Core Values Handbook

Better Health, Brighter Future

Our Core Values describe who we are, how we treat one another, and the way we conduct ourselves in the Company and in the community.

CORE VALUES INTRODUCTION

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INNOVATIONteamwork

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CORE VALUES INTRODUCTION

Our Core Values reflect our dedication to making a difference for our patients, their families and healthcare providers, and our commitment to creating sustainable value for our stakeholders. We understand that what matters most is how we live our Core Values. That is what this Handbook is for—to help us understand what it means to live our Core Values.

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CORE VALUES INTRODUCTION

Table of ContentsCore Values Introduction 1-3

Our Core Values 6-7

Introduction – Our Company Policies & Guidelines 8-9

Using This Handbook – Who to Contact 10-11

Living Our Core Values – Patients & Families 12-15

Living Our Core Values – Healthcare Professionals 16-17

Living Our Core Values – Scientific Integrity 18-19

Living Our Core Values – Our People 20-23

Living Our Core Values – Fair Competition & Insider Trading Avoidance 24-25

Living Our Core Values – Company Information 26-27

Living Our Core Values – Conflicts of Interest 28-29

Living Our Core Values – Intellectual Property & Record Keeping 30-31

Living Our Core Values – Anti-Corruption & Relationships with Governments 32-33

NORI- The Origin of our Corporate Philosophy 34-35

Elements of Our Corporate Philosophy 36-37

Our Global Mission /Vision 2020 38-39

About Vision 2020 40-45

Takeda-ism 46-47

CORE: Compliance Ownership Responsibility Ethics 48

TABLE OF CONTENTSTABLE OF CONTENTS

PASSIONTakeda’s drive comes from perseverance and a strong desire to contribute to patients.

TRANSPARENCYTakeda appropriately shares information and promotes dialogue with stakeholders, thereby building trust.

DIVERSITYTakeda respects and includes a broad range of peoples and ideas in its daily operations.

TEAMWORKTakeda builds strong borderless teams through fairness and promoting shared goals.

INNOVATIONTakeda implements bold initiatives on a daily basis.

COMMITMENTTakeda works to meet its responsibilities to stakeholders *on a daily basis.

OUR CORE VALUESOUR CORE VALUES

Each of us has the responsibility to read, understand and comply with this

Core Values Handbook.

Our Core Values

Our Company has a steadfast commitment to the highest ethical standards and to complying with all applicable guidelines and legal requirements. Our ability to uphold that commitment begins with our people. All employees and contractors of Takeda Pharmaceuticals International Co. (“Takeda”), have the responsibility to read, understand and comply with this Core Values Handbook, to complete assigned training related to the Core Values and to comply with legal and other requirements. The Core Values Handbook is also consistent with the principles and guidelines of the Takeda Global Code of Conduct. Please read the Handbook carefully, ask questions, and keep on asking until your obligations are clear. When finished, please complete the required certification on the Learning Management System. Continue to use the Handbook as a reference to help in living our Core Values every day.

By living our Core Values, we are embracing Takeda-ism. Takeda-ism represents the Takeda Group’s pledge to act with integrity at all times, especially when facing difficulties or challenges. Integrity refers to compliance with the highest ethical standards, fairness and honesty in conducting every activity and perseverance in pursuing ideal forms of our operations and management.

Through the demonstration of these qualities, we show both our commitment to building trust and confidence in all the people around us and our determination to continue to expand the business.

Our Core Values

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INTRODUCTION / Our Company Policies & Guidelines

RESPECT

INTRODUCTION / Our Company Policies & Guidelines

Continued importance of other Company policies and guidelines

The Core Values Handbook reminds us of many of the ethical and legal compliance requirements of our jobs, but it does not address every ethical, legal or compliance issue employees may face day-to-day. Consequently, this Core Values Handbook should be read and understood in conjunction with all of the Company’s policies, including the Employee Handbook, our Standard Operating Procedures, and the policies and procedures posted to the Company’s intranet site—sometimes referred to as the “portal.” And, of course, employees should raise any questions not addressed in the Handbook or in Company policies through one of the channels described on the “Who to Contact” page of this Handbook.

We will update the Handbook periodically and educate employees on the Handbook’s information. Like our Core Values, the information in this Handbook must be practiced— lived—for us to earn our stakeholders’ respect.

“As we transform, we must continue to center our actions and our decisions around Takeda-ism,

and put patients’ needs first.CHRISTOPHE WEBER

CEO, Takeda Pharmaceutical Company, Ltd.

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USING THIS HANDBOOK / Who to Contact

Our corporate compliance group will promptly review and investigate all reports of non-compliance or suspected noncompliance. We will take all good faith reports very seriously and we will take corrective action, if appropriate, in accordance with our policies and the law. Each employee is required to cooperate fully with the investigation of any alleged violations.

USING THIS HANDBOOK / Who to Contact

Each of us has an obligation to prevent and report actual or suspected violations of this Handbook and its underlying policies and laws.

