Declaration of Compliance

Veritas Corporation hereby declares that it gives top priority to compliance in daily operations and that it will live up to stakeholder expectations.

Compliance initiatives

In order to further enhance Veritas's value to society as a global biotechnology marketing company, its executives and employees strive to ensure compliance by observing laws and ordinances inside and outside Japan, corporate ethics, and social codes ever more thoroughly at all times when performing their duties, creating a keener awareness of the need for compliance and acquiring knowledge, and understanding the relevant standards correctly. Veritas's compliance initiatives are as follows:

• Abide by related laws and ordinances strictly on a company-wide basis when engaged in sales operations and administrative work requested by customers
• Strive to the utmost to provide working-level employee training in, and ensure compliance with, laws and ordinances
• Establish a Compliance Committee to promote compliance efforts and work to ensure compliance on a company-wide basis
• Assure customers of Veritas's commitment to compliance with related laws and ordinances
• In terms of internal controls, conduct business appropriately in accordance with the Veritas Corp. Quality Management System Manual based on the guiding principles, quality policy, code of conduct, and standards of the ISO9001:2015 quality management system.
• Establish a section for employees to directly contact for consultation about or reporting internal illegal acts, inappropriate practices and the like, and clearly stipulate that persons seeking advice and/or making reports will not be put at a disadvantage for doing so.

Basic Policy for the Protection of Personal Information

Veritas Corporation recognizes that the appropriate protection and management of personal information is an important responsibility and handles personal information related to its business in an appropriate manner. As a company operating in a wide range of areas such as pharmaceuticals, diagnostic agents, research reagents, and the aquatic environment, it strives to fulfill its social responsibilities and protect personal information in accordance with the following policies:

• Comply with laws and ordinances related to personal information
  • Veritas observes laws, ordinances, and other standards related to personal information.
  • Veritas is fully aware of its missions and responsibilities, and handles personal information appropriately.
• Improve Veritas’s internal control systems continuously
  • Veritas strives to continuously improve and review its internal control systems for personal information protection.
• Make all-out efforts to take measures to manage personal information safely
  • In an effort to prevent the divulgence, loss, destruction, or falsification of personal data Veritas handles as well as unauthorized access, it takes necessary, appropriate, and reasonable measures to manage such data safely.
  • Veritas appropriately collects, utilizes, and provides personal information within the range required for fair business activities.
  • Veritas handles personal information appropriately taking into account the characteristics of its business and personal information it handles (such as information related to privacy and the privacy of communication).
  • Veritas provides its executives and employees with training so they can be fully familiar with its policies, internal regulations, etc. for the protection of personal information.
  • If Veritas outsources the handling of personal information to a third party, Veritas conducts strict investigations of that third party and supervise it properly so that it maintains the confidentiality of the information.
• Respect for rights
  • Veritas respects the rights of individuals to personal information, and if Veritas is requested by the individual concerned to disclose, correct, or delete personal information it holds on him/her, it responds appropriately to such request according to generally accepted ideas and practices.

About personal information held by Veritas Corporation

• Personal information Veritas collects and methods used to obtain it
  The personal information Veritas obtains through data entry by customers is as follows:
  • Affiliation, name, address, contact, etc.
  • Replies to questionnaires
  • Other information for registration
• Purposes of use
  Veritas utilizes personal information on customers only for the purposes listed below.
  • Business-related communication, performance of contracts to provide products and services handled by Veritas, and collection of fees for marketing activities carried out for a consideration
  • Utilization for products and services handled by Veritas (such as promotional campaigns, questionnaire surveys, and seminars)
  • Acceptance of customers as Veritas website's members and communicating with them
  • Provision of information on the quality, safety, and effectiveness of products handled by Veritas
  • Business required from commercial practices such as New Year and other greeting cards
  • If Veritas obtains personal information for purposes other than those listed above, it specifies such purposes in advance. Personal information obtained for such purposes will not be used beyond those expressly stated.
• Disclosure and provision of personal information to, and outsourcing its handling to, third parties
  • Veritas does not provide third parties with personal information without the consent of the customer concerned.
    However, Veritas may provide personal information to contractors within the range required to achieve the purposes of use.
    Veritas strives to the utmost to manage personal information properly. It should be noted that based on such efforts, Veritas may provide such information to contractors to the minimum extent required (For example, Veritas informs customers' names and addresses to companies it outsources delivery and other services).
    In such cases as well, Veritas ensures the appropriate management of personal information it provides by requesting that contractors handle information properly. Furthermore, Veritas may use the personal information collected for operations related to products and services it or its affiliated companies handle, or based on the personal information obtained, Veritas may provide customers with information on such products and services.
  • In addition, Veritas may provide personal information on customers to third parties within the range required by laws and ordinances.
• Disclosure, correction, erasure of personal information and discontinuation of its use
  • If customers do not wish their personal information to be used or provided, or if they want to confirm, correct, or delete the personal information they registered, and make such a request to the section to contact for inquiries, Veritas will respond to such request accordingly.
    If an individual requests Veritas to disclose the personal information that he/she provided on him/her own, Veritas will disclose the portion of the information related to such request in accordance with the provisions of the relevant laws and ordinances.
• Section to contact for inquiries
  All inquiries regarding this Basic Policy for the Protection of Personal Information should be addressed via email or postal mail to the following section:
  
  Contact for inquiries
  Personal Information Management
  Veritas Corporation
  Sumitomo Hamamatsucho Bldg. 6th Floor,
  1-18-16 Hamamatsucho,
  Minato-ku, Tokyo 105-0013, Japan
  email: legal@veritastk.co.jp

Anti-Bribery Anti-Corruption Policy

Veritas Corporation hereby enacts the anti-bribery/anti-corruption policy and its exclusives and employees strive to fulfill the following requirements thoroughly at all times when performing their duties.

