Compliance

As a company that handles medical devices that are critical to the lives of patients, we believe that in order to be a trusted presence at all times, we must not only comply with laws and regulations but also follow compliance policies with high ethical standards. To that end, the actions of each and every employee are important. Therefore, we strive to ensure thorough compliance awareness by disseminating the Code of Conduct so that we can meet the expectations of all stakeholders and build relationships of trust.

» JLL Philosophy

Based on the Compliance Promotion Regulations, the Board of Directors has appointed a Chief Compliance Officer (CCO) and the Compliance Committee, chaired by the CCO, plays a central role in promoting company-wide compliance activities. The Compliance Committee meets quarterly to discuss various compliance issues, including sharing information on compliance violation cases, the operation of the whistleblower system, and the status of compliance training. In addition, the CCO reports quarterly to the Board of Directors on the status of company-wide compliance and receives instructions as appropriate.

The JLL Group has establisheda whistleblower system to ensure the early detection, response, and prevention of compliance violations such as legal violations, human rights abuses, harassment, bribery, fraudulent transactions, and comprehensive corrupt practices. We have two whistleblower system contact points: An external third-party organization that allows anonymous reporting, and an internal contact point where employees can report and also feel free to discuss compliance issues. Either contact point gives maximum consideration to the anonymity and privacy of whistleblowers, protects whistleblowers so that they are not disadvantaged by reporting, conducts investiJLL Compliance Consultation Desk gations, and takes corrective measures as necessary.

At JLL Group, the Chief Financial Officer handles tax governance and leads our tax compliance efforts. Under their supervision, we work closely with external tax professionals to ensure we follow all applicable tax laws and regulations and keep positive relationships with tax authorities. We also ensure that our employees and management are promptly informed about important tax matters.

In our tax-related efforts, we are committed to the proper and timely execution of tax returns and payments. As a responsible corporate citizen, we comply with the tax laws and regulations of each country and region in which we operate. Additionally, we dedicate ourselves to realizing optimized tax costs. To this end, we carefully select and apply available tax incentives to make the best use of the government policies. Should we receive any requests from tax authorities in any country, we are always willing to cooperate.

We make sure that we make right tax payments in each country. We allocate our international income to each Group company based on its contribution in each country, allowing us to adjust our payments in line with our business activities. When calculating transfer prices for intercompany transactions, we adhere to Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations, which was established by the Organization for Economic Cooperation and Development in 2022.

In developing and introducing new medical devices, it is essential to collaborate with research institutions such as universities and medical facilities, and such activities may involve monetary payments, etc. As we comply with the “The Fair Competition Code of the Medical Devices Industry in Japan,” which is an industry-independent regulation, and related laws and regulations, our Legal Department examines and strictly monitors our relationships to ensure that they remain fair and equitable.

We, the JLL Group, in order to fulfill our mission of " Contributing to a healthier society through cutting-edge medical technologies." conducts our business activities with high ethical standards and transparency based on our Code of Ethics and Code of Conduct, and does not tolerate any form of misconduct, including bribery.

1. Definitions
(1) "Bribery" refers to acts of offering, promising, giving, soliciting, or receiving money, goods, entertainment, gifts, benefits, or anything of economic value with the intent to unjustly distort proper transactions of medical devices or the fair judgment of healthcare professionals.
(2) "Public officials, etc." refers to individuals who perform public duties based on laws, regulations, establishment acts, or other provisions and are subject to anti-bribery regulations. This includes, but is not limited to:
① Public officials under laws such as the National Public Service Act and Local Public Service Act.
② Individuals affiliated with private companies or organizations but in positions to exercise public duties or authority (deemed public officials).
③ Individuals affiliated with foreign governments, local governments, international organizations, or government-related enterprises who perform duties as public officials.
④ Individuals subject to anti-bribery regulations under establishment acts or related laws.

2. Compliance Requirements
(1) Compliance with Relevant Laws and Regulations
We comply with relevant laws and regulations concerning anti-bribery in all countries and regions where it operates, including the following:
① Japan: Unfair Competition Prevention Act (Article 18)
② Malaysia: Malaysian Anti-Corruption Commission Act 2009
③ United States: Foreign Corrupt Practices Act (FCPA)
④ United Kingdom: UK Bribery Act 2010

(2) Prohibition of Improper Payments, etc.
We prohibit improper payments or provision of benefits to public officials, healthcare professionals, or any other individuals or organizations for the purpose of obtaining improper business advantages, exerting undue influence, or distorting fair decision-making.

(3) Accurate and Appropriate Accounting Records
We ensure the preparation and maintenance of accurate and appropriate accounting records for all payments and receipts, including interactions with public officials and healthcare professionals.

(4) Continuous Implementation of Internal Education
We conduct regular training and education to ensure compliance with laws and this policy regarding anti-bribery.

Furthermore, we require our business partners to act in accordance with the content of this policy.