Asking Questions, Reporting Concerns, and Seeking Guidance

EACH OF US HAS AN OBLIGATION TO PREVENT AND REPORT ACTUAL OR SUSPECTED VIOLATIONS OF THIS HANDBOOK AND ITS UNDERLYING POLICIES AND LAWS. THE PEOPLE LISTED BELOW ARE AVAILABLE AS A RESOURCE FOR QUESTIONS OR CONCERNS.

MANAGERSEmployees can begin by consulting the person who best understands their area of responsibility: their manager.

HUMAN RESOURCESFor issues concerning managers, or other employer-employee or organizational issues, employees may consult with Human Resources (see the Human Resources section of the portal, or call a Human Resources representative listed on the Company directory for more information).

LEGAL DEPARTMENTOur Legal Department provides guidance concerning laws and acceptable business practices; please refer to the Company directory for contact information.

CORPORATE COMPLIANCECorporate Compliance coordinates and monitors legal compliance activities across the Company. The Compliance group may investigate concerns or reports of wrongdoing, institute appropriate corrective actions, and help educate employees about our legal obligations. Please refer to the Company directory for contact information. Corporate Compliance may also be reached by email at CORE@takeda.com.

COMPLIANCE AND ETHICS HELPLINE (866-469-6566)

A worldwide, toll-free telephone number that is available 24 hours a day for use by employees who seek guidance on ethical, legal or corporate governance issues, or who want to report concerns regarding business-related conduct. Callers have the option of reporting concerns anonymously and may also listen to pre-recorded suggestions for enhanced ethical decision-making and behavior, or leave messages.

USING THIS HANDBOOK / Who to Contact

Our corporate compliance group will promptly review and investigate all reports of non-compliance or suspected noncompliance. We will take all good faith reports very seriously and we will take corrective action, if appropriate, in accordance with our policies and the law. Each employee is required to cooperate fully with the investigation of any alleged violations.

USING THIS HANDBOOK / Who to Contact

Each of us has an obligation to prevent and report actual or suspected violations of this handbook and its underlying policies and laws.

Asking Questions, Reporting Concerns, and Seeking Guidance

ALERTLINE (www.mpi.alertline.com)Employees, contractors and third parties may also report compliance and ethical concerns anonymously to the AlertLine. Employees may access the AlertLine through the Compliance and Ethics HelpLine or online at www.mpi.alertline.com. Please note that you may report concerns anonymously. We will respect the confidentiality of the identity of employees who do not remain anonymous, although Company policies or the law may in some circumstances require us to disclose this information.

POLICY AGAINST RETALIATIONThe Company prohibits any retaliation against employees who raise in good faith concerns about suspected violations of law. Under law and the Company’s policy, the Company may not discharge, demote, suspend, threaten, harass or in any manner discriminate against any employee, or the terms and conditions of his or her employment, because the employee reports a suspected violation of the law, Company policies or our ethical standards, even if a subsequent investigation proves the report to be unfounded. This protection extends to anyone giving information in relation to an inquiry conducted by the Company. Of course, the Company has the right to discipline anyone who knowingly makes a false accusation, provides false information, or otherwise acts improperly.

DISCIPLINEFailure to comply with the law, regulations or Company policies will subject employees to disciplinary action, up to and including termination of employment.

Your Responsibilities: (1) Live the Core Values and follow all policies; (2) Bring forward actual or suspected violations; (3) Cooperate fully in any investigations

The Company’s Responsibility: (1) Take all good faith reports seriously; (2) Take corrective action where appropriate; (3) Protect employees from any retaliation.

THE ETHICS “QUICK TEST”• How do I FEEL about this action? • Is this action the RIGHT THING TO DO – does it align with our CORE VALUES? • How would I feel if my MOST RESPECTED PERSON knew of my actions? • Would I behave differently if I knew my actions would be REPORTED in the newspaper?

Clinical Trials

Takeda is committed to making a difference in patients’ lives by developing breakthrough treatments for cancer. In working toward this goal, we place the highest priority on the safety of our products and product candidates and pay particularly close attention to safety considerations. We are especially sensitive and responsive to concerns related to the conduct of clinical trials and the company:

• Seeks to protect the dignity, privacy and safety of those participating in our clinical trials. • Maintains appropriate confidentiality of personally identifiable medical and genetic information. • Supports the process of informed consent and is cognizant of and responsive to circumstances that might impact this process. • Requires independent review and approval by groups unaffiliated with our clinical research (for example, institutional review boards, ethics committees, data and safety monitoring boards, and medical advisory boards) before and during company-sponsored clinical trials. • Commits that any clinical research undertaken by the Company or on its behalf is designed to advance human healthcare.

In conducting and sponsoring research, development, and post-marketing activities, we are committed to complying with all applicable ethical, professional and legal/regulatory standards, including Good Laboratory Practices, Good Clinical Practices and Good Pharmacovigilance Practices. Every employee and contractor must understand his or her responsibility for patient safety and product quality as further described in the Takeda Quality Statement, which is available on the Learning Management System.

