1. Basic Principles & Scope

We require relevant interests in research and business to be declared, avoid leaving decisions to interested parties alone, and take appropriate management and disclosure measures.

Declaring or disclosing an interest and managing its effects are separate responsibilities. Disclosure alone does not remove the need for review or recusal.

This Policy applies to Company officers, employees, and others involved in our research or business. External advisers, contractors, and research collaborators are asked to cooperate with declarations and checks according to their roles and contracts.

Collaborating universities and medical institutions apply their own rules. Our decisions and approvals do not replace their conflict-of-interest review, outside-activity procedures, ethics review, or other required steps.

2. Conflicts of Interest We Manage

A conflict of interest is a situation where financial or other interests may influence fair research or business judgment, or reasonably appear to do so. Corporate research funding or a researcher’s financial interest is not inherently misconduct.

We review actual problems, potential problems, and relationships that could reasonably raise external concerns.

Individual Conflicts of Interest

These may arise where compensation, shares or stock options, patent royalties, advisory fees, speaking fees, or other benefits received by officers or researchers could influence assessment of findings, selection of vendors, or contract terms.

We also review relevant interests involving spouses, parents, children, or others who substantially share financial benefits with the individual.

Organizational Conflicts of Interest

These may arise where rights in research findings, funding, or business interests held by the Company or another organization could bias evaluation, publication, or contract decisions.

Where an institution receives funds or has a business relationship, we make appropriate checks even if an individual researcher receives no compensation.

Conflicts of Commitment

Multiple roles at universities, medical institutions, companies, or other organizations may create incompatible duties involving work, time, information, or facilities.

We manage conflicts of commitment as well as financial interests. Kyoto University’s conflict-of-interest policy also distinguishes individual and organizational conflicts from conflicts of commitment.

3. Responsibility & Independent Review

The Company’s representative is responsible for establishing the structure and securing resources needed to implement this Policy.

A designated conflict-of-interest manager receives declarations, reviews cases, maintains records, and conducts periodic reviews.

Conflict-of-interest manager: Representative Director Fumihisa Kojima

If the manager or representative is personally involved in a matter, that person must not independently review and clear it.

Independence is determined by relationships, not titles.

We check a reviewer’s involvement in the matter, financial interests, family ties, concurrent roles, and ongoing business relationships.

Being outside the Company, an adviser, investor, or research collaborator does not alone establish independence.

If no suitable internal reviewer is available, we seek an independent lawyer, certified public accountant, or specialist in research ethics or clinical research. Fees paid to such experts are not contingent on a particular outcome.

If adequate independence or a suitable review process cannot be secured, we generally do not proceed with the transaction or research decision unchanged.

4. Declaration, Review & Management

Declare Before Involvement

Covered individuals declare relevant interests when joining, before taking part in a new study or transaction, and at least annually. Material changes in shareholdings, outside work, compensation, or contracts are reported promptly without waiting for annual review.

Declarations cover research funding, provision of goods, equipment or services, IP rights and income, roles in related companies, and family interests, as well as pay and shares.

Unlisted shares directly related to a project, concurrent officer roles, and family relationships are not excluded solely because a monetary amount is small. Specific scope and thresholds follow internal rules, applicable law, and collaborating institutions’ policies.

Do More Than Collect Declarations

The manager compares declarations with contracts, payment records, roles, and rights as necessary and assesses their effect on the matter.

Material cases undergo independent review to decide whether to proceed, add conditions, limit participation, or defer the matter.

Record & Revisit Management Measures

Measures may include changing reviewers, recusing interested persons from deliberations, independent analysis or evaluation, revising contract terms, and additional disclosure.

For each matter we record the basis for the decision, approver, conditions, and review date. Material changes in interests or study and transaction terms trigger reassessment as needed.

5. Relationships with Universities & Research Institutions

We respect academic independence and each institution’s procedures for research, outside roles, and conflicts of interest.

Kyoto University’s Department of Biocommunication Development is a Kyoto University research unit separate from the Company. Kyoto University’s official information identifies the Company as a research collaborator.

Collaborative research agreements and required procedures define objectives, roles, funding, use of facilities, samples and data, ownership of results, and publication.

Our funding does not give us authority over university hiring, degree review, research conclusions, or clinical decisions for participants.

When university researchers also serve as our officers or advisers, we cooperate with disclosures and outside-activity procedures at their institutions. Their universities’ conflict-of-interest reviews remain separate from ours.

We do not misuse supervisory or employment relationships to pressure students or early-career researchers into Company work, share purchases, confidentiality commitments, or assignment of rights. We work with universities to ensure collaborations do not unreasonably hinder publication or degree completion.

6. Transactions with Relatives, Concurrent Affiliations & Related Companies

We apply heightened scrutiny to the need for and fairness of transactions involving founders, officers, major shareholders, lead researchers, their relatives, or companies they manage or control.

Examples include commissioned research, software development, equipment purchases, management support, compensation, loans or guarantees, and IP transfers or licenses.

We assess the substance of the transaction, not just the relationship.

Before proceeding, we review business need, services or deliverables, the counterparty’s capability, price, alternatives, and benefit to the Company, and record the rationale.

