Compliance Promotion Initiatives

Anti-Corruption

Sysmex supports the spirit of the UN Global Compact and undertakes thorough efforts to prevent corruption in line with one of the Ten Principles, which states: “Businesses should work against corruption in all its forms, including extortion and bribery.”
The Internal Control Committee conducts periodic risk assessments covering all divisions and the Group companies in Japan and overseas. Through this process, we recognize compliance violations, including corrupt practices, as critical risks that could damage our social credibility, and we continuously work to mitigate these risks. Furthermore, the “Corruption and Bribery” section of the Global Compliance Code prohibits corrupt practices, such as giving or offering bribes or providing inappropriate entertainment or gifts. It also prohibits any other practices that may appear to be such corrupt practices, as well as accepting excessive entertainment or gifts.
In addition, our Global Anti-Bribery Regulations, applicable to all Group companies, define specific banned activities, including bribery, facilitation payments, the provision of inappropriate entertainment, gifts, benefits, or donations, and the acceptance of bribes. These regulations also establish mandates for conducting due diligence during mergers and acquisitions, providing training, and maintaining management systems, thereby driving initiatives to ensure Group-wide compliance. If a violation of the Global Anti-Bribery Regulations is identified, we promptly take appropriate corrective measures and preventive measures against recurrence after investigating and reviewing the relevant facts. The Group executives or employees who committed the violation will be subject to disciplinary action in accordance with the rules of their Group company and the laws and regulations of the relevant country or region. The Board of Directors oversees the operation of the Group’s compliance framework, including the Global Compliance Code and the Global Anti-Bribery Regulations, and receives periodic reports on initiatives based on these frameworks from the Internal Control Committee.

Transparency in Relationships with Medical Institutions

At Sysmex, our opportunities to collaborate with healthcare professionals and medical institutions are increasing across various stages of our business activities—from research and development to production, sales, and customer care. It is therefore essential that we conduct our transactions with high ethical standards. Guided by the “Transparency of Relationships with Healthcare Professionals and Healthcare Organizations” section of the Global Compliance Code, we are committed to establishing and maintaining appropriate relationships with healthcare professionals and medical institutions and ensuring transparency in these relationships. Additionally, the “Global Regulations on Ethical and Transparent Interactions with Healthcare Professionals and Healthcare Organizations,” applicable to all Group companies, provide for topics such as specific banned activities, coordination among Group companies, provision of training, and management systems. Through these regulations, we promote efforts to build ethical and highly transparent relationships throughout the Group.
In Japan, Sysmex Corporation concurs with the philosophy of the “Guidelines on Transparency of Relationships between Corporate Activities and Medical Institutions” established by the Japan Association of Clinical Reagents Industries as a member company, and it discloses information regarding funding to medical institutions.
In countries and regions outside Japan, laws requiring companies to ensure transparency in their relationships with medical institutions (such as Sunshine Acts) and medical device industry codes have been enacted and are actively enforced. In compliance with the laws, regulations, and industry codes of each country and region, the Sysmex Group reports and discloses information on financial contributions to applicable medical institutions and other entities to the respective national authorities and industry associations as follows.

Research Ethics

Implementation of Appropriate Research and Development Activities

In the “Proper Research and Development Activities” section of the Global Compliance Code, Sysmex stipulates that it must be engaged in appropriate research and development activities while protecting the dignity and human rights of test subjects and complying with the relevant laws, regulations, and ethical guidelines of each country and region. Based on this, we promote our research and development activities with high ethical standards. We have also established the “Group Ethics Regulations on Clinical Research and Development” and a Research Ethics Examination Committee, which includes outside members such as legal and scientific experts, to review research content. The list of committee members and deliberation results are disclosed on our website to ensure transparency. Furthermore, in accordance with the “Guidelines for Responding to Misconduct in Research Activities” established by the Ministry of Education, Culture, Sports, Science and Technology, we have set up a Reporting Hotline for Misconduct in Research Activities.

Policy on Animal Testing and the Use of Genetically Modified Organisms (GMOs)

Sysmex conducts animal testing in compliance with the laws and regulations of each country and region, giving priority to the consideration of alternative methods to minimize the number of animals used while taking sufficient measures to reduce animal suffering. We also ensure strict adherence to relevant national and regional laws and regulations in the use of genetically modified organisms (GMOs) and implement measures to prevent their release in order to avoid adverse effects on biodiversity. These experiments are conducted in line with internal regulations that conform to applicable laws and guidelines. Our Testing Control Committee rigorously deliberates on all testing plans to ensure compliance with relevant regulations.