Clinical trial registry and publication of results

We believe that patients, family members, health professionals, and members of the public should have access to medically important information on Takeda clinical research. We notify the public of the start of all Company-sponsored clinical research designed to test the safety or efficacy of our investigational and marketed products on ClinicalTrials.gov, a National Institute of Health registry of ongoing clinical trials.

We publish results of completed clinical trials of our marketed product in a timely, objective, accurate and balanced manner—regardless of outcome. Our policies on registering and reporting results from clinical trials are consistent with applicable laws, regulations and guidelines, including the Principles on Conduct of Clinical Trials and Communication of Clinical Trial Results promulgated by the Pharmaceutical Research and Manufacturers of America (PhRMA). We also support PhRMA’s Principles for Responsible Clinical Trial Data Sharing.

LIVING OUR CORE VALUES / Patients & Families

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LIVING OUR CORE VALUES / Patients & Families

PATIENTS

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LIVING OUR CORE VALUES / Patients & Families

Drug Safety

Takeda is committed to meeting our drug safety reporting obligations so that we may better understand our products and protect patients. All employees are required to understand our adverse event reporting policy and to report all safety or quality issues within one day of learning of the event. An adverse event is any untoward medical occurrence (such as signs, symptoms or illnesses) in a patient or clinical investigation participant administered a pharmaceutical product, whether or not the event is considered related to the pharmaceutical product. Employees must report this information whether or not they believe that someone else is also reporting the event to Takeda. All medical information inquiries, adverse events (AE) or product complaints (PC) for VELCADE, ADCETRIS, or MEPACT should be directed to the Dohmen call center at 1-866-VELCADE (1-866-835-2233). In general, safety issues that arise during the course of a clinical trial should be reported in accordance with the clinical trial protocol. However, employees who are not members of the clinical team should direct medical information inquiries, AE or PC for pipeline molecules to PPD at 1-877-TAKEDA7 (1-877-825-3327).

Company Education of Patients, Families and Caregivers

Company-developed education that focuses on the information needs of patients, families and caregivers can help to increase awareness of diseases and available treatments. That is also true for direct to consumer (DTC) print and media advertising and we support the PhRMA Direct to Consumer Guiding Principles. Consistent with those principles and Company guidelines, we seek to support patients, families and caregivers by developing education with goals that include:

• Increasing disease awareness

• Appropriately educating about treatment options

• Encouraging patients to contact their physicians and engage in a dialogue about health concerns

• Increasing the likelihood that patients will receive appropriate care for conditions that are frequently under-diagnosed and/or under-treated

LIVING OUR CORE VALUES / Patients & Families

All employees are required to understand our adverse event

reporting policy and to report all safety or quality issues within one

day of learning of the event.

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LIVING OUR CORE VALUES / Healthcare Professionals

In Our Interactions With Healthcare Professionals Across The World, We Are Committed To Following The Highest Ethical Standards, As Well As Complying With All Applicable Legal Requirements.

We have endorsed the PhRMA Code on Interactions with Healthcare Professionals and have developed policies and procedures to foster compliance with these standards. For example, the policies require that we:

• Not offer or give anything of value to healthcare professionals for prescribing or recommending the prescribing of any of our products. Kickbacks, bribes, rebates or any kind of benefits intended to induce prescribing are prohibited. • Have a legitimate business need and sign a written agreement with each healthcare professional from whom we obtain consulting or other services that reflects fair market value payment for services we receive. • Only provide items designed primarily for the education of healthcare professionals or patients. Gifts and entertainment may not be provided. • Promote our products in a manner that is balanced, accurate, not misleading and consistent with the approved product label and regulatory requirements. • Only promote our products for a specific use in a country after that country’s regulatory authority has authorized our company to market for that use. • Respect the confidential nature of prescriber data and use it appropriately to facilitate communications with healthcare professionals in a manner consistent with our policies.

LIVING OUR CORE VALUES / Healthcare Professionals

Ethical relationships with healthcare professionals are critical to Takeda and our reputation. We conduct a wide range of activities in the pharmaceutical marketplace, including research, development, education and marketing that are subject to a variety of legal and ethical standards, some of which are unique to the healthcare industry. In our interactions with healthcare professionals, we are committed to following the highest ethical standards and complying with all applicable legal requirements, including laws such as the Physician Payments Sunshine Act (Open Payments Program) which are intended to promote transparency regarding financial interactions between industry and healthcare professionals.

We are committed to complying with applicable

international legal requirements and industry codes, including the IFPMA’s Code of Pharmaceutical

Marketing Practices.1716

Our vision is to make a difference for our patients, their families, and healthcare providers, by developing medicines based on breakthrough science. Scientific research is fundamental to the growth and success of the Company.

