Corporate Philosophy

• To plan, conduct and report clinical projects to applicable quality and regulatory standards, agreed timelines and budgets.
• To specialise in clinical pharmacology and in the delivery of clinical Proof of Concept results to enable efficient and effective drug development and decision making.
• To develop and sustain appropriate and distinctive business capability.
• To strive for an effective global collaboration with global colleagues.

DSPE's anti-bribery ethos

Dainippon Sumitomo Pharma Europe Ltd. ('DSPE') is firmly committed to the prevention of corruption and bribery across all areas of the organisation's operation. DSPE's ethos is to operate without bribery or corruption, and to clearly communicate this ethos to all personnel and applicable third parties with whom DSPE interacts to achieve its objectives. DSPE is committed to conducting its operations in a lawful, ethical and professional manner. Moreover, DSPE shall comply with the provisions of the Dainippon Sumitomo Pharma ('DSP') Group Anti-Corruption Policy and with applicable laws relating to bribery and corruption, including the UK Bribery Act 2010. To this end, DSPE shall implement measures which aim to reduce the risk of bribery and corruption from occurring, as far as reasonably possible. Such measures shall 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.

The DSPE Compliance Committee will monitor the organisation's anti-bribery and anti-corruption provisions (including compliance with the DSP Group Anti-Corruption Policy) on an ongoing basis, and review provisions on an annual basis, or more frequently if required. DSPE will seek advice from external specialists (including legal advisers), as needed. Relevant policy provisions shall also extend, via written agreements with third parties, to activities undertaken by others acting on DSPE's behalf.

DSPE shall 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.

These measures demonstrate DSPE's senior level commitment to ensuring that appropriate systems and procedures are in place to prevent the occurrence of bribery and / or corruption within the organisation, as far as reasonably possible.

DSPE completed a comprehensive Bribery / Corruption Risk Assessment in May / June 2011. The Risk Assessment considered key internal and external risks (in line with the Bribery Act 2010 Guidance document, and the provisions of the DSP Group Anti-Corruption Policy). Each functional manager provided input to the Risk Assessment, and the document was reviewed by an external legal adviser. The document was approved by the Compliance Committee on 16th June 2011, and signed on 17th June 2011.

DSPE will now focus on implementing appropriate follow up actions, as identified in the Risk Assessment and defined in the subsequent Implementation Plan.

The Risk Assessment will be reviewed by the DSPE Compliance Committee on a periodic basis moving forward, to identify any new risks that DSPE should address and to allow appropriate risk mitigation strategies to be put in place.