Code of Conduct 2017

CODE OF

CONDUCT

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AMBITION

RESPONSIBILITY

HAPPINESS

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CREDIBILITY

TABLE OF CONTENTS About the Icepharma Code of conduct

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Icepharma values

5

Communication with customers and partners

7

Community responsibility

11

Conflicts of interest

11

Legal environment

13

Confidential information and privacy protection

14

Archiving and handling of information

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ABOUT THE ICEPHARMA CODE OF CONDUCT

Icepharma operates in a competitive environment, where the expectations of consumers, suppliers and customers are increasingly demanding. The purpose of the Code of conduct is to establish firmly the policy that has been set within the company and make it clear to employees what is expected of them in their work. Icepharma employees enjoy the privilege and responsibility to maintain the company‘s reputation with their words and actions.

The Icepharma Code of conduct contains instructions that every employee must follow in communication with consumers, suppliers, customers and other stakeholder. Any breach of these rules, the policy of Icepharma or the law must be reported to the Quality Manager, the appropriate Division Director, the Managing Director or the Company Board, as appropriate.

Employees can be assured that such a notification, put forward in good faith, will have no undesirable consequences for the reporting employee.

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ICEPHARMA VALUES RESPONSIBILITY, HAPPINESS, AMBITION AND CREDIBILITY The operations of Icepharma are characterized by care for customers, employees, investors and the community within which the company operates.

To maintain this spirit, Icepharma relies on four values in its daily operations: Responsibility, happiness, ambition and credibility.

A clear code of conduct further corroborates the principles laid down by Icepharma. The company‘s employees are responsible for aquainting themselves with and implementing these rules, as well as the general laws and regulations governing their operating environment.

It can be helpful to answer the following questions before a decision is made: • Is it legal?

• Does it comply with general ethical standards?

• Can it withstand media/internet coverage?

• Will it enhance the reputation of Icepharma?

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We care for the projects we undertake We use company funds in a sensible manner

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We take responsibility for our decisions and actions

RESPONSIBILITY

COMMUNICATION WITH CUSTOMERS AND PARTNERS Icepharma puts emphasis on honesty, transparency and credibility in its relationships.

It is in the mutual interest of the company and its customers that the products and services offered always comply with quality requirements and the most stringent environmental standards, to ensure that neither people nor environment are harmed. Icepharma employees provide correct and reliable instructions to ensure the proper use of products and assist customers to the best of their ability.

Icepharma employees choose their suppliers in a fair and honest manner. The aim is to ensure that the products and services offered by the company are among the best available.

Icepharma employees respect the nature and seek to avoid wastefulness in their daily operations.

Icepharma employees are not allowed to receive payment from anyone involved in or seeking to do business with Icepharma. Receipt of gifts and participation in events for entertainment must be kept at a modest level and be part of a business relationship.

COMMUNICATION WITH GOVERNMENT EMPLOYEES AND OPINION LEADERS The operations of Icepharma rely heavily on communication with public authorities and the

company‘s employees are in regular contact with employees of public offices such as ministries and surveillance institutions. Icepharma also has considerable contact with influential people such as politicians, representatives of interest groups and others who can, due to their position, make or influence decisions regarding issues concerning Icepharma.

For simplification, Icepharma defines public servants as people working within the health care system, politicians and the employees of public institutions and committees. Communication with public servants and other influential individuals must always be conducted in such a way that there is no risk to the reputation of Icepharma or the individuals in question.

In their communication with public servants and other influential individuals, Icepharma employees must comply with the most stringent ethical standards as well as all applicable laws and regulations. If documentation is to be sent to public servants, e.g. in connection with tenders or marketing authorization of medicinal products, it must be detailed and comply with all requested criteria. It is under no circumstances allowed to offer financial support or payment to a public servant on behalf of Icepharma, except as payment for meetings and consultation, cf. the corresponding sections below.

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We put emphasis on a good atmosphere, happiness, respect and empathy

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We are genuinely interested in our customers and their wellbeing

HAPPINESS

We wish to contribute to increasing our partners‘ quality of life

MEETINGS AND HOSPITALITY Meetings arranged by the company must have a purpose and a clear educational content. The cost of such meetings must be modest and in accordance with the scope of the meeting.

Payments to speakers and moderators are permitted if it is justified and/or constitutes reimbursement of cost.

COMPLAINTS AND COMPLIMENTS Icepharma expects great demands and expectations from their suppliers, customers and consumers. Icepharma employees therefore need to deal with any obstacle and unexpected scenario with a positive mindset and in a polite and responsible manner, while seeing it as an opportunity to improve the company‘s services.

PRESENTS AND PAYMENTS No gift, money or benefits may be supplied, offered or promised to customers as an inducement to enter into business with Icepharma. Modest and inexpensive gifts, such as samples, may be given, provided it is appropriate and suitable for the occasion. Payments for consultation shall be in accordance with a written contract and the values of Icepharma.