To promote the integrity of our research, we take steps to:

• Manage potential conflicts of interest of researchers. • Prevent and deter scientific misconduct, such as fabrication, falsification, or plagiarism in proposing, conducting or reporting research. • Maintain accurate and comprehensive records of research and product testing, and report fully and accurately on the results of research, product trials and clinical trials as required by the appropriate regulatory authorities and professional standards. • Ensure that all Company publications follow the International Committee of Medical Journal Editors (ICMJE) guidelines on authorship and publication. • Respect the welfare of animals used for scientific research purposes. Takeda is committed to the “Three Rs” of biomedical research involving animals— Refining procedures, Reducing the numbers of animals involved in any procedure, and Replacing animals with non-animal models where appropriate. • We are also committed to manufacturing and distributing our products throughout our distribution chain in accordance with Good Manufacturing Practices and Good Distribution Practices.

LIVING OUR CORE VALUES / Scientific IntegrityLIVING OUR CORE VALUES / Scientific Integrity

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PEOPLETHIS HIGH LEVEL OF RESPECT FOR ONE ANOTHER ENTERS INTO EVERY ASPECT OF OUR DEALINGS WITH COLLEAGUES AND THOSE WE COME INTO CONTACT WITH IN EACH WORKING DAY, AND REFLECTS ON HOW OUR CORPORATE CULTURE IS PERCEIVED.

OURETHICAL PERSONAL CONDUCT AT WORK MEANS TREATING ONESELF AND OTHERS

WITH RESPECT AND FAIRNESS. WE ARE DEDICATED TO THE DIGNITY OF OUR PATIENTS,

AND WE OWE NOTHING LESS TO OURSELVES AND EACH OTHER AT WORK.

LIVING OUR CORE VALUES / Our People

Computers, Email and Internet

The Company encourages the use of its computer and related electronic resources to assist employees in accomplishing their work, and supports a working environment in which information is freely exchanged. We will protect the Company’s assets and only use company property in accordance with Company policy. Employees are encouraged to use their professional judgment and show respect for fellow Company personnel when utilizing these resources.

Employees are reminded that use of computers, email and Internet access must comply with Company policies and should be consistent with Company practices. In particular, employees should comply with the Company’s IT Acceptable Use Policy. Violation of Company policy or abuse of the privileges of computer/Internet/email use by any employee may result in disciplinary action. For more information on use of the Company’s computers, internal network and Internet access, see the Employee Handbook and the Information Technology section of the portal.

Health and Safety

The health and safety of each employee is our highest priority at work. Each employee must understand his or her responsibilities to abide by all safety rules and practices, taking the necessary precautions to protect him- or herself and coworkers, and reporting immediately any unsafe conditions, practices or accidents. Moreover, our program requires collaboration, not only among employees, but also with our vendors, outside experts, and government regulators. All of us must join together in promoting health and safety, and taking every reasonable measure to assure safe working conditions at the Company. More information on the Company’s health and safety policies and practices can be found in the Employee Handbook and on the Safety section of the portal.

Commitment to the Environment

We are committed to minimizing the environmental impact of our products and operations. Through a variety of initiatives, we will comply with all applicable legal requirements and Company policies concerning environmental protection and accident prevention in all our business activities.

Diversity

Takeda respects and welcome diversity. We are an equal opportunity employer and it is the Company’s policy not to discriminate against any employee or applicant for employment because of race, color, creed, religion, sex, national origin, age, medical condition or disability, sexual orientation, veteran status, or any other characteristic protected by law. More information on the Company’s equal employment opportunity/ affirmative action (EEO/AA) policies and practices can be found in the Employee Handbook (posted to the Human Resources section of the portal).

No Harassment or Creation of a Hostile Work Environment

It is the Company’s goal to promote a workplace that is free of sexual and other forms of harassment. Harassment of employees occurring in the workplace or in other settings in which employees may find themselves in connection with their employment, or behavior that would create a hostile work environment, is unlawful and will not be tolerated by this organization. The Company takes allegations of any form of harassment or hostile work environment seriously and will respond promptly to complaints of such behavior. Where it is determined that such inappropriate conduct has occurred, we will act promptly to eliminate the conduct and impose corrective action as necessary, including disciplinary action where appropriate. Any retaliation against an individual who has complained about harassment, a hostile work environment, or retaliation against individuals for cooperating with an investigation of a harassment or hostile work environment complaint is similarly unlawful and will not be tolerated. For more information about the Company’s policy, please refer to the Employee Handbook or contact the Human Resources Department.

LIVING OUR CORE VALUES / Our People

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LIVING OUR CORE VALUES / Fair Competition & Insider Trading Avoidance

Insider Trading

Employees having material, non-public information about Takeda or any other company obtained as a result of their employment with Takeda (e.g., a partner, potential partner or company with whom we are contemplating a material transaction) may not sell, purchase or otherwise trade in stock, derivatives or other securities of those companies to which the information is material, or disclose such material, non-public information to another person, including family and friends. Additionally, employees may not exercise any Phantom Stock Appreciation Rights granted under the Takeda Long-Term Incentive Plan, or any similar plan, while in possession of material, non-public information relating to Takeda.

