Corporate Information Anti-Bribery and Corruption Policy
Anti-Bribery and Corruption Policy
PT. MITSUBISHI TANABE PHARMA INDONESIA
Policy Statement
This Policy sets out anti-bribery and corruption policy applicable to PT Mitsubishi Tanabe Pharma Indonesia in accordance with the legislation applied in Indonesia about bribery and corruption and Global Anti-Bribery and Corruption Policy Guidelines (for Indonesia) by Mitsubishi Tanabe Pharma Corporation.
It is PT Mitsubishi Tanabe Pharma Indonesia’ policy to conduct all business in an honest and ethical manner as a “Life Science Company”. PT Mitsubishi Tanabe Pharma Indonesia takes a zero-tolerance approach to Bribery and Corruption and is committed to acting professionally, fairly and with integrity in all of its business dealings and relationships, and implementing and enforcing effective systems to counter Bribery and Corruption.
PT Mitsubishi Tanabe Pharma Indonesia will uphold all regulations and legislation relevant to countering Bribery and Corruption.
Engaging Third Parties
Employees and Third Party Representatives, pursuant to this Policy, shall perform the necessary procedures for business relationship to Third Party or Public Service to Public Officials
Employees and Third Party Representatives must communicate PT. Tanabe Indonesia’s zero-tolerance approach to Bribery and Corruption to Third Parties at the outset of a business relationship with them and as appropriate thereafter.
It is the responsibility of all Employees of PT. Tanabe Indonesia to conduct due diligence prior to establishing a business relationship with Third-Party Representative or third parties considering such factors as territory, reputation, qualifications, honesty and openness, the manner and reasonableness of compensation and the relationship.
Purpose of this Policy
The purpose of this Policy is to:
set out Employees’ and Third Party Representatives’ responsibilities in observing and upholding PT Mitsubishi Tanabe Pharma Indonesia’ position on Bribery and Corruption, and in maintaining fair trade practices and
Provide Employees and Third Party Representatives with information and guidance on how to recognize and deal with Bribery and Corruption issues.
It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty may be punished in accordance with PKB, by imprisonment and/or a fine. As an employer, if a PT Mitsubishi Tanabe Pharma Indonesia fails to prevent Bribery it may face fines and damage to PT Mitsubishi Tanabe Pharma Indonesia’s and Global Company’s reputation. PT Mitsubishi Tanabe Pharma Indonesia therefore take their legal responsibilities very seriously.
Prohibited Conduct
It is not acceptable for Employees and Third Party Representatives (or who represent it) to:
Give, or promise or offer to give any Advantage with the expectation that any Advantage will be received in return, or to reward any business advantage already given in return
Give, or promise or offer to give any Advantage during any commercial negotiations or tender process, if this is intended to or will influence the outcome
Accept, or promise or offer to accept any Advantage from a Third Party that they know or suspect is offered with the expectation that a PT Mitsubishi Tanabe Pharma Indonesia will provide any Advantage for them or anyone else in return
Give, or promise or offer to give, or accept, or promise or offer to accept any Advantage to or from government officials or representatives, or politicians or political parties without prior approval in accordance with Local Policies or
Engage in any other activity that will lead to a breach of this Policy, including Clause 9.1. or become a perpetrator who commits a bribery and corruption act as mentioned in the Potential Risk Scenario 'Red Flag' Clause 11.
Record-Keeping
Employees and Third Party Representatives must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to Third Parties and/or public official.
Employees and Third Party Representatives must submit all expenses claims relating to payments to Third Parties and/or public official and record the reason for expenditure.
All accounts, invoices, and other records relating to dealings with Third Parties and/or public official should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.
Responsibilities of Employees and Third Party Representatives
Employees and Third Party Representatives must read, understand and comply with this Policy and other applicable Policies of PT Mitsubishi Tanabe Pharma Indonesia.
The prevention, detection and reporting of Bribery and Corruption are the responsibility of Employees and Third Party Representatives. Employees and Third Party Representatives are required to avoid any activity that will lead to, or suggest, a breach of this Policy.
Employees and Third Party Representatives must follow notification procedures defined in this policy if they believe or suspect that a conflict with this Policy has occurred, or may occur in the future.
If Employees or Third Party Representatives are offered a bribe, or are asked to make one, or if believe or suspect that any Bribery, Corruption or other breach of this Policy has occurred or may occur, Employees must immediately report this to the Compliance Committee or Third Party Representatives must report it to the contact person or Compliance Committee of PT Mitsubishi Tanabe Pharma Indonesia.
If Employees or Third Party Representatives are unsure about whether a particular act constitutes Bribery or Corruption, Employees must immediately report it to the Compliance Committee or Third Party Representatives must report it to the contact person or Compliance Committee of PT Mitsubishi Tanabe Pharma Indonesia.
