responsibility to speak up and report any potential violations and compliance concerns and our culture of compliance starts with you!
What if I’m wrong or may not have all the information? I don’t want to wrongly accuse someone.
All reports submitted will be reviewed, investigated and addressed appropriately, including whether the concern is justified or not. If the concern is not justified or cannot be substantiated (for example due to lack of evidence), then you as the reporter, will be notified. If you have a genuine concern and would like to make a report in good faith, then we strongly encourage you to do so.
What if I remember something important about the incident after I file the report? What if the company has further questions for me concerning my report? How do I find out the status of my concern?
When you file a report through the Speak Up Portal you will be issued a Report Key. Please record it and keep it in a safe place. You will need to use this report key along with the password of your choosing to return to the Speak Up Portal. You can access the Speak Up Portal again through the website (on your computer or mobile phone) or telephone hotline to receive feedback or provide additional information about the concern which you had earlier reported. We strongly suggest that you check back into the Speak Up Portal if you are an anonymous reporter as this is the only way we will be able to communicate with you if we have any questions.
You can also check the status and disposition of your report by accessing the Speak Up Portal. Due to privacy concerns, we will not be able to disclose detailed findings or case outcomes to reporting parties. We will, however, be able to share with you whether the case is still under investigation or has been closed. You are, of course, encouraged to report any feedback or continuing issues even after case closure.
Reporting Security & Confidentiality
Where do these reports go and what happens to the information provided?
Reports submitted via the Speak Up Portal are entered directly in the NAVEX secure server to prevent any possible breach in security. NAVEX makes these reports available only to specific individuals within Santen, who are charged with evaluating the report based on the type of violation and location of the incident. The report will then be assigned to the appropriate party within Santen for further investigation.
Any information you provide will be treated as confidential to the extent permitted by law and other than where disclosure is necessary in the context of an investigation into a reported concern. Confidentiality will be protected to the greatest extent possible while allowing for a thorough investigation and appropriate resolution to take place.
Anonymity and Zero tolerance for Retaliation
You can choose to make a report by identifying yourself or make a report anonymously, except where legally restricted from doing so. With our principle of zero tolerance for retaliation, we encourage you to identify yourself when making a report because knowing the identity of the reporting party can often assist with the investigation. We take our zero tolerance for retaliation principle very seriously as it is the key to the success of speaking up. No one who reports any suspected violation in good faith will be subject to retaliation for making such a report. “Good faith” means that you come forward with all the information you have and believe you are giving a sincere, truthful, and complete report.
Please include sufficient details and evidence you may have, to enable Santen to complete a thorough review of your report, especially if you chose to report anonymously.
Can I file a report from a home, company or alternative computer and still remain anonymous?
The Speak Up Portal service provider, NAVEX, does not generate or maintain any internal connection logs with IP addresses, so no information linking the PC you use to file the report is available. In fact, NAVEX, is contractually committed not to pursue a reporter’s identity.
A report from home, a neighbor’s computer, or any Internet portal will remain secure and anonymous. An Internet portal never identifies a visitor by screen name and the system strips away Internet addresses so that anonymity is totally maintained.
Is the telephone line confidential and anonymous too?
Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the Speak Up site. These reports have the same security and confidentiality measures applied to them during delivery.