Material, non-public information is defined as information that has not been publicly communicated and an investor would consider important in making investment decisions. It includes, for example, confidential information about financial or clinical trial results, plans for acquisitions, mergers, divestitures or joint venture transactions, senior management changes, significant litigation or regulatory proceedings, new products and expansion plans, significant product discoveries, or important agreements or contracts.

Insider trading may lead to civil and criminal penalties.

Antitrust and Competition Laws

The Company is committed to competing fairly in the marketplace by promoting adherence to all antitrust and fair competition laws. Most countries have antitrust or fair competition laws that prohibit certain practices that reduce competition or restrict trade. For example, we will not impose any resale price restrictions on wholesalers, distributors, licensees, sales agencies or other third parties if such restrictions would be unlawful. An employee’s violation of antitrust or fair competition laws and regulations could have serious consequences for the Company and for that individual.

We are committed to competing fairly in the marketplace by promoting adherence to all antitrust and fair competition laws.Consequently, our employees should not exchange information or make agreements with any competitor or potential competitor about prices, pricing policies, sales terms, inventory levels, business or marketing plans, or any other confidential matters related to the Company’s business. Employees who find themselves in a discussion or communication where the representative of another company begins to discuss one of these topics should stop the discussion or remove themselves from that situation and, in either event, report the discussion or communication to the Legal Department.

Please contact the Legal Department with any questions regarding the propriety of actions under the antitrust and fair competition laws or for more information on our policies concerning these laws.

Competitive Intelligence

We must be careful with how we handle information, data and/or knowledge concerning the current or proposed business activities of our competitors. We will only obtain such information using lawful and ethical methods—whether the information is obtained by the Company directly or through the use of an agent. In addition, we will not seek confidential information from other Takeda employees regarding their former employers.

Our employees may not directly contact any Company competitor in order to seek non-public and competitive information, as communication or exchange of such information directly with a competitor could result in violations of antitrust and competition law. Similarly, individuals may not use third parties to directly or indirectly contact any competitor without Legal Department approval. Please contact the Legal Department with any questions about the propriety of a source of confidential information, the method of gathering competitive intelligence, or the use of competitive information.

LIVING OUR CORE VALUES / Fair Competition & Insider Trading Avoidance

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Before discussing any confidential information with an outside person, always confirm that a confidentiality or similar agreement which clearly covers that confidential information has been signed by that person or their employer and that there is a bona fide need for the person to know the information. Within the Company, we will use our discretion and limit use of confidential information to legitimate business purposes in a manner that does not violate any of our contractual obligations.

We also respect the confidential information of third parties and we will only disclose confidential information obtained from third parties in compliance with applicable contractual requirements.

Personal Information and Data Protection

It is our policy to respect the privacy of “personal information.” Personal information is information that can be used to identify a specific individual by name, date of birth, or other description contained in that information. It can include information about employees, patients, clinical study subjects, doctors, employees of customers and others. We will comply with all applicable laws and regulations regarding protection of personal information. We will collect personal information only for legitimate business purposes and by lawful means, and will not disclose or use personal information for purposes other than a legitimate business purpose or as required by law. We will protect personal information by reasonable security safeguards against accidental loss or destruction or unauthorized access, use, modification or disclosure.

LIVING OUR CORE VALUES / Company Information

Confidential Information

During and even after employment, all Company employees and contractors must keep in confidence all Company confidential information, as required by the terms of the agreement signed by each employee at the time of employment with Takeda.

Confidential information generally means any non-public, scientific, technical, trade or business information possessed, obtained by, developed for, or given to the Company, which is treated by the Company as confidential or proprietary. It can also include public information that is presented in a context that imparts a special meaning that is proprietary to Takeda.

Confidential information should not be disclosed to any person within or outside the company who is not authorized to receive such information, and great care must be taken not to discuss such information in a manner or place where it may be overheard by others.

Public disclosure of Company publications and other information can only take place if the information has been approved through the Company’s online Request for Public Disclosure (RPD) process. Examples of publications for which RPD review is required include abstracts, posters or oral presentations to be presented at an outside venue, such as a scientific conference or academic lecture, and documents, such as manuscripts, intended for submission to a journal or other periodical.

LIVING OUR CORE VALUES / Company Information

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LIVING OUR CORE VALUES / Conflicts of Interest

Promptly disclose any relationships, gifts or other circumstances that could present a conflict of interest promptly disclose the situation to a manager and to the Legal Department before taking any action, then act according to their advice and in the best interests of the Company. In many cases, a conflict of interest can be managed if the conflict is disclosed in advance. Prior disclosure of actual conflicts or the appearance of conflicts will protect both the employee’s and the Company’s reputations.

