Code of conduct

Each of Norsk Pharma’s Business Partners, including but not limited to suppliers, distributors, agents, resellers, joint venture partners, customers and strategic partners, is recognized as an important member of the worldwide team contributing to Norsk Pharma’s success and responsible business conduct in line with our Mission, Vision and Values.

Norsk Pharma’s Code of Conduct for Business Partners applies to all individuals and companies with which Norsk Pharma has business relationships, regardless of their nature, type of transactions or duration. This includes companies of all legal types, ownership structures and jurisdictions in which they are incorporated.

Our goal is to develop relationships with Business Partners that share similar corporate values as Norsk Pharma, and conduct business in an ethical manner. This document outlines two types of business integrity standards: a) strict legal obligations for Norsk Pharma’s Business Partners, which comprise non-negotiable standards and regulations; and b) expected standards, which include desired standards that Norsk Pharma expects its Business Partners to implement. Norsk Pharma reserves the right to discontinue business relationships in case of material breaches of strict legal obligations and will address and support remediation with its Business Partners in case of breaches of expected standards. Norsk Pharma also reserves the right to audit or inspect Business Partners in relation to the obligations and expectations outlined in this document.

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Legal obligations for Norsk Pharma’s Business Partner

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1) General compliance

Norsk Pharma’s Business Partners shall comply with all applicable laws and regulations, including but not limited to items 2-8 below, in respect of our business dealings and notify Norsk Pharma in case of any suspected breaches, or any other non-compliance with the standards set out in this document, allowing for joint verification of facts. This applies to both Norsk Pharma’s Business Partners and their sub-contractors.

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2) Bribery and corruption

Norsk Pharma’s Business Partners shall uphold the highest standards of business ethics, respect local laws and not engage in any form of corruption, bribery, fraud, facilitation payments, kickbacks, illegal gratuities or extortion. Norsk Pharma considers facilitation payments as a form of corruption and has a zero tolerance policy for such payments.

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3) Money Laundering

Norsk Pharma conducts business with high integrity and within the limits of laws and regulations. We will not allow our Business Partners to condone or support money laundering in any form, in any location on behalf of Norsk Pharma.

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4) Fair Competition

Norsk Pharma strictly prohibits anti-competitive agreements or conduct, including fixing prices, restricting the supply of goods or services, bid rigging and market sharing. We require our Business Partners to commit to free and fair competition and to abide by relevant competition laws and regulations.

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5) Use of Products

In line with our strong commitment and adherence to applicable legal and regulatory obligations, Norsk Pharma will not tolerate the misuse of our products for illegal purposes. In our resolve to strengthen legal and regulatory frameworks, Norsk Pharma continuously raises awareness of its Business Partners to their obligations to have implemented adequate monitoring systems within their supply chains to ensure that misuse is prevented, or can be detected and remediated immediately.

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6) Child or Forced Labor

Norsk Pharma will not use or accept human trafficking, involuntary labor, bonded or forced labor or accept anyone do so on our behalf. Any use of child labor by Business Partners must comply with internationally recognized standards such as the guidelines of UNICEF, and the ILO, as well as local legislation.

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7) Discrimination

Norsk Pharma takes the issue of discrimination very seriously. We require that employees of our Business Partners be treated with respect and dignity, and that equality of opportunities are based solely on merit, irrespective of race, color, religion, gender, age, national origin, sexual orientation, marital status or disability. Norsk Pharma’s Business Partners must commit to creating a fair work environment and to abide by all applicable local laws concerning discrimination in hiring and employment practices.

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8) Safe and Healthy Work Environment

Norsk Pharma’s Business Partners shall provide a safe and healthy workplace in compliance with international standards and national laws to their employees and contractors.

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Expected standards for Norsk Pharma’s Business Partner

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1) General expectation

Norsk Pharma’s Business Partners are expected to uphold similar standards as set out in items 2-8 below and require the same from their own set of Business Partners, especially those that conduct business for Norsk Pharma.

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2) Business Gifts and Hospitality

Norsk Pharma’s main rule is that we prefer not to give or receive gifts. Norsk Pharma employees cannot give or accept gifts over the value of 75 USD without express written approval from their manager. Norsk Pharma employees will not seek to influence others or be influenced by others by giving or receiving gifts and/or hospitality.

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3) Freedom of Association & Collective Bargaining

Norsk Pharma expects its Business Partners to respect and uphold their employees’ right to freedom of association, involving trade unions or similar external representative organizations. Their employees should have the right to collective bargaining in accordance with applicable laws and regulations, and the right for employees to elect not to join a trade union or other representative body. Where these rights are restricted we expect our Business Partners to find alternative means for effective worker-employee collaboration

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4) Conflicts of Interest

Norsk Pharma expects its employees and Business Partners to immediately disclose and address situations where there is an actual, potential or perceived conflict of interest.

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5) Equal pay and working hours

Business Partners are expected to pay employees fairly for the work they perform, regardless of personal beliefs or any individual characteristics. Individual compensation for employees, consultants or contractors, shall only vary based on position, performance and competence. All compensation shall meet requirements of national minimum wage. Business Partners are also expected to abide by applicable laws and regulations on hours of work and rest periods.

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6) Indigenous peoples

Norsk Pharma expects its Business Partners to respect and prevent breaches to indigenous peoples’ rights. Indigenous peoples have the right to be informed and thereafter asked for their consent in decisions that may affect them.

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7) Protection of the environment and environmental impact

Business Partners are expected to operate in compliance with all applicable environmental laws and regulations. The use of environmentally friendly technologies, products and services are also expected, aiming at optimizing the use of natural resources, energy and water and minimizing negative impact to air, water and groundwater, soil, biodiversity and the climate.

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8) Sustainability

Norsk Pharma expects its Business Partners to adopt and promote sustainability principles and to comply with applicable environmental, social and governance (“ESG”) laws and regulations and to foresee any known or expected future changes in the requirements and take all reasonable actions to ensure compliance.

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9) Grievance mechanisms

Norsk Pharma expects its Business Partners to implement reporting mechanisms and processes for addressing grievances for workers and possibly affected stakeholders.