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STATE OF CALIFORNIA
COMPREHENSIVE COMPLIANCE ANNUAL PROGRAM DECLARATION
As part of the continued compliance efforts of Takeda
Pharmaceuticals North America, Inc., and its subsidiaries, we have developed a
Corporate Ethics & Compliance Program, as described in our Corporate Ethics
& Compliance Program Charter, and hereby declare:
To the best of our knowledge, and based upon our good faith
understanding of the statutory requirements, our Corporate Ethics &
Compliance Program is in compliance with the requirements for a Comprehensive
Compliance Program as set forth in California Health and Safety Code §§ 119400-119402.
To the best of our knowledge, we are, in all material respects,
in compliance with our Corporate Ethics & Compliance Program.
This declaration is made as of the date indicated above.
We have tailored our Corporate Ethics & Compliance
Program to the size and organizational structure of our company, and
implemented the program to demonstrate our company’s commitment to compliance
and to satisfy the statutory requirements of the State of California.
Takeda’s Office of Ethics & Compliance is charged with
the continuous improvement of our Corporate Ethics & Compliance Program and
will reassess and refine the Program as necessary and appropriate.
Our program is reasonably designed to prevent improper
conduct from occurring. As the Office of Inspector General of the U.S.
Department of Health and Human Services recognizes in its
OIG Compliance Program Guidance for Pharmaceutical Manufacturers,
however, the implementation of a compliance program cannot entirely eliminate improper
conduct. Accordingly, we cannot, and we do not represent that we can entirely
eliminate improper conduct or completely prevent individual employees from
engaging in improper conduct. Through our Corporate Ethics & Compliance
Program, we have established mechanisms to identify suspected improper conduct
and to take appropriate disciplinary and/or corrective action in the event that
improper conduct occurs.
A copy of this Declaration and Takeda’s Corporate Ethics
& Compliance Program Charter can be obtained by calling 1-888-825-3320.
Version: July 2008
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