LIVING OUR CORE VALUES / Conflicts of Interest

While we want to be free to make personal investments and enjoy social and business relations, we must not have any personal interests that conflict with those of the Company, or which might influence or appear to influence our judgment or actions in performing our duties. Employees should avoid any interest, investment or association that might interfere, or even appear to interfere, with the independent exercise of sound judgment in the Company’s best interest. To avoid situations that create a real or apparent conflict of interest, you must:

• Handle personnel issues impartially and fairly. Disclose to your manager or Human Resources any close relationship that could create the potential for an actual or perceived conflict of interest and do not give any advantage to an employee based on a personal relationship when handling issues such as recruitment, evaluation, transfer or promotion. • Disclose to your manager any material financial interest you or a member of your household have in a Takeda customer, competitor or company with whom we do business, or if you or a member of your household otherwise engage in the activities of such an entity. • Seek permission in advance to participate in any work outside of the company that is in the healthcare/pharmaceutical industry or is otherwise related in any way to the Company’s business. This would include, for example, service as a board member for a company or non-profit healthcare organization. All requests to participate in outside work must be reviewed and approved by your manager, Human Resources, and the Legal/Compliance Department. • Select suppliers and customers based on fair and objective standards and without favor or preference based on any personal relationship. • Not solicit any money, goods, hospitality, gifts or any other item of value from a supplier, customer or other third party with whom we do business. If you do receive a small gift or business courtesy from a company supplier, contractor, consultant or professional firm, you may accept it so long as: • the gift is not excessive; • you are not in the midst of a bidding or selection process involving that vendor or supplier; and • your acceptance of the gift will not influence your impartiality in the decision-making process. Examples of appropriate gifts from third parties include an occasional modest meal, a box of chocolates, or non-luxury tickets to a sporting event. Employees should always tell their manager about gifts or entertainment offered to them, no matter the value, and should consult with our Sourcing group whenever a gift or entertainment is offered by a vendor or supplier. If you have any concerns about the appropriateness of a gift, you should decline the gift or call the Legal/Compliance Department.

The purchase of gifts for third-party vendors or suppliers is discouraged. If it is necessary to purchase a gift, management approval is required prior to purchasing the gift.

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Record Keeping

Accuracy and reliability in the preparation of records is of the highest importance to Takeda. All records, expense reports, bills, payroll-related records, invoices, reports to or for government agencies, and other books, reports and records must be prepared with care and honesty and must be complete and accurate, best of the preparer’s knowledge. False or misleading entries in such records are not permitted and may be unlawful. Takeda will maintain internal control systems to monitor compliance with all recordkeeping policies and procedures and will not allow any fraudulent expense reimbursement.

All employees must ensure that corporate, legal and regulatory recordkeeping requirements, policies and procedures are adhered to at all times. Employees should ask their managers, department or group leaders to clarify the records retention policies and procedures for their area.

Contacts With The Media

The news media are important links to our internal and external audiences, including existing and potential customers such as partners and collaborators, patients, healthcare professionals, government officials, and the general public. What is said or written about Takeda can impact the Company’s reputation and value. Consequently, it is very important to direct any inquiries to Corporate Communications. Only those employees designated as spokespeople may speak for the Company. Please contact Corporate Communications with any questions about this policy.

We are also committed to making timely and accurate disclosure of material information to Takeda so that Takeda can comply with its disclosure obligations to investors.

LIVING OUR CORE VALUES / Intellectual Property & Record Keeping

Whether copying an article from a newspaper for use in a meeting; using third-party data found on the Internet in a presentation or research paper; or emailing colleagues content from an industry report, it is important to be aware of what is protected by copyright and what can be lawfully used.

Intellectual Property

All intellectual property owned, developed or obtained by the Company through research, development or other activities (including patents, designs, copyrights, trademarks, know-how, data and technical knowledge) are vital assets of the Company. We will carefully safeguard the Company’s intellectual property and fully protect the Company’s intellectual property rights. Takeda also respects the confidentiality and valid intellectual property rights of third parties and have processes designed to assure we avoid infringing the rights of others.

Whether copying an article from a newspaper for use in a meeting; using third-party data found on the Internet in a presentation or research paper; or emailing colleagues content from an industry report, it is important to be aware of what is protected by copyright and what can be lawfully used. In the United States, the law grants publishers, writers, other types of creators, and other types of copyright holders the exclusive right to reproduce, perform, distribute, translate and publicly display their original works. Unless a use meets one of the exceptions outlined in the Copyright Act, the copyright holder or its agent must grant explicit permission to reuse or reproduce a copyright-protected work.

Takeda has an agreement with the Copyright Clearance Center (CCC) that allows employee photocopying and electronic storage rights to certain copyrighted materials. More details about the CCC and its appropriate use may be found on the portal or by contacting Scientific & Competitive Analysis (“S&CA”).

LIVING OUR CORE VALUES / Intellectual Property & Record Keeping

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International Activities and Anti-Corruption

Our business touches lives around the globe. Certain standards apply to our international relationships and to transactions that cross international borders. Many healthcare professionals outside of the United States are employed by their governments, subjecting our relationships with them to additional scrutiny. Further, some countries prohibit bribery of private sector employees.