If the Employee, in their circumstances beyond his or her consent has received a gift from a Third Party Representatives or Public Official, then Employees shall immediately report this to the Compliance Committee. Employees, prior to such reporting, is prohibited to enjoy the prizes and the prizes will be submitted fully to the Compliance Committee.
No Retaliation
Employees or Third Party Representatives must not retaliate, attack, denounce or intervene or deeds of any kind (‘retaliation’) against another individual who has refused to commit a Bribery offence or who has raised concerns participate in socializing, although voluntarily, to submitting and obey this Policy.
Individuals who refuse to accept or offer a bribe, or who raise concerns to this policy or report another's wrongdoing, are sometimes worried about possible retaliation. PT Mitsubishi Tanabe Pharma Indonesia aims to encourage openness and no retaliation in any form whatsoever is permitted by the PT Mitsubishi Tanabe Pharma Indonesia against anyone who reports or gives a statement in connection with a complaint.
PT Mitsubishi Tanabe Pharma Indonesia are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in Bribery or Corruption, or because of reporting in good faith their suspicion that an actual or potential Bribery or Corruption offence has taken place, or will take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an Employee or Third Party Representatives believes that they have suffered any such treatment, they should report it to the Compliance Committee.
Breaches of this Policy
Any Employees who breach this Policy will face disciplinary action in accordance with PT Mitsubishi Tanabe Pharma Indonesia regulation, up to and including dismissal and sanctions in accordance with the regulation of Criminal Law legislation.
PT Mitsubishi Tanabe Pharma Indonesia is never engage and will take appropriate action for prevention, termination of business relationship, until the resistance against any Third Parties Representatives if they breach this Policy.
Potential Risk Scenarios: "Red Flags"
The following is a list of possible red flags that may arise and which may raise concerns under various anti-bribery
and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
If, Employees and Third Parties Representatives encounter any of these red flags while working for or working with a PT Mitsubishi Tanabe Pharma Indonesia, Employees must report them to the Compliance Committee. The Third Party may report to the contact person who directly has business relationship with the Third Party or to the Compliance Committee.
In this scenario, what is meant by a Third Party or Public Official is that which has become or will potentially become a Third Party or Public Official.
They become aware that a Third Party or Public Official engages in, or has been accused of engaging in, improper business practices or improver public service, such as Bribery, Corruption, acquisition of personal gain and abuse of position
If Third Parties offer anything to gain profit or remuneration from PT Mitsubishi Tanabe Pharma Indonesia, or indicate that a gift or payment is needed to secure their business
They learn that a Third Party or Public Official has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a "special close relationship" with government officials or foreign governments
A Public Official or Third Party insists on receiving a commission or fee payment before committing to sign up to a contract with PT Mitsubishi Tanabe Pharma Indonesia, or carrying out a government function or process for PT Mitsubishi Tanabe Pharma Indonesia
A Public Official or Third Party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made
A Public Official or Third Party requests that payment is made to a country or geographic location different from where the Third Party resides or conducts business
A Public Official or Third Party requests an unexpected additional fee or commission to "facilitate" a service
A Public Official or Third Party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services
A Public Official or Third Party requests that you provide employment or some other advantage to a friend or relative
They receive an invoice from a Public Official or Third Party that appears to be non-standard or customised or not issued in compliance with relevant laws and regulations
A Public Official or Third Party insists on the use of side letters or refuses to put terms agreed in writing
They notice that PT Mitsubishi Tanabe Pharma Indonesia has been invoiced for a commission or fee payment that appears excessive given the service stated to have been provided or
A Public Official or Third Party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us.
Reporting Procedures
At the moment the following event occurs, the Employee and the Third Party Representative must immediately consult or report to the person or department specified in clause 13:
If they believe or suspect that a conflict with the Policy or Guidelines has occurred, or will occur in the future (please refer to Clause 8.3).
If they are offered bribes, or are required to take bribes, or if they believe or suspect a Bribery, Corruption or other violation of the Policy or Guidelines has occurred or will occur (please refer to Clause 8.4)
If they are not sure whether an action is categorized as bribery or corruption (please refer to Clause 8.5)
If the the Employee or Third Party Representatives, in his condition cannot refuse the gift of a Third Party or Public Official beyond its power or without its intention (please refer to Clause 8.6)
If they are subjected to adverse treatment, such as dismissal, disciplinary sanctions, threats or other unpleasant treatment, as a result of refusal to participate in Bribery or Corruption, or due to the reporting of their suspicion that a bribery or corruption or potential event has occurred or will occur in the future (please refer to Clause 9.3) or
If they are faced with any situation set out in Clause 11 'Potential Risk Scenario'.
We use cookies on this website to customize our website to your needs. By continuing to use this website you consent to our use of cookies. For more information, please see our Privacy Policy.