Scope of application

This Policy applies to all executives and employees (including, in addition to regular employees, contract employees, temporary employees dispatched by a placement agency, part-time employee, and advisors; the same applies hereinafter) of Veritas regardless of the country or region where their activities take place.

Declaration and Compliance

• Compliance with laws and regulations
  All executives and employees of Veritas comply with the Criminal Code, Companies Act, Unfair Competition Prevention Act, and other relevant laws of Japan concerning anticorruption as well as US Foreign Corrupt Practices Act, UK Bribery Act, commercial bribery legislation of China, and all laws and regulations concerning prohibition of bribery applicable in all countries and regions where Veritas carries out its business.
  Furthermore, Veritas requires all of its customers and vendors to comply with these regulatory requirements concerning prohibition of bribery.
• Prohibition of bribery
  All executives and employees of Veritas do not, whether directly or indirectly, provide, offer to provide, or promise to provide money or other benefits to any person including public officials and private citizens in or outside the country to obtain unlawful business benefits.
• Prohibition of receiving bribes (prohibition of receiving unlawful benefits)
  All executives and employees of Veritas do not, whether directly or indirectly, request or receive inappropriate or unlawful benefits to or from any person including public officials and private citizens in or outside the country.
• Prohibition of bribery through third parties
  No executive or employee of Veritas provides, offers to provide, or promises to provide or receives bribes through third parties such as consultants and agents.
• Lawful entertainment and gift-giving
  When lawfully providing entertainment, gifts, travel expenses, donations, sponsorship, or support to customers and vendors for legitimate business purposes, all executives and employees follow relevant rules and comply with all applicable laws and regulations.
• Thorough recording and management
  All executives and employees of Veritas correctly record all transactions in accounting books and maintain such records in an appropriate manner.
• Educational and awareness building activities
  Veritas provides education and training on a continual basis for the purpose of making this Policy known and raising awareness of compliance with this Policy within Veritas.
• Reporting concerns and protection
  Any executive or employee of Veritas who suspects of any violation of this Policy or relevant laws and regulations or faces a situation where a certain act potentially constitutes a violation immediately reports such issue to the responsible section of Veritas (Administrative Department). Veritas does not treat disadvantageously or take retaliatory action against any person who raises concerns or doubts in good faith.
• Actions taken in the event of violation
  When Veritas discovers any act of violation or possible violation of this Policy, Veritas carries out internal investigation in a strict manner and fully cooperates with relevant authorities in their investigation.
  Any executive or employee who violates any provision of this Policy or any other rules of Veritas will be legally liable as an individual and also be subject to strict disciplinary actions in accordance with the rules of Veritas.

VERITAS Code of Conduct

Veritas Corporation positions the streamlining of international industries through the coordination of advanced technology as its basic line of business and considers it its mission to contribute to world peace by fostering circles of trust internationally through its business. This Code of Conduct was established so that each employee can improve themselves and Veritas can expand its business based on this Mission, thus contributing to all stakeholders and the society in general.

1: Basic actions

• Veritas will strive to establish corporate ethics so that it will gain society’s trust as a biotechnology marketing company.
• Veritas will comply with Japanese and international laws and regulations, relevant independent industrial standards, the Code of Ethics, social standards and in-house rules and carry out corporate activities with high ethical standards and social sensibility.

2: Corporate actions

Actions as business persons

• Veritas will respect local cultures and traditions in Japan and internationally and contribute to the development of local communities through corporate activities.
• Veritas will manage internal information properly and protect it thoroughly with security based on its Privacy Policy that will ensure accountability towards the society.
• Veritas will be environmentally responsible when carrying out corporate activities.
• Veritas will proactively implement social contribution activities.
• Veritas will always maintain a sound relationship with political and administrative bodies and its partners. The company will not hold a relationship with anti-social forces and organizations that threaten the social order and safety.

Actions as a biotechnology marketing company

• Veritas will proactively seek information on products that possess new technologies and values. When providing product information, Veritas will work to provide accurate data while demonstrating its expertise and broad perspectives.
• Under a comprehensive quality assurance system, Veritas will comply with relevant laws and regulations, including the Pharmaceutical Affairs Law, rules and in-house rules to supply high-quality products with stability.
• When marketing products, Veritas will comply with the Antitrust Law and relevant laws, regulations and rules. It will carry out fair and transparent sales activities based on the industry’s independent standards and in-house rules.
• For corporate advertising, product advertising and sales activities, Veritas will comply with the Pharmaceutical Affairs Law among other relevant laws, regulations and in-house rules. It will eliminate expressions that may potentially mislead its customers and partners, and use accurate and appropriate expressions instead.
• For complaints from customers, Veritas will promptly ascertain the situation, investigate to identify causes and respond with accuracy. It will take necessary measures to prevent further damages and occurrences.

3: Actions as a marketing company

• The management team will respond to changes in the external environment such as social structure, and work on building a simple structured organization while rationalizing and streamlining company management overall.
• The management team shall respect employees’ rights and individuality and will develop a safe and comfortable working environment. By continually updating its employee training system and self-enlightenment assistance system, the management team will provide a motivational workplace in which each employee can grow and enrich their lives without pressure while fully demonstrating their enthusiasm and capabilities.
• The management team recognizes its role of demonstrating the spirit of this Code of Conduct, and will take initiative to thoroughly drill the significance of the Code into everyone in the company and develop an in-house structure. When developing an in-house structure, the team will establish a structure that will ascertain, assess and report the conditions of the Business Conduct Guidelines based on the spirit of this Code of Conduct.
• In the event that a situation that violates this Code of Conduct arises, the management team will immediately investigate the cause, work to resolve the issue, and prevent recurrence.