Takeda has adopted a Foreign Anti-Corruption Policy that prohibits corrupt activities or bribes of any kind. Employees must comply with all applicable legal requirements prohibiting bribery of domestic or foreign government officials or private sector employees, including the Foreign Corrupt Practices Act (FCPA) and must also ensure that those who act on our behalf, such as our agents, comply with the same. Specifically, employees and agents may not offer, give, promise or authorize the payment or gift of money or anything of value to any individual, including government or public officials either directly or indirectly to obtain, retain or direct business for Takeda or for any other inappropriate purpose. Where questions arise about the appropriateness of a particular activity outside the United States, employees should contact the Legal/Compliance Department.

In addition, every country, including the United States, has laws about importing and exporting goods, technology and other items. International organizations such as the United Nations and the European Union also regulate trade by member states. The Companyand its partners and representatives must comply with all applicable import and export control laws and regulations. The FCPA and import and export laws can be complicated to interpret; for more information contact the Takeda Boston Legal Department.

LIVING OUR CORE VALUES / Anti-Corruption & Relationships with Governments

Political Activities

In personal civic affairs, we must always make it clear that our views and actions are our own and not those of the Company. No corporate contributions for any candidate for any office can be made by or on behalf of the Company. Similarly, employees may not use Company resources to assist a candidate or political committee. The Takeda Pharmaceuticals U.S.A. Government and External Affairs group is responsible for any contacts with elected or appointed officials on a matter related to the Company’s business. For more information on the Company’s policies and procedures, visit the Company portal or contact the government relations point person for your site within the Company.

Interactions with U.S. Government Officials

There are strict limitations on payments to healthcare professionals employed or contracted by the government. Generally, all meals or gifts must not exceed $20 per employee and $50 from the entire Company in a single year. Some government agencies have more restrictive rules. Moreover, nothing of monetary value (including meals, entertainment or gifts) may be offered or paid directly or indirectly to any elected official, or any Federal, State or local government employee or contractor, unless specifically permitted by law or regulation. For questions regarding permissible gifts to government officials, please contact the Legal Department.

LIVING OUR CORE VALUES / Anti-Corruption & Relationships with Governments

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NORI- The Origin of our Corporate PhilosophyNORI- The Origin of our Corporate Philosophy

Our Corporate Philosophy

Our Corporate Philosophy was created in 2002 as a clear principle upon which all employees should act. It originates from the concept we call “Nori.” Nori was established in 1940 by Chobei V, the president of Takeda at that time. Chobei summarized values that had been cultivated in Takeda’s long history in a written form.

“Serve the public” demands a sense of social responsibility on the part of company management.

“Work together in harmony” calls for the constant cooperation of all members in a concerted manner.

“Make efforts to study deeply” requires originality and ingenuity, not only in research but in every aspect of our work.

“Esteem plainness” applies both to the conduct of our daily lives and to the allocation of limited resources.

“Observe propriety” posits respect for the individual and adherence to a strict code of business conduct.

The principles of “Nori,” which laid the groundwork for our current Corporate Philosophy, have been translated and paraphrased so that they can be shared globally.

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Elements of Our Corporate PhilosophyElements of Our Corporate Philosophy

MissionEmbodies the Takeda Group’s reason for being, sense of social responsibility, and defines our business domains.

We strive towards better health for people worldwide through leading innovation in medicine.

Vision 2020What we aspire to be by 2020, based on our Mission.

Takeda-ism and ValuesTakeda-ism is the unchanging set of Core Values that guides all our activities. We pledge to act with Integrity—comprising Fairness, Honesty and Perseverance—at all times, especially when facing difficulties or challenges.

In our day-to-day work, we focus on the following values while upholding the highest ethical standards:

For more than 230 years, we have been serving society with innovative medicines and helping patients reclaim valuable moments of life from illness. Now, with new healthcare solutions from prevention to care and cure, we are determined to help even more people enjoy their lives to the fullest.

We continue to transform the future of healthcare by unifying our strengths as “Global One Takeda.” We are a diverse organization committed to working with local communities to fully understand their needs and deliver industry-leading solutions with a sense of urgency, dedication and unparalleled efficiency.

Our passion for healthcare and commitment to improving lives will enable us to make the next 230 years healthier and brighter for people around the world.

• Transparency

• Passion

• Innovation

• Diversity

• Teamwork

• Commitment

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Vision 2020

Our Global Mission

The purpose of our existence is to work with medical professionals worldwide to provide better health for people through leading innovation in medicine.

As individuals involved in the global pharmaceutical industry, we pursue the unlimited potential of medicine. We combine all the resources and wisdom of the Takeda Group in order to achieve our goals.

Our Global Mission

What makes Takeda unique is that we put the happiness of patients and

people first. This is what has led us to prosper as a company.

YASUHIKO YAMANAKA Managing Director, Takeda Pharmaceutical Company, Ltd.

Vision 2020

This is one of the most exciting moments in Takeda’s history. Our globalization is progressing rapidly. Our portfolio has expanded to include innovative medicines as well as high-quality branded generics, life-saving vaccines,and OTC drugs. We now number 30,000 employees, united in diversity, and capable of truly great things.