Applicable laws and guidelines include the following:
  • Act on Welfare and Management of Animals (Ministry of the Environment)
  • Standards Relating to the Care and Keeping and Reducing Pain of Laboratory Animals (Ministry of the Environment)
  • Fundamental Guidelines for Proper Conduct of Animal Experiments and Related Activities in Academic Research Institutions Under the jurisdiction of the Ministry of Health, Labour and Welfare (MHLW)
  • Guidelines for Proper Conduct of Animal Experiments (Science Council of Japan)
  • Act on the Conservation and Sustainable Use of Biological Diversity Through Regulations on the Use of Living Modified Organisms
  • Act on the Prevention of Infectious Diseases and Medical Care for Patients with Infectious Diseases
  • WHO Laboratory Biosafety Manual, 4th edition (2020)

Fair Marketing Activities

To ensure fair and proper competition in its global promotional activities, Sysmex has established an ethics code for marketing based on the “Antitrust/Anti-Competitive Behavior” section of the Global Compliance Code. We have also established the Global Regulations for Compliance with Competition Laws to ensure strict compliance with competition laws in each country and region.
For activities in Japan, we have formulated the Sysmex Promotion Code. In fiscal 2025, we held training sessions using case studies regarding the Promotion Code for 65 departments in our sales divisions and also conducted compliance training for general employees, striving to deepen their understanding and awareness.
In connection with an investigation by the Japan Fair Trade Commission (JFTC) into a suspected violation of the Antimonopoly Act, the commitment plan submitted by Sysmex pursuant to the Act was approved in February 2025. We are currently implementing this commitment plan steadily. Although this approval does not constitute a finding that we violated the Antimonopoly Act, we take seriously the fact that we were investigated by the JFTC on suspicion of a violation of the Act. Moving beyond the mere execution of the commitment plan, the Group is dedicated to further strengthening its compliance system, including strict adherence to the Antimonopoly Act.

Tax Policy

Sysmex has established a “Tax Strategy” in the Global Compliance Code approved by the President with the aim of increasing tax-related transparency. We appropriately pay taxes according to the spirit of the law, thereby contributing to the economic development of each country and region where we pay taxes. In transactions with foreign affiliates, we appropriately calculate transfer prices in accordance with the OECD Transfer Pricing Guidelines and the transfer pricing laws of the relevant countries and regions, ensuring proper tax payments in each jurisdiction. We do not transfer created value to low-tax jurisdictions, such as tax havens, solely to gain a tax advantage, nor do we engage in abusive tax planning that uses artificial tax structures lacking business substance or a genuine business purpose.
In addition, we disclose the Group’s corporate income tax payments in our securities reports and other documents, as well as the factors contributing to the difference between the effective and statutory tax rates.
The Internal Control Committee, chaired by the President, is our governance body responsible for overseeing sustainability-related risks and opportunities, including tax risks. Important matters related to such risks and opportunities are reported to and, if necessary, deliberated by the Board of Directors.

Tax Strategy in the United Kingdom

Respect for Intellectual Property

Sysmex requires all Group executives and employees to respect and appropriately handle the intellectual property rights of third parties, as well as its own intellectual property rights. This rule is stipulated in the “Intellectual Property Rights” section of the Global Compliance Code, and we work to ensure it is thoroughly disseminated. Furthermore, during new product development, our intellectual property, R&D, and business development divisions collaborate to conduct and discuss IP reviews from a global perspective.
We strive to maintain appropriate intellectual property management by identifying potential risks of infringing third-party IP rights and exploring ways to protect and use our own intellectual property.

Promotion of Security Trade Control

In the “Security Trade” section of the Global Compliance Code, Sysmex stipulates that it will comply with the export control regulations in each country and region and will not engage in transactions likely to impede the maintenance of international peace and security. We have established the Security Trade Control Committee, which is under the direct control of the President, to prevent illegal exports. We have also assigned personnel to overseas regional headquarters to oversee security trade control, bolstering our global operational structure. We continuously implement a variety of educational programs, including annual basic e-learning for all employees and seminars covering the latest global situation and regulatory requirements, to deepen understanding of security trade control and ensure strict regulatory compliance.