Where comparable bids or market prices are unavailable, we document why and assess the scope, effort, expertise, and alternatives.

Being a related company or an early supporter is not by itself a reason to order work, pay, or transfer rights.

Interested persons do not independently complete review of their own terms. Material related-party transactions receive prior independent review.

Where a transaction is subject to Japanese Companies Act conflict-of-interest rules, we obtain the required shareholder or board approvals and make reports appropriate to our governance structure. An external expert’s opinion does not replace a legally required resolution or approval.

After contracting, we check delivery and performance against invoices and reassess fairness when terms change or renew.

7. Proper Handling of Research Funding, Fees & Support

We manage research funds, donations, service fees, speaking fees, and advisory fees according to their substance and purpose, not merely their labels.

Payments to universities and research institutions are distinguished from payments to individual researchers. We do not bypass institutional acceptance procedures by paying institutional costs into personal accounts.

Compensation must be reasonable for the work needed, expertise, effort, and deliverables. We do not offer money or benefits as improper inducements for prescribing, hiring, purchasing, referring participants, or producing favorable findings or publications.

For research funding and grants, we identify the purpose, contract terms, payer, and recipient and keep Company, affiliate, and university accounts and assets separate. We link contracts, invoices, payments, and work records to prevent duplicate or fictitious charges and use outside the approved purpose.

Deciding whether to continue research based on results differs from demanding a preferred conclusion. Development milestones must not undermine accurate reporting.

8. Integrity of Study Design, Analysis & Data

As a basic principle, we do not distort the collection, analysis, or interpretation of research findings to suit fundraising, partnership negotiations, patents, or commercialization.

At the start of a study, we define its objectives, primary endpoints, comparators, analytical methods, and responsibility for data management as appropriate to the research. We distinguish exploratory analyses from prespecified tests and record the reasons and timing of any changes to the plan.

We manage original data, samples and measurement conditions, analysis procedures, software and versions used, and change histories in a way that allows necessary verification.

Results that differ from expectations also inform decisions.

We do not conceal or arbitrarily exclude negative results, findings that could not be reproduced, or safety concerns because they may be unfavorable to the business.

Where exclusions or adjustments are needed, we record the scientific reasons so reviewers can assess them. For major development decisions, we seek review by independent assessors, statisticians, or other institutions as needed.

If the Company participates in study design, data collection, analysis, or manuscript preparation, we disclose its role. We do not claim to have provided funding only and had no role in the research when we were in fact involved. The recommendations of the International Committee of Medical Journal Editors (ICMJE) also emphasize disclosure of the funder’s role and access to data.

9. Research Involving People & Protection of Participants

When we participate in research involving people, we identify the type of study, where it is conducted, and our role, and manage conflicts of interest under applicable laws and ethical guidelines.

We distinguish clinical trials, studies under Japan’s Clinical Trials Act, and other life science and medical research, and confirm the required ethics and conflict-of-interest reviews, contracts, registration, reporting, and disclosure.

We accurately explain to research institutions our provision of funding, goods, equipment, and analytical support, as well as our involvement in the study, and cooperate in preparing any required conflict-of-interest management plan. Guidance on managing conflicts of interest under the Clinical Trials Act also addresses corporate contributions of funding, goods, and services.

In information provided to participants, we disclose the funder, relevant interests, and how the study is conducted, in accordance with applicable requirements.

We put participant safety and clinical judgment ahead of sales, fundraising, or enrollment targets. We do not link donations, investments, or product purchases to priority for study participation or treatment.

Depending on the nature and risks of the research, we ensure that safety assessment, efficacy evaluation, and analysis are sufficiently independent of those conducting the study.

10. Academic Publication & Intellectual Property

We seek to balance academic publication of research findings with the protection of intellectual property needed for practical application.

Collaborative research agreements specify procedures for review before publication, handling of confidential information, and review periods needed for patent filings. We do not refuse publication or unreasonably delay it solely because the conclusions are unfavorable to us.

We confirm that researchers can access the data needed for the agreed research and conduct scientific analyses and interpretations.

In papers and conference presentations, we disclose funding sources and authors’ relationships involving compensation, shares, positions, and intellectual property under the applicable publication standards. Disclosure of research funding alone does not satisfy all required conflict-of-interest declarations.

Authorship is based on actual contributions to the research and accountability for it. We do not add authors solely because of funding, position, or family ties, or improperly exclude contributors.

Providing research funding alone does not automatically transfer university research findings, patents, samples, or data to the Company. We confirm inventorship, ownership, and the scope of use, exploitation, and sublicensing under applicable law and contracts.

11. Disclosure of Research Funding & Other Support

We confirm our legal disclosure obligations and intend to voluntarily publish transparency information so people can understand our relationships with universities, medical institutions, and others.

We establish disclosure standards suited to our business, taking account of guidelines such as those of the Japan Pharmaceutical Manufacturers Association. This Policy does not indicate that we belong to any particular industry association or have been certified as meeting all of its standards.

