Code of Conduct

Supplier Code of Conduct

At Oresund Pharma, integrity, responsibility, and patient safety are the foundation of our business. As a pharmaceutical distributor, we play a critical role in ensuring that medicines reach healthcare providers and patients safely, efficiently, and in compliance with all
applicable regulations. This responsibility extends beyond our own operations to every
partner in our supply chain.

Our responsibility as a company also encompasses a responsibility to be a sustainable
actor in society; to demonstrate our respect and care for people and planet.

Our Supplier Code of Conduct sets out clear expectations for ethical and sustainable
practices, including human rights, labour rights, environmental responsibility, and business ethics. We count on our suppliers’ and business partners’ full cooperation to meet these requirements. Working together with transparency and accountability is critical to ensuring the trust of our stakeholders and maintaining the integrity of our operations.

International Frameworks

The requirements in this Code, including the applicable terms and concepts, are based on the UN Guiding Principles on Business and Human Rights, the OECD Due Diligence Guidance for Responsible Business Conduct, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, and the ILO Tripartite Declaration on Multinational Enterprises and Social Policy.

Scope

This Code applies to all suppliers to Oresund Pharma. Suppliers must ensure that these requirements are communicated and enforced with their own suppliers and partners throughout the value chain.

Follow Up and Audit

Oresund Pharma shall be allowed to conduct follow up activities in the supply chain, such as document review, worker dialogues and on-site audits, either through its own representatives or third-party auditors. Oresund Pharma expects first-tier suppliers to enable transparency across their entire value chain and to share information with Oresund Pharma upon request.

Any audits and inspections conducted by Oresund Pharma at the supplier’s subcontractors will becarried out in agreement with the supplier.

If deviations from this Code are identified, the supplier must take corrective actions. This includes ensuring that the supplier or their suppliers establish a Corrective and Preventative Action (CAPA) Plan and address the deviations within an agreed timeframe. Oresund Pharma will follow the process and verify that all deviations have been addressed.

In cases of unwillingness to cooperate or persistent non-compliance after the agreed action plan, Oresund Pharma reserves the right to terminate the contract with reasonable notice. If severe deviations are not addressed, Oresund Pharma reserves the right to pause or terminate the contract with immediate effect. Severe violations refer to forced labor, child labor, working conditions that endanger life, significant environmental damage, large-scale corruption, and attacks on environmental and human rights defenders.

Intentional breaches may result in the termination of all business relations with the company with immediate effect.

Legal Compliance

Suppliers shall comply with all relevant laws, both national and regional, in the countries
in which they operate, as well as relevant and applicable international regulations related to this Code. Where the requirements of this Code are stricter than local laws, the requirements of the Code shall apply

Due Diligence Process

The supplier must have a due diligence process in place to identify, prevent, mitigate and respond to potential negative impacts connected to this Code, that they cause, contribute to, or are directly linked to through their operations.

1. Human Rights

All internationally recognized human rights, as expressed in the UN Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the ILO Declaration on Fundamental Principles and Rights at Work, shall be respected.

2. Worker's Rights

2.1 Freedom of association and the right to collective bargaining must be respected
a) Workers, without distinction, shall have the right to join or form trade unions of their own choosing and to bargain collectively.
b) Employers must adopt an open attitude towards the activities of trade unions and their organizational activities.
c) Workers’ representatives must not be discriminated against and shall have access to carry out their representative functions in the workplace.
d) Where the right to freedom of association and collective bargaining is restricted under law, employers must facilitate and not hinder the development of parallel means for independent and free association and bargaining.

2.2. Employment must be freely chosen

a) There shall be no forced, bonded, or involuntary prison labor.

b) Workers shall not be required to lodge “deposits” or their identity papers with their employer and must be free to leave their employer after reasonable notice.

2.3. Unlawful child labor shall not be used

a) There shall be no unlawful child labor. Unlawful child labor refers to any work that is harmful to the intellectual, physical, social, and moral development of persons under the age of 18 and that undermines their education, deprives them of attending school,
constrains them to abandon schooling too soon, or requiring them to work and study
at the same time.
b) The employer shall develop or participate in, and contribute to policies and programs which provide for the transition of any child found to be performing child labor, to enable him or her to attend and remain in education until he or she is no longer a child.
c) A worker under the age of 18 may work if they meet the age requirements for the
specific type of work:

For general work, the minimum age is 15.
For non-hazardous work, the minimum age may temporarily be set at 14 in countries where the school-leaving age is below 15.

d) Persons under the age of 18 shall not be employed at night or in hazardous conditions.

2.4 No discrimination or inhumane treatment must be allowed

a)There shall be no discrimination in hiring, compensation, access to training, promotion, termination, or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership, political affiliation or any other characteristic.
b) Physical abuse or discipline, the threat of physical abuse, sexual or other harassment, and verbal abuse or other forms of intimidation must be prohibited.

2.5 Working conditions must be safe and hygienic

a) A safe and hygienic working environment must be provided. Adequate risk assessments and emergency plans shall be in place to ensure the safety of the work environment. Safety information relating to hazardous materials – including pharmaceutical compounds and pharmaceutical intermediate materials – shall be available and used to educate, train, and protect workers from hazards. Suppliers shall demonstrate good housekeeping practice and a culture of safety.
b) Workers shall receive regular and recorded health and safety training, which shall be repeated for new or reassigned workers.
c) Access to clean toilets and potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
d) Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
e) Responsibility for health and safety shall be assigned to a senior management representative.

