BeiGene
Code of Conduct

Effective December 2021

BEIGENE CODE OF CONDUCT > CONTENTS

Contents
Commitment to Integrity
Company Values
A Culture of Quality and Excellence
Purpose and Scope of the CodeOur Responsibilities
Seeking Guidance and Reporting Concerns
Confidentiality
Investigative Process
Non-Retaliation
Disciplinary Action
Integrity in the Marketplace
Compliance with Laws and Regulations
Interactions with Healthcare Professionals
Interactions with Healthcare Professionals Who
May be Considered Government Officials
Interactions with the Patient Community
Safety Monitoring and Adverse Event Reporting
Quality, Manufacturing, and Supply Chain
Anti-Bribery and Anti-Corruption
Anti-competition
International Trade Controls
Political Activities
Responsibilities in the Workplace
Diversity and Inclusion and Equal
Employment Opportunity
Anti-Discrimination and Anti-Harassment
Environmental, Health and Safety
Substance Abuse
Conflicts of Interest
Gifts, Gratuities, and Entertainment
Corporate Opportunities
Company Information Technology Assets
Confidential Information and Intellectual Property
Commitment to the Company and Our Shareholders
Integrity of Books and Record Keeping
Record Retention
Securities Trading
Privacy and Data Protection
Scientific Integrity
Social MediaMedia, Investor or Other Public Inquiries
Cooperating with Government Investigations
Code Dissemination, Amendments, and Waivers
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BEIGENE CODE OF CONDUCT > COMMITMENT TO INTEGRITYA Message from Our Founders

Dear BeiGene team,Not long ago, we set out to build a fully-integrated,

Please take time to review the Code and familiarize

global biotechnology company committed to

yourself with its contents so that you may refer to it

innovation in drug development and improving

whenever you have a question. Much of the Code’s

patient access to medicines. As we continue to growrules and principles reflect practical common sense to

our organization, it is critical that we formally reinforce

help you in your decision-making process. Nonetheless,high global standards for how we conduct our

if you are unsure about the right course of action or if

business activities and interact with each other andyou have concerns about activities or behaviors that

our external stakeholders.

you believe may be inconsistent with the Code, we

Our Code of Conduct (the “Code”) helps us to achieve
those standards by providing common rules, principles,

encourage you to consult with the many resources
contained herein for guidance.

and expectations for behavior for our board of directors

Through our shared commitment to the Code, we lay

and all Company employees — regardless of role,

the foundation for a culture of lasting integrity andlevel, or location. By doing so, the Code not only helps

excellence at BeiGene. None of this is possible without

us fulfill our ethical and legal obligations wherever

all your efforts, and we are honored each day to work

we operate, but also earn and maintain the trust ofwith such an incredible team.

our fellow colleagues, customers, suppliers, business
partners, government regulators, and most importantly,

Kind regards,

the patients we serve.
Every day at BeiGene, each of us is responsible for
upholding the Code and practicing the Company
Values reflected in it, especially those relating topatient-centricity, honesty, integrity, respect, open
communication, quality, and compliance. While
working in today’s increasingly complex and fastpaced business environment can present uniquechallenges, we must never waver in our commitment
to the principles embodied in the Code, each otherand our stakeholders.
John Oyler

Xiaodong Wang, Ph.D.

Co-Founder,
Chairman and CEO

Chairman of the
Scientific Advisory Board& Co-Founder

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BEIGENE CODE OF CONDUCT > COMMITMENT TO INTEGRITY

Who we are
VisionTransform the biotechnology industry, creating impactful medicines that will beaffordable and accessible to far more cancer patients around the world.

Mission

Build the first next-generation biotechnology company — one that expands the highest
quality therapies to billions more people — through courage, persistent innovation, andchallenging the status quo.

ValuesCOLLABORATIVESPIRIT

BOLD INGENUITY
Challenge the status quo
to deliver science once
thought to be impossible

Foster superior,
non-hierarchicalteamwork

Make bold commitments
and deliver against them

Respect individual
differences

PATIENTSFIRSTStand up for more
affordable medicines forpatients everywhere

Improve global health and well-being

DRIVING
EXCELLENCE
Make a lasting impact
in the world
Sense of urgency and agility to follow
the science and deliver for patients
while maintaining integrity

Behavior

How we get things done is just as important as what we accomplish — we operate withan unwavering commitment to compliance, ethics, and integrity, and always treat fellow
colleagues with respect and dignity

A Cultureof Quality andExcellence
Although we are a global organizationthat thrives on diversity, we share common
BeiGene values through our Code.