What We Disclose

• Research & Development Funding
  Recipient organization, type of research, annual number of payments and amounts, and related information
• Donations, Research Grants & Conference Support
  Recipients, purpose of support, number of payments, amounts, and related information
• Fees for Speaking, Writing, Advising & Similar Work
  Type of work, number of payments, and amounts. Names of individuals and related details are handled under applicable law and appropriate procedures
• Provision of Goods, Equipment & Services
  Research-related support provided and its recipients. Nonfinancial support is also reviewed
• Support for Patient & Community Organizations
  Recipients, purpose, and an overview of financial and nonfinancial support

Where the law requires publication of additional details, such as a study identification number or principal investigator, we follow those requirements.

Timing & Method of Disclosure

We review the information for each fiscal year and, as a rule, publish it on this site within one year after that fiscal year ends. If the law sets a different deadline or period, we follow it.

When publishing, we state the period covered, how figures are compiled, whether amounts include tax, and the scope of disclosure. We distinguish total contract values, actual payments, and planned future amounts, and indicate categories in which no applicable payments were made.

Disclosure, Personal Information & Confidentiality

We obtain necessary consent and confirmation before disclosing personal information or confidential research information, and publish it only as legally permitted. Where details cannot be disclosed individually, we document the reasons and explain them through aggregated information where possible.

We do not omit legally required reporting or disclosure solely because of a confidentiality agreement or business considerations.

Publication of this Policy is separate from disclosure of actual funding information for each fiscal year.

12. Information for Shareholders, Investors & Business Partners

We distinguish established facts from plans when explaining rights, transactions, and development progress material to assessing the Company’s value.

In specific partnership or investment discussions, we provide documents needed to examine capital relationships, concurrent officer roles, material related-party transactions, agreements with universities and others, intellectual property ownership and license rights, and use of funds, as appropriate and subject to law, contracts, and protection of personal and confidential information.

When presenting research data and business plans, we distinguish results already obtained from data yet to be collected, rights secured from rights under negotiation, and signed partnerships from discussions.

We do not select only favorable information to give the impression that no material issues remain unresolved. If we become aware of significant findings or rights issues affecting continued development, we consider appropriate explanations to relevant parties.

For matters involving our investors or business partners, we do not offer favorable transaction terms or research assessments solely because of a capital relationship.

13. Raising Concerns, Investigation & Corrective Action

We receive questions and reports from officers, employees, researchers, business partners, and other stakeholders about undeclared conflicts of interest, improper transactions, interference with research findings, misuse of funds, or misleading disclosures.

We address anonymous reports to the extent that facts can be verified. We do not permit dismissal, contractual disadvantage, restrictions on research opportunities, harassment, or other retaliation for good-faith inquiries, reports, or cooperation with an investigation.

Those involved in a matter do not conduct its investigation alone.

If the representative, manager, or another relevant person is the subject of a report, someone independent of that matter participates in receiving and investigating it.

We limit access to a reporter’s identity and the contents of a report to those who need the information for the response. We do not impede reports made under law or legitimate consultations with universities, regulators, or other bodies.

If a problem is confirmed, we take appropriate corrective action, which may include changing personnel, suspending a transaction or study, reanalyzing data, settling funds, correcting information, or reporting to relevant institutions.

We record the causes, actions taken, and measures to prevent recurrence, as well as the investigation’s conclusion.

14. Training, Records & Periodic Review

We provide those covered by this Policy with information and training on conflict-of-interest declarations, related-party transactions, research funding, academic publications, and related matters when they join and periodically thereafter.

We manage declarations, supporting documents, review findings, approval records, contracts, payment records, published information, and corrective actions under retention periods set according to law, research and grant programs, and contracts.

At least once a year, we review declaration compliance, management of material matters, disclosures, and responses to concerns and corrective actions, and report to those responsible for management oversight. Matters concerning an oversight person are handled following independent review.

We revisit our management function and use of external specialists as the size of our business, clinical development, capital structure, and collaborative research arrangements change.

15. Status & Updates of This Policy

This Policy sets out our basic principles for managing conflicts of interest and transparency.

Individual studies and transactions remain subject to applicable laws, rules of universities and medical institutions, ethics review conditions, contracts, and our internal procedures. Publication of this Policy does not mean that review or approval of any individual matter has been completed.

This Policy does not mean that Kyoto University or any other research collaborator has approved or guaranteed our governance or all of our business activities.

We review the Policy as needed and announce revision dates and changes on this site.

Contact & Consultation

For questions or consultations about conflicts of interest, research funding, related-party transactions, or transparency disclosures, please contact us below.

Biozipcode, Inc.
Conflicts of Interest & Transparency Contact

General inquiries: +81-03-6821-7318

For your initial inquiry, describe the study, transaction, or published information concerned and briefly explain your question. Please do not send information that identifies patients or confidential materials obtained without authorization. Contact us first to discuss how to submit any necessary materials.

Ask About Conflicts of Interest & Transparency

Related Policies

For information about how we manage personal information, see our Privacy Policy.

For guidance on interpreting information about research stages, treatment effects, and approval status, see our Medical & Scientific Disclaimer.

For terms of use of published materials and general site use, see our Site Policy.

Established: September 1, 2026
Last revised: September 22, 2026