2.6 Living Wages Shall Be Promoted

a) Wages and benefits paid for a standard workweek shall meet at least national legal standards or industry benchmark standards, whichever is higher. In any case, wages for full-time employees should always be sufficient to meet basic needs and provide some
discretionary income.
b) All workers shall be provided with written and understandable information about their employment conditions regarding wages before they enter employment and about the particulars of their wages for the pay period concerned each time they are paid.
c) Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

2.7 Working Hours Shall Not Be Excessive

a) Working hours must comply with national laws, collective agreements, and the provisions of b to f below, whichever affords greater protection to workers.
b) Working hours, excluding overtime, shall be defined by contract and shall not exceed 48 hours per week.
c) All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency, and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, recommended to be not less than 125% of the regular rate of pay.

d) The total hours worked in any seven-day period shall not exceed 60 hours, except where covered by clause e below.
e) Working hours may exceed 60 hours in any seven-day period only in exceptional circumstances where all of the following conditions are met:

this is allowed by national law;
this is allowed by a freely negotiated collective agreement with a workers’ organization representing a significant portion of the workforce;
appropriate safeguards are taken to protect workers’ health and safety; and
the employer can demonstrate that exceptional circumstances apply, such as unexpected production peaks, accidents or emergencies.

f) Workers shall be provided with breaks during the working day.
g) Workers shall be provided with at least one day off in every seven-day period or, where permitted by national law, two days off in every 14-day period.

2.8 Regular employment must be provided

a) To every extent possible, work performed must be on the basis of a recognized employment relationship established through national law and practice.
b) Obligations to workers under labor or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labor-only contracting, sub-contracting, or home-working arrangements, nor shall such obligations be avoided through the excessive use of fixed-term contracts of employment.

2.9 Complaints

Suppliers must establish and maintain documented procedures that allow employees to report complaints related to the requirements of this Code of Conduct confidentially and anonymously. These procedures should be easily accessible to all employees, including temporary workers, and communicated in an understandable way. Examples include a whistleblower system or equivalent reporting mechanism.

2.10 Product protection and quality

Suppliers shall ensure that management and security systems protect products, components and ingredients from the risks of adulteration, falsification, or theft for the purpose of illegal resale.

2.11 Process safety

Suppliers shall have management processes in place to identify the risks from chemical and biological processes and to prevent or respond to catastrophic release of chemical or biological agents.

3. Environment

3.1 Climate and environmental impact

a) National environmental legislation shall be followed.
b) Climate measures contributing to achieve national and international climate goals shall be promoted.
c) Suppliers shall strive for circularity, designing out waste, taking measures to improve efficiency and reduce the consumption of resources, including water, favoring renewable and sustainable sources. They shall also take measures to reuse and recycle.

d) No raw materials may be used from species listed in CITES or those categorized as critically endangered, endangered, or vulnerable on the IUCN Red List of Threatened Species.
e) Chemical use shall be controlled and evaluated. Where applicable, substitution and/or implementation of alternative processes shall be performed to reduce health and environmental hazards and improve resource efficiency.
f) Suppliers shall have systems in place to ensure safe handling, movement, storage, disposal, recycling, reuse, or management of waste, air emissions and wastewater discharges. Any waste, wastewater or emissions with the potential to adversely impact human or environmental health shall be appropriately managed, controlled and treated prior to release into the environment. This includes managing releases of active pharmaceuticals into the environment (PiE).
g) Suppliers shall have systems in place to prevent and mitigate accidental spills and releases to the environment and adverse impacts on the local community.
h) Suppliers shall have management processes in place to identify the risks from chemical and biological processes and to prevent or respond to catastrophic release of chemical or biological agents.
i) Strategies for efficient water use shall be promoted where applicable.
j) Emissions posing risks to health and the environment shall be reduced or eliminated.
k) Suppliers shall understand their impacts on biodiversity, reducing and mitigating their footprint wherever possible.

3.2 Environmental rights

a) Suppliers shall not infringe upon all peoples’ right to self-determination and to freely dispose of their natural wealth and natural resources. No people shall be deprived of their means of subsistence.
b) Illegal eviction or taking of land, forests, or water must not occur.
c) Indigenous peoples’ rights to lands, territories, and natural resources which they have traditionally owned, occupied, or otherwise used or acquired shall be respected, including the right to free, prior, and informed consent.
d) The right to a safe, clean, healthy, and sustainable environment shall be respected. This right is an integral part of the full enjoyment of the right to life, health, food, water and sanitation.

4. Ethitcs

4.1 Animal Welfare

Animals shall be treated humanely with pain and stress minimized. Animal testing should be performed after consideration to replace animals, to reduce the numbers of animals used, or to refine procedures to minimize distress. Alternatives should be used wherever these are scientifically valid and acceptable to regulators.

4.2 Data privacy & security

Suppliers shall safeguard and make only proper use of confidential information to ensure that company, worker, patient, subject and donor privacy rights are protected. Suppliers shall comply with applicable privacy and data protection laws and ensure the protection, security and lawful use of personal data.

4.3 Patient safety & access to information

Suppliers shall ensure that adequate management systems are in place to minimize the risk of adversely impacting on the rights of patients, subjects and donors, including their rights to health and to access information directly.

4.4 Conflicts of interest

Suppliers shall take reasonable care to identify, avoid, and manage conflicts of interest. Suppliers are expected to notify all affected parties if an actual or potential conflict of interest arises.

5. Business Ethics

5.1 Corruption, anti-competitive behavior, and taxation

a) Involvement in bribery, embezzlement, trading in influence, abuse of function, illicit enrichment, money laundering, concealment, or obstruction of justice shall not occur.
b) No agreements shall be entered with the intention of distorting competition or abusing a dominant position.
c) Tax arrangements shall be avoided if it is uncertain whether the arrangement is within the framework of the law.
d) Workers shall receive regular and recorded training on business ethics, such as an annual review of anti-corruption policies or the Code. Such training shall be repeated for new or reassigned workers.