Culture of Compliance

Our Culture of Ethics and Compliance

Takeda is an organization based on integrity. A culture of compliance is borne out of this foundation and it shapes, the decisions we make, and the actions that we take as Takeda employees. Please click here to view the Takeda Global Code of Conduct.


Takeda established a Corporate Ethics & Compliance Program that requires that all Takeda employees and agents are responsible for conducting their business activities in compliance with all applicable laws and regulations, industry guidance and codes and the highest standards of ethical behavior. The Corporate Ethics & Compliance Program is aligned with the OIG Compliance Program Guidance for Pharmaceutical Manufacturers. In addition, Takeda adopted the principles set forth in the PhRMA Code on Interactions with Healthcare Professionals.


One of the Program’s missions is to prevent and detect violations. To report a suspected violation, please call 1-888-TAKEDA-0 (1-888-825-3320) or make an on-line report by clicking this link www.Takeda.Ethicspoint.com


1. Written Policies & Procedures


Our company Global Code of Conduct, US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities, and other related Compliance policies and procedures are tangible expressions of our culture of ethics and compliance. These documents guide and instruct Takeda personnel in the conduct of our day-to-day activities. The Global Code of Conduct and the US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities, and other related Compliance policies and procedures express Takeda’s commitment to:

  • Preventing the occurrence or even the appearance of illegal or unethical behavior as soon as reasonably possible after its discovery; and
  • Disciplining employees who violate the Global Code of Conduct, US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities, and other related Compliance policies and procedures up to and including termination, is the sole discretion of Takeda

The Global Code of Conduct gives us a framework for achieving the highest ethical standards when we make decisions and take actions that can affect people’s lives. At Takeda, we have a culture that encourages ethical behavior and shared responsibility among all employees. Acting with integrity is also everyone’s personal responsibility.

The US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities sets forth the ethically appropriate manner in which Takeda personnel will interact with Healthcare Professionals and Healthcare entities. This document reflects the company’s adoption of the principles set out in the PhRMA Code on Interactions with Healthcare Professionals.

Takeda also has developed policies and procedures identifying appropriate conduct in the three primary risk areas for pharmaceutical companies identified in the OIG Guidance, including, (1) data integrity pertaining to government reimbursement practices; (2) kickbacks and other illegal remuneration; and (3) compliance with laws regulating drug samples.


2. Leadership & Oversight


Takeda has established its Global Ethics & Compliance Office to lead the company’s ethics and compliance efforts. The Global Ethics & Compliance Office is responsible for developing, implementing, and continuously improving Takeda’s Corporate Ethics & Compliance Program. Takeda is committed to ensuring that the Global Ethics & Compliance Office can effectuate necessary and appropriate change within the company and to exercise independent judgment. The Head of USBU Ethics & Compliance reports to Takeda’s Global Ethics & Compliance Officer. Takeda’s Global Ethics & Compliance Officer reports to Takeda’s Global General Counsel.

The Global Ethics & Compliance Office works closely with Takeda Leadership in shaping the company’s Corporate Ethics & Compliance Program. This engagement is to provide advice and oversight in the development, implementation, and continuous improvement of this Program. Compliance engages with a number of Takeda’s senior management personnel from both Commercial and R&D, including the heads of the Legal, Marketing, Sales, and Medical & Scientific Affairs departments, who provide a variety of skills and perspectives as well as the authority to effectuate compliance initiatives within their respective functions.


3. Training & Education


Training and education are critical features of Takeda’s Corporate Ethics & Compliance Program. We firmly believe that when provided with the proper tools and information, Takeda employees will conduct their activities in a manner consistent with our culture and the law. Takeda is committed to taking the necessary steps to effectively communicate our Global Code of Conduct, US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities and other related Compliance policies and procedures to all employees.

New employees in both the Home Office and the field receive initial training and tenured employees receive refresher training on Takeda’s Global Code of Conduct, US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities and other related Compliance policies and procedures. We employ a mix of instructor-led and computer-based training that is example based to provide employees with real world scenarios to which to apply Takeda’s policies. Takeda employees also receive training that is specific either to their roles—for example, sample accountability training for sales representatives involved with the distribution of samples—or to a topic area—for example, speaker program training.

 

4. Lines of Communication


Employees are encouraged to take advantage of Takeda’s open-door policy when it comes to raising ethics and compliance questions and discussing potential ethics and compliance concerns. Managerial personnel are available to respond to these questions and concerns, as is the Global Ethics & Compliance Office. If an employee does not feel comfortable talking with their manager, they also may contact the Ethics and Compliance Office directly or through the Takeda Ethics Line. Reports to the Takeda Ethics Line may be made anonymously. Upon receiving a report, the Global Ethics & Compliance Office, in conjunction with other relevant functions, will follow up to ensure appropriate resolution.

Takeda is committed to its policy of not retaliating against personnel who make good faith reports of potential ethics and compliance issues. This policy is expressed in Takeda’s Global Code of Conduct and US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities.


5. Monitoring & Auditing


The Global Ethics & Compliance Office and the Group Internal Audit engage in ongoing monitoring and auditing to evaluate the existence of appropriate policies and procedures, the implementation and communication of such policies and procedures, and compliance with such policies and procedures. In accordance with the OIG Guidance, the nature, extent, and frequency of the reviews Takeda conducts varies according to factors such as new regulatory requirements, changes to Takeda’s business practices, or identified high-risk areas.

In addition to the company’s monitoring and auditing activities, all Takeda employees are responsible for reporting potential ethics or compliance issues of which they become aware. Both the Global Code of Conduct and the US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities expressly highlight this responsibility.


6. Disciplinary Policies


Takeda is committed to having clear disciplinary practices to address situations where employees engage in illegal or unethical conduct. While conduct is evaluated on a case-by-case basis, the company will undertake disciplinary or corrective action in a consistent manner so as to ensure that such action is appropriate under the circumstances and has the intended deterrent effect. Penalties for compliance violations may include termination, depending upon the seriousness of the violation.


7. Investigation & Corrective Action


Takeda’s Corporate Ethics & Compliance Program is designed to create a culture of compliance and to help prevent the likelihood of the occurrence of illegal or unethical behavior. As recognized in the OIG Guidance, no compliance program can prevent all occurrences of misconduct by individuals. However, Takeda’s Corporate Ethics & Compliance Program is reasonably designed to prevent and detect violations.

The Global Code of Conduct and US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities address the investigation of suspected violations of the Global Code of Conduct and US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities and other related Compliance Policies and Procedures. Upon receipt of reports or discovering information about a suspected violation of the Global Code of Conduct, US Compliance Policy for Interactions with Healthcare Professionals and Healthcare Entities, and other related Compliance Policies and Procedures, Takeda responds promptly, including, where appropriate, conducting an investigation to determine if a violation has occurred. If the company determines that a violation has occurred, it shall promptly take appropriate disciplinary and/or corrective action to help prevent similar violations in the future.

To further assist in preventing violations, the company screens individuals against the OIG exclusion list prior to making hiring decisions.

Takeda’s Compliance Mission

At Takeda, the Global Ethics & Compliance Office’s mission is to nurture a company-wide ethical culture in line with Takeda-ism and our priorities of Patient-Trust-Reputation-Business. Takeda’s Corporate Ethics & Compliance Program is designed to help each and every one of us achieve this mission.