Code of Conduct

1. Introduction
Meribel Pharma Solutions is a major player in pharmaceutical subcontracting, operating in Sweden, France, Spain and the UK, and supplying medicines worldwide. We are committed to complying with the highest standards of regulatory compliance, business ethics, and social responsibility.

Our vision: To achieve exceptional service, continuously raising standards to new heights and contributing to positive change in worldwide healthcare for generations to come.
Our mission: To consistently deliver the highest quality solutions and service, enabling customers to scale new heights and improve patient health.

This Code of Conduct, and its underlying policies (which are available upon request), have been approved by the Board for circulation to all employees, and aim to ensure that all Group activities comply with applicable laws, regulations, and standards in the pharmaceutical industry, thereby ensuring patient safety, product quality, and the integrity of our organization.

2. Scope and Duty of Representation
This Code of Conduct applies to all employees, executives, and partners of the Group, as well as subcontractors and suppliers involved in our operations (« partners »).

As representatives of Meribel Pharma Solutions, all employees, executives, and partners are expected to uphold the company’s reputation and values in all professional interactions. This includes:
• Acting with integrity, professionalism, and accountability when representing the company in any capacity.
• Ensuring that all communications and external engagements reflect the company’s commitment to compliance, ethical business practices, and corporate social responsibility, as set out in detail in this Code.
• Maintaining a clear distinction between personal opinions and statements made on behalf of the company, particularly in public forums or social media.
• Adhering to internal policies and regulatory requirements when engaging with stakeholders, customers, regulatory bodies, and the general public.
Failure to uphold these principles may result in enforcement and/or disciplinary action, as outlined in Section 7 of this Code.

3. Compliance with International and Local Regulations
We are committed to adhering to the following regulations and we take a ‘zero tolerance’ approach to any breach of compliance of these laws:
• Anti-corruption laws and regulations (UK Bribery Act, French Sapin II Act, Foreign Corrupt Practices Act etc.).
• Export and international trade laws and regulations (sanctions, customs restrictions, etc.).
• Data protection and cybersecurity laws and regulations (GDPR and other applicable laws).
• Competition law / anti-trust laws and regulations.
• Tax and Financial transparency laws and regulations, including the prevention of Tax avoidance and money-laundering.
• Human Rights, Equal Opportunities and the prevention of underage working / Modern Slavery.
• Environmental Protection and Sustainability.
• Publicity and Social Media policy.

These are summarised in more detail in section 8 below and in the specific policies in Annexes 1 – 8 of this Code. Please review these carefully as they form part of this Code of Conduct.

4. Product Quality and Safety
We implement strict controls to ensure:
• Compliance of raw materials and finished products with quality standards, including Good Manufacturing Practices (GMP) issued by EMA, FDA, and other competent authorities, and all other EU, U.S., and other jurisdictional laws and regulations related to the manufacture and supply of pharmaceutical products.
• Serialisation and traceability of production and distribution.
• Effective management of product recalls if necessary.
• Transparency in communication with regulatory authorities.

5. Monitoring System and Reporting Violations
An internal audit and monitoring program is implemented to ensure compliance with this policy.
We provide a confidential and independent ‘whistleblowing’ hotline to enable everyone to speak up, without fear of recrimination, in the event that they suspect any violation or suspected non-compliance with this Code of Conduct, or any of its associated policies. Any concerns or suspicions should be reported through our confidential whistleblowing hotline (https://meribelpharma.com/reporting-hotline).

6. Training and Awareness
As part of our commitment to compliance, and the continuous training and education of our staff, all employees will receive regular training on compliance requirements and best practices. We also offer tailored support and training upon request or as needed.

7. Implications and sanctions for Non-Compliance
Any violation of this Code of Conduct will be investigated fully and may result in disciplinary sanctions in relation to employees (up to and including termination and legal proceedings if necessary) and enforcement action in relation to partners.

