Biomedica Code of conduct

Effective date June 12, 2023

Purpose

The Code of Conduct is our guide to doing the right thing and to help us to observe highstandards of integrity and honesty, acting with care, diligence, and fairness in all businessactivities.

Scope

Every person conducting business for Biomedica worldwide must follow and employ reasonablesteps in preventing violations of this Code of Conduct, together with all applicable laws andcompany policies. This includes all staff and levels of management as well as consultants,external workers, secondees, and temporary workers. This Code of Conduct also applies to allBiomedica locations, affiliates, and subsidiaries. In some countries, due to local laws orbusiness requirements, the policies discussed here may be supplemented by additional policiesor standards to address local requirements.

One of your responsibilities is to follow the law and Biomedica policies as you conduct businesson behalf of Biomedica. While this Code of Conduct has been written to familiarize you withmany of the policies that apply at Biomedica it does not supersede them or act as a substitutefor reading each policy, SOP and process that applies to your specific job, no written policy orcode on its own can guarantee compliance with the law or ethical decision-making. Each of usmust do our part.

Term and Termination

Access to medicines

Many people still lack access to medicines and healthcare. As the size and complexity of theworld’s healthcare challenges continue to grow, our commitment is to extend access to themedicines for underserved patient populations.

We address the unmet needs of global patients by deploying our distribution infrastructure andnavigating complex regulatory environments to supply unlicensed medicines via named patientprograms for unlicensed medicines and represent specialty medicine biopharma companies inkey emerging markets through licensing and partnership agreements for licensed medicines.

Anti-corruption

We prohibit bribery and corruption. None of us or anyone acting on our behalf may offer or paya bribe, kickback, or other improper payment. We are also not allowed to provide anything ofvalue that is intended to win business, improperly influence a decision, or gain an unfairbusiness advantage – or even appear to do so. We are committed to comply with the letter andspirit of the United States Foreign Corrupt Practices Act (“FCPA”), UK Bribery Act and their localequivalents in all the countries where Biomedica operates.

Anti-trust, Unfair Competition

Competition drives innovation and leads to greater choice of higher quality products atcompetitive prices, benefiting patients and society. We conduct our business to serve theinterests of Biomedica and our customers in manner that doesn’t unfairly restrict trade andwithout anti-competitive understandings or agreements with competitors.

Business continuity and crisis management

As a distribution company we are committed to ensure uninterrupted supply of key products andservices to patients. We will take all reasonable precautions to protect patients, associates,assets, and the business from a disruptive incident.

Conflicts of interest

Conflicts of interest arise when we place personal, social, financial, or political interests beforeCompany’s interest. Members of our Companies’ management teams and employees areresponsible for avoiding situations that present – or create the appearance of – a conflictbetween their interests and those of Biomedica. Whether on the job or in our private life, nothingshould conflict with our responsibilities to Biomedica. We will disclose and manage potential, perceived, and existing conflicts of interest.

Customs and trade compliance

We comply with customs regulations, export controls and trade sanction laws. It allows us todeliver our medicines in a timely manner to patients who need them. We ensure that we do notengage with persons or companies that have been placed by governments on sanctioned partylists. We comply with regulations and laws that govern the distribution and use of our productsin markets in which we operate.

Data privacy

Biomedica is committed to collecting and keeping only personal information that is legitimatelyneeded to carry out our business, and to implementing measures designed to protect thatinformation. We collect, use, and retain personal information only to the extent we need it forlegitimate business, human resources, or scientific purposes, or as otherwise required byapplicable laws.

Drug safety

Medicines and treatments can have potentially undesirable effects. Reporting those adverseevents is critical to take appropriate actions to safeguard patient safety. To follow strict safetymonitoring and evaluation processes at every stage of the product lifecycle we report adverseevents within 24 hours of discovery to our pharmacovigilance employees and quality complaints to quality assurance, and then transparently communicate the risks of the medicines toregulatory authorities and our partners if applicable.

Fair employment practices, diversity, and inclusion

We create a safe place to work, where all our associates have an equal opportunity to succeed.We do not tolerate discrimination, harassment, retaliation, bullying or incivility. We value thecontributions of all our associates and encourage them to express themselves and theiropinions freely in a professional way. We educate our people on inclusivity and provide allassociates with equal opportunities to contribute to our company and advance their careers.

Financial integrity

We maintain accurate and complete financial records, and make full, fair, accurate, timely, andunderstandable disclosure in reports and documents that we file with government regulatorybodies or otherwise make publicly available.

Interactions with Healthcare Professionals and Healthcare Organizations

Biomedica interacts with healthcare professionals and healthcare organizations in a variety ofcontexts. Biomedica committed to comply with all applicable laws and regulations and industrystandards and to adhere to the highest standards in its marketing, promotional and educationalactivities. In general, any payment or benefit provided to a healthcare professional, orhealthcare organizations must comply with the standards that are defined in Biomedica Policyon Interactions with Members of the Health Care Community.

Interactions with Business Partners and Third-party management

We select the parties best suited for our business and society based on objective criteria,evidencing their competence, integrity, and other relevant merits. We conduct business withindividuals and organizations who share our values and commitment to high ethical standards.We strive to ensure that throughout our relationship, the third party continues to uphold thesame standards. We follow our comprehensive due diligence program and procurementprocess to choose the best partners in the markets where we operate.

Disciplinary Action

Failure to comply with the Code, Biomedica policies, or applicable law will subject staff todisciplinary action up to and including termination of employment, to the extent permitted bylocal laws. Disciplinary action may also be taken when managers ignore misconduct or fail tocorrect it. Managers must also ensure their teams are educated on the standards of businessconduct, promote compliance, prevent violations, supervise, and guide subordinates regardingstandards, and create a culture that encourages staff to voice their concerns. In addition,Biomedica may terminate the services or work engagement of non-employees who fail tocomply with the Code, our policies, and applicable law.

Reporting obligations

Employees who believe their conduct or the conduct of the fellow employee, partner or thirdparty may have violated desired behaviours or any other Code of Conduct provisions, have anobligation to report it.

Employees should report concerns about any potential misconduct or unethical behaviour to the following email address: complianceteam@biomedica.bio

Third party Representatives are expected and encouraged to seek guidance, raise concernsand to contact Biomedica to ask questions and/or report concerns to the following e-mailaddress complianceteam@biomedica.bio about any potential misconduct or unethicalbehavior by Third Party Representatives, Biomedica or their affiliated parties.

Biomedica is committed to non-retaliation and will maintain appropriate confidentiality andanonymity with respect to all disclosures.

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