These changes—and those to come in the future—have led us to ask ourselves a vital question: What kind of company do we aspire to be by 2020? Through several rounds of discussions, our Global Leadership Committee drafted a unified, company-wide vision that sought to answer the question.

Dialogue sessions engaged employees throughout our organization to gain feedback and additional insight. The result is Vision 2020, a set of guiding principles that aligns all our individual efforts toward a common goal. It recognizes that the diversity of thought, talent and approach we possess as a global organization is one of our fundamental strengths, and the means by which we will grow as a company. Vision 2020 celebrates our aspirations, both as people and as providers of solutions that improve health and promote happiness. It is the new energy that courses through Takeda, empowering everyone. Therefore, it is vitally important to understand it, and to embrace it as the very heart of our daily work as we move confidently into the future.

All of us are members of Global One Takeda. If we acknowledge our

differences, respect one another’s identities and values, and work openly and

honestly to deepen communication, we’ll generate synergy and create new value.

YASUHIKO YAMANAKA Managing Director, Takeda Pharmaceutical Company, Ltd.

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About Vision 2020

Our Business

Our Business explains the reason for everything we do: people who urgently need us.

Committed to Improving Health

With countless people in desperate need of new healthcare solutions, there’s no time to wait. That’s why we pursue innovative medicines as well as high-quality branded generics, life-saving vaccines, and OTC medicines – to help as many people as we can, as soon as we can.

About Vision 2020

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Vision 2020

Our Organization

Our Organization describes our organizational capabilities, and how they will help us achieve our goals.

Strength from Diversity

A common set of values, Takeda-ism, unites us as one. Using our diverse skills and ideas, we develop fresh solutions to meet the needs of people around the world. Each one of us is empowered to act swiftly and decisively in our quest to improve quality of life.

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Vision 2020

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Vision 2020

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Vision 2020

Our People

Our People focuses on our greatest asset, our employees, who are key to our growth as a company.

Powered by Passion

Our people are our greatest asset. Driven by passion to learn and contribute more, we embrace new challenges with confidence and open minds. We are determined to lead the change for a better world.

Teamwork, on the other hand, was one of our Values in the past, but we clarified its objective by adjusting the definition from “We act as a team, developing ties of mutual trust and respect” to “Takeda builds strong borderless teams through fairness and the promotion of shared goals,” in order to show more clearly how teamwork should be demonstrated.

Commitment and Transparency

Honesty can be realized when we meet our responsibilities to stakeholders on a daily basis (Commitment) and build trust by appropriately sharing information and promoting dialogue with them (Transparency).

Commitment means having the responsibility to accomplish something and pledging oneself to do so. To fulfill one’s Commitment, one must work on it wholeheartedly and earnestly, and this is nothing other than the quality of being honest.

To be honest, one must also have Transparency which goes hand in hand with appropriate information sharing and dialogue with the parties concerned.

Passion and Innovation

Perseverance can be realized if we have a strong desire yoked to a strong sense of mission and act it out (Passion), and also implement bold initiatives on a daily basis (Innovation).

Passion runs high when one has acquired a strong will to “strive towards better health for patients worldwide.” It is something that gushes forth when inspiring others and shooting for higher results and goals, as well as when making earnest efforts. Thus Passion is indispensable when attempting to realize Perseverance.

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TAKEDA-ISM

TAKEDA-ISM (Corporate Philosophy): We pledge to act with Integrity, Fairness, Honesty and Perseverance at all times, especially when facing difficulties or challenges.

MISSION: We strive towards better health for patients worldwide through leading innovation in medicine.

VISION: Innovation based on bold leadership in science and medicine resulting in the discovery, development and delivery of high-quality, differentiated products focused on patient needs.

A Culture based on good corporate citizenship that empowers employees through collaboration, inclusion, trust and timely decision making.

Sustainable Growth in corporate value by leveraging core therapeutic areas, and an industry-leading pipeline and product portfolio.

VALUES: Providing links between Takeda-ism (Integrity = Fairness, Honesty and Perseverance) and the Values, the diagram illustrates specifically how we should act and what principles and values we should uphold in our daily business in order to demonstrate the qualities that Takedaism represents.

Arranged in a circle in the diagram, each of the six Values is placed on the same level, i.e., no one value is considered more important than any other.

Diversity and Teamwork

We believe that Fairness can be realized if we respect and include a broad range of people and ideas in our daily operations (Diversity), and builds strong borderless teams through fairness and the promotion of shared goals (Teamwork).

Because of the recent changes in the employment environment, as well as our growing presence in one new market after another, it has become essential for our sustained growth to understand and respect the diverse ideas of people regardless of nationality, gender, age, or cultural background. Recognizing Diversity as a key value for our future, we have decided to include it in our new Values.

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Takeda Pharmaceuticals International Co.Cambridge, MA 02139Copyright © 2015, Takeda Pharmaceuticals International Co., All rights reserved. Printed in USA CC 4625