8. Overview of the individual policies in Annexes 1 – 8 of this Code of Conduct
8.1. Business Ethics and Anti-Corruption Laws
As set out in the policy at Annex 1, the Group strictly prohibits any form of corruption, bribery,
inappropriate gifts, and conflicts of interest. Our employees must:
• Report any attempt of corruption or fraud.
• Exercise caution when dealing with any public official or Governmental officer.
• Not accept or offer advantages that could influence a business decision.
• Comply with rules on interactions with healthcare professionals and regulatory authorities.

8.2 Trade Laws
As set out in the policy at Annex 2, we ensure that all our employees and agents, and our business transactions with partners, comply fully with export and international trade laws and regulations, including sanctions, customs restrictions, etc. Our employees must:
• Verify each new customer or partnership to ensure that it is fully compliant
• Keep informed of sanctions, export controls and international restrictions and consult the Legal department if they have any questions or concerns.

8.3. Competition Laws
As set out in the policy at Annex 3, we ensure that all our employees and agents, and our business
transactions with partners, comply fully with applicable Competition / Anti-Trust laws. Our employees must :
• Understand the competition law prohibitions on (i) anti-competitive arrangements between companies/undertakings (Article 101 of the EU Treaty, Chapter 1 Competition Act 1998) and (ii) abuse of a dominant position (Article 102 of the EU Treaty, Chapter 2 CA1998)
• Avoid direct contact with competitors (actual or potential) and exercise caution and restraint in relation to competitors at any industry conferences
• Avoid prohibited arrangements and consult the Legal department if they have any questions or concerns.

8.4. Data Protection, Confidentiality & IP
As set out in the policy at Annex 4, we ensure the confidentiality of sensitive data, including patient, customer, and employee data, in accordance with applicable legislation (GDPR and international equivalents) and we must protect the confidential information and intellectual property of our Group and our customers. Our employees must :
• Understand the international protections on the use of personal data
• Avoid the unnecessary recording of sensitive data and avoid transmitting personal data outside of the EU and UK permitted regions.
• Protect the confidential information and Intellectual Property of the Group and our customers.

8.5. Tax and Financial Transparency
As set out in the policy at Annex 5, we ensure that all our employees and agents, and our business transactions with partners, comply fully with applicable financial, accounting and tax laws. Our employees must :
• Ascertain the source of all funds received by the Group
• Ensure that all applicable Tax laws are fully complied with

8.6 Employee/Human Rights and Social Responsibility
As set out in the policy at Annex 6, we guarantee a safe and respectful work environment, upholding human rights:
• Prohibition of modern slavery, forced labor and child labor in our organisation and throughout our global supply chain.
• Promotion of diversity, inclusion, and equal opportunities.
• Compliance with occupational health and safety standards.

8.7 Environmental Protection and Sustainability
As set out in the policy at Annex 7, we are committed to sustainability and reducing our environmental footprint. This is also extremely important to our customers and we are often required to report upon our progress. We establish targets and processes to reduce our greenhouse gas emissions and our carbon footprint each year, and we comply with all applicable laws and regulations regarding waste materials from our facilities. We encourage our employees to continue to explore and identify ways in which these ESG initiatives can be developed. For example, a number of our facilities have already switched fully to green electricity.

8.8 Publicity and Social Media
As set out in the policy at Annex 7, because we are part of the highly-regulated healthcare industry, we cannot engage in sensitive topics or talk about any pharmaceutical products or other health treatments on our social media or web pages. Our employees should follow these 4 simple rules in relation to any publicity or use of social media:
• keep comments on topic
• be constructive/positive
• do not disclose any confidential information (of our company or our partners)
• do not post comments on political and/or sensitive issues from a social media account where you are named as an employee of the Company and may therefore appear to be representing the Company.
We do not endorse information and opinions shared by social media users and they do not represent our views.

9. Updates
This policy will be reviewed regularly and adapted to legislative developments and industry best practices.
Date of Issue: 14 April 2025
Annexures :
1. Business Ethics and Anti-Corruption policy
2. Sanctions, export and international trade policy
3. Competition law policy
4. Data Protection, Confidentiality & IP policy
5. Tax and Financial Transparency policy
6. Employee/Human Rights and Social Responsibility policy
7. Environmental Protection and Sustainability
8. Publicity and Social Media policy