Ethical Marketing

Santen always acts ethically when engaging in marketing practices in accordance with applicable laws, regulations, and industry standards in our interactions with Healthcare Professionals(HCPs), healthcare organizations, patients and patient organizations.

The company has established Policies on the Ethical Interactions with Healthcare Professionals, Ethical Interactions with Patients and Patient Organizations, and Communications with Healthcare Professionals, which can all be found in our Santen Global Compliance Policy.

Our interactions with HCPs are for the purpose of enhancing the quality of healthcare and improving patient care with a global commitment to improving patient well-being by providing HCPs with information about the safety and efficacy of our medicines, clinical information, medical and educational information. To ensure the integrity of the information, Santen categorizes two types of communication, "Promotional Communications" and "Non-Promotional Communications” and manages each of them accordingly under strict requirements of Santen Global Compliance Policy, local laws and regulations.

"Promotional Communications" are disseminated by the commercial organization to inform HCPs of the safety and efficacy of our products only for use within the approved label. All marketing messages and materials are approved in accordance with defined procedures by promotional review committee members. Santen also provides ethical marketing training to all its employees of sales organizations annually. Additionally, in Japan, all sales and marketing employees annual performance rating incorporates compliance and code of conduct metrics when evaluating total performance.

"Non-Promotional Communications" cannot be promotional in nature and must only be disseminated by the medical departments that are held separate from the commercial department. Trainings on the Medical Science Liaison Standard Operating Procedures to define clear guidelines of separation/interaction between Medical and Commercial are delivered by Compliance and Medical Affairs. Non-promotional communications include Educational Communication (i.e., activities with the primary purpose to educate the public and/or HCPs about clinical data or scientific information), responses to off-label requests and Scientific Exchange (i.e., activities where the bona fide exchange of medical and scientific information is conducted in a non-promotional context). All such medical materials are also reviewed and approved in accordance with defined procedures by medical review committee members.

The presence or absence of upheld regulatory complaints concerning marketing and selling practices is disclosed in Governance Data.

The Company engages HCPs, HCOs, patients and patient organizations in a manner involving payments to them in the course of its business. To ensure transparency not to unlawfully influence their professional judgement, such engagement cay be made only when there is a documented legitimate business reason, with a contract for services (written agreement), using a company approved fair market value, subject to all local laws and regulations. All such engagements are reviewed and approved in accordance with defined procedures. In these contractual activities, Santen collects and discloses payments and other approved transfers of value provided to HCPs and HCOs in accordance with applicable laws, regulations and industry codes. In addition, Santen regularly trains employees of its sales organization in ethical marketing.