Icepharma employees accept any compliment with a smile and use it as motivation for continued improvement.

ADVERTISEMENTS AND PROMOTION Advertisements and promotion are an important part in the operations of Icepharma. It must be honest and accurate, not misleading and comply with all valid laws. The purpose must be to make it possible for the recipient to form his own opinion of the product or service being advertised or promoted. It must be kept in mind that advertisements and promotion do not only build the image of the product in question, but also the reputation of Icepharma, as the company‘s views and performance in such matters may influence its future customer relations. As always, it is important to use Icepharma‘s values: responsibility, happiness, ambition and credibility as a guiding light in this context.

COMPETITORS Icepharma employees show respect for the company‘s competitors with their words and actions. They are not allowed to discuss prices, markups, markets or anything else concerning the products and services offered by Icepharma with the company‘s competitors.

Icepharma participates in an open and fair competition and complies with all current laws regarding competition in Iceland and any country the company conducts business in.

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We use our freedom and flexibility to act

AMBITION We put emphasis on correct and reliable information

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We wish to contribute to the success of our partners

COMMUNITY RESPONSIBILITY Icepharma is an active participant in the society with the products and services the company offers. Icepharma employees participate in discussions within the society in a responsible manner and with a positive mindset. The company supports charity organizations, sports organizations and patient organizations in accordance with ethical rules and recognizes their importance. Icepharma does not support political organizations.

CONFLICTS OF INTEREST Icepharma employees must avoid entering into commitments, connections or other behaviour which might constitute a conflict of interest with Icepharma. If this is unavoidable, the employee must report this to his line manager or the Managing Director as soon as possible.

A conflict of interest may for example arise when an employee puts his or her personal, social, financial or political interest above the company‘s interest.

If an employee is not certain whether a conflict of interest has been constituted, the Icepharma Quality Manager must be consulted before any decisions are made or measures taken.

It is Icepharma policy that the company‘s employees only work for Icepharma. Exceptions from that rule must be authorized by the Managing Director.

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We put emphasis on transparency and integrity We keep to facts and keep our promises

CREDIBILITY

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We act professionally in everything we do

LEGAL ENVIRONMENT In addition to this code of conduct, Icepharma employees who interact with companies and suppliers throughout the world, are in that context bound by the laws and regulations in the corresponding countries. In Iceland, Icepharma employees abide by valid laws and regulations, the Icepharma Quality Manual, EFPIA rules and contracts/codes of practice regarding communication with health care professionals and institutions.

By adhering to the most stringent standards and rules, Icepharma confirms its moral principles.

This provides the company with an advantage in competition and a positive image and enhances responsibility and credibility.

COMPETITION LAW Icepharma abides by the Competition Law and the principles of competition legislation, assuming: • that Icepharma employees understand the aims and purposes of competition legislation, which is the enhancement of active competition.

• that Icepharma employees understand the role of Competition Authorities and the scope of competition legislation.

• that Icepharma employees understand the basic rules of competition legislation and promise to abide by them in their work.

• that Icepharma employees promise to communicate with Icepharma‘s customers on business and legitimate grounds only.

• that Icepharma employees realize that breaching the Competition Law is a punishable offence which will lead to dismissal without a notice.

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CONFIDENTIAL INFORMATION AND PRIVACY PROTECTION Icepharma‘s confidential information is one of the company‘s most valuable assets, both because of its business importance and because of the effect mishandling of such information would have on the company‘s reputation.

Icepharma employees must ensure that confidential information is not disclosed to a third party. Confidential information includes technical documentation on products or processes, lists of resellers and prices, contract content, plans for cost, pricing or services, marketing plans, customer lists, unofficial financial data, information about company sales, mergers and acquisitions etc.

In gathering and handling of information, it is always important to comply with good business practice and ethical principles.

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CONFIDENTIALITY ACROSS DEPARTMENTS Icepharma employees must keep in mind that competition is not only between the company and outside competitors, but also between departments within the company itself. The same rules regarding confidential information therefore apply within each of the company‘s departments.

HANDLING OF PERSONALLY IDENTIFIABLE INFORMATION When working with personally identifiable information, the company‘s values must be used as a guiding light. Employees must preserve confidentiality and ensure that the information is handled in a fair and legitimate manner.

It is important that personally identifiable information is gathered for a clear and well defined purpose.

ARCHIVING AND HANDLING OF INFORMATION Icepharma archives all information used for business purposes within the company. Great emphasis is put on ensuring the safety of information, which is implemented by well defined access restrictions.

Icepharma information systems comply with ISO 9001 standards and are subject to routine audits. A document and project management system is in place to facilitate co-operation between employees and restrict access to business critical data.

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