Code of Conduct

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BEIGENE CODE OF CONDUCT > A CULTURE OF QUALITY AND EXCELLENCE

Purpose and Scope of the CodeOur Responsibilities

At BeiGene, Ltd., we are passionate about our

We are each expected to read and understand thepeople, science, and the communities we serve. As

Code and its application to our role and responsibilities

we expand our global organization, our goal is to beat the Company, and to seek guidance and report

recognized for our innovations in cancer research andconcerns when necessary. We are also responsible fordrug development, talented employees, exceptional

ensuring our personal decisions and actions comply

therapies, and strong culture. To that end, we arewith the Code in letter and spirit, regardless of thecommitted to maintaining the highest standards oflocation or nature of our work.

quality, compliance, and ethical business conduct in allof our activities, both internal and external.

Additionally, managers and supervisors are
responsible for fostering an environment where
Company Personnel are encouraged to ask

Although we are a globalorganization that thrives on
diversity, we share common
BeiGene values through our Code.
The Code embodies our commitment to ethicalbusiness practices in all our interactions with thehealthcare community, patients, suppliers, business
partners, government regulators, shareholders, andeach other. Integrity is more than complying withquestions and raise concerns without hesitation orfear of retaliation.

Acting with integrity and doing
what is right may not always
be easy, but we must strive tobe better if we want to achieve
our potential as a leading global
biopharmaceutical company.

the law. It reflects who we are as a company and as
individuals, and it serves as a driving force in how we
operate. Our commitment to doing what is right is ashared responsibility of all employees.
The Code applies to all employees, Officers andDirectors of BeiGene, Ltd. and its subsidiaries worldwide(collectively, “BeiGene,” “Company,” “Company
Personnel,” “you,” “we,” “us” or “our”).
Company Personnel who engage third party

The Code is designed to provide an overview ofcontractors, vendors and consultants on behalf of thecommon topics relating to our operations and toCompany must ensure that they are made aware ofset standards that promote compliance with manyand support the principles and requirements set forthof the laws affecting our business. The Code is notin the Code.

intended to address every situation that may occur.

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BEIGENE CODE OF CONDUCT > A CULTURE OF QUALITY AND EXCELLENCE

As such, we must use good judgment, always• Familiarizing ourselves with and adhering tobearing in mind our commitment to putting

Company policies and procedures relating topatients first, and refer to applicable Company

our activities;

policies, procedures and other Company resources
if further guidance is needed.

• Treating patients, customers, partners, suppliers andother Company Personnel with respect, honesty andintegrity;• Avoiding situations where our personal interests are,or appear to be, in conflict with Company interests;• Protecting Company proprietary information, assets
and resources, as well as those of our customers,
vendors and collaboration partners;• Preserving the confidentiality of the Company’s
non-public information;• Using the Company’s assets responsibly; andThe Legal and Compliance Department is charged
with administration of the Code, and the Board of• Reporting in good faith any suspected violationof applicable laws and regulations, the Code or

Directors and our executive management teamCompany policies and procedures in accordance

are responsible for overseeing its implementation.

with the reporting procedures provided in 		

However, all of us are accountable for:the Code.

• 		Acting with honesty and integrity whenrepresenting the Company;• 		Conducting Company business in compliancewith applicable legal and regulatory requirements;• 		Supporting the Company’s Quality Management
System and related policies and procedures

When faced with a challenging
situation, ask yourself:• Is it permitted by applicable laws andregulations?
• Is it consistent with the letter and spirit offor Good Manufacturing Practices (GMP), Goodthe Code and other Company policies andDistribution Practices (GDP), Good Clinicalprocedures?

Practices (GCP), Good Pharmacovigilance Practices(GPV), Good Laboratory Practices (GLP) and otherinternationally recognized quality standards;• Would I be comfortable if my actions weredisclosed to the media?

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BEIGENE CODE OF CONDUCT > A CULTURE OF QUALITY AND EXCELLENCE

Seeking Guidance and Reporting Concerns
BeiGene encourages a culture of open-doorcommunication. This means that managers are here
to address concerns, listen to suggestions about ways
to improve the workplace and help find solutions. It
also means that we should feel comfortable seeking
guidance, raising concerns or making reports aboutsuspected misconduct.
Raising questions and reporting concerns not
only helps the Company address potential
problems before they occur, but also supports therefinement of our policies and training in potentiallymisunderstood areas.