Basic Policy on Fraud Prevention

Based on the guidelines (implementation standards) for the management and auditing of publicly funded research at research institutions, PtBio Inc. has formulated the following basic policy on fraud prevention, and operates and manages competitive research funds and similar funding accordingly.

1. Clarifying Lines of Responsibility

The following officers are designated as responsible for the operation and management of competitive research funds and similar funding:

1. Chief Administrator: Representative Director
2. General Manager: General Manager of the Corporate Planning Department
3. Compliance Promotion Officer: General Manager of the Research & Development Department

In addition, the Company’s Audit & Supervisory Board Member reviews the state of internal controls for fraud prevention from a company-wide perspective and provides opinions accordingly.

2. Developing an Environment That Forms the Basis for Proper Operation and Management

To develop an environment that forms the basis for proper operation and management, the Chief Administrator carries out the following initiatives:

1. Conducting compliance education and awareness activities (raising and spreading awareness among stakeholders)
2. Clarifying and standardizing rules
3. Clarifying the scope of authority for each role
4. Establishing and operating transparent rules for handling reports, investigations, and disciplinary action

3. Identifying Factors That Give Rise to Misconduct, and Formulating and Implementing a Fraud Prevention Plan

To encourage voluntary efforts among stakeholders and prevent misconduct from occurring, we identify the factors that give rise to misconduct and formulate and implement a concrete fraud prevention plan, through the following initiatives:

1. Establishing a person or department responsible for promoting the fraud prevention plan
2. Identifying the factors that give rise to misconduct, and formulating and implementing a fraud prevention plan

4. Appropriate Operation and Management of Research Funds

Based on the fraud prevention plan, we execute budgets appropriately. We also retain documents, data, and other records related to the execution of research funds for a defined period so that they remain available for later verification.

5. Promoting Information Disclosure and Sharing

We have established the following point of contact to receive inquiries from both inside and outside the Company regarding the rules for using competitive research funds and similar funding. We also make our basic policy on fraud prevention publicly available.

(Contact point) Corporate Planning Department

6. Monitoring

To minimize the possibility of misconduct occurring, we develop and implement an effective monitoring framework from a company-wide perspective, and continuously work to enhance and strengthen organizational checks and balances.

Established November 1, 2023
PtBio Inc.
Keisuke Okuhara, Representative Director and CEO