Taisho Compliance and Ethics Whistleblowing Line

Who can use the Compliance and Ethics Alert Line?

This line is available to:

• All current and former employees of UPSA and the Taisho Group, as well as external personnel (intermediaries, consultants, service providers) and temporary staff.
• All current and former employees of any third party working with UPSA and the Taisho Group (suppliers, customers, etc.).

To ensure that every individual benefits from the necessary guarantees for fair handling of their alert, the Group’s Compliance and Ethics Alert Line is managed and maintained by an independent external company, DQ Helpline.
This system ensures the protection of the whistleblower, the safeguarding of their personal data, and, if desired, their anonymity.

What issues can be reported?

Through the Compliance and Ethics Alert Line, anyone can report inappropriate situations or non-compliance with procedures, laws, or applicable regulations in the following areas:

• Accounting or auditing matters;
• Corruption or bribery;
• Violation of anti-trust legislation;
• Conflict of interest;
• Discrimination; harassment (gender-based, sexual, or moral);
• Embezzlement; fraud;
• Violation of laws relating to environmental, health, or safety protection;
• Falsification or alteration of contracts, reports, or records;
• Data falsification or misuse;
• Insider trading;
• Acts of sabotage or destruction;
• Theft;
• Assault, intimidation;
• Conduct that violates the protection of whistleblowers or those who assisted them;
• Violation of internal rules and procedures leading to any of the behaviors listed above.

How to access the Taisho Compliance and Ethics Alert Line?

The platform is accessible online: https://i365.dqhelpline.com/taishopharma/upsa07509.
The service is available 24/7 in multiple languages, including French, English, Italian, and Spanish.

To log in, simply use the following common credentials:

• Username: alertUPSA
• Password: UPSA39466

Please note and carefully keep the code provided to you when your report is submitted (this code cannot be reissued or changed, as it is confidential and unique). It will allow you to track whether responses, updates, or requests for further details or additional information have been posted.

Non-retaliation policy

Whistleblowers cannot be sanctioned, dismissed, or subjected to discriminatory measures, directly or indirectly, for reporting a violation or situation in good faith and selflessly via this Compliance and Ethics Alert Line, even if the facts later prove to be inaccurate or result in no further action.

The same protections apply to facilitators or individuals linked to the whistleblower who have helped report and disclose information related to the alert (associations, unions, etc.).

However, misuse of this system may expose the individual responsible to disciplinary sanctions as well as legal proceedings.
Conversely, there is no obligation to file a report through the alert line, and no sanction can or will be taken against an employee who chooses not to use it.

What happens after a report is filed?

The whistleblower receives a unique code when submitting their report, which allows them to access the information provided and check whether responses, updates, or requests for additional details have been added.

Investigations are carried out confidentially and impartially. Depending on the nature of the report, investigations are conducted by Taisho’s Internal Affairs Department, UPSA’s Legal and Compliance Department, or UPSA’s Human Resources Department.

The number of individuals authorized to collect and handle these alerts is limited, and they are bound by strict confidentiality obligations. They only access information necessary for the performance of their duties and within the limits of their respective responsibilities.

The DQ Helpline system and, where applicable, UPSA’s Legal and Compliance Department or Human Resources Department communicate the results of the investigation to the whistleblower, along with the follow-up actions taken in response to the alert.

Confidentiality, anonymity, and data security

Collaboration with DQ Helpline ensures the confidentiality of the data collected and an objective, relevant handling of alerts.

When using the Compliance and Ethics Alert Line, if you wish, the DQ Helpline system can guarantee your anonymity.

For UPSA SAS, this line is compliant with the Sapin II and Waserman laws.
Data collected through the Group’s alert system is processed in accordance with the requirements of the European General Data Protection Regulation (GDPR).

All necessary measures have been taken to preserve the security and confidentiality of the data during collection, transmission, and storage. In line with applicable regulations, any individual may request access to and rectification of their personal data.
These rights can be exercised by email at: EUDPO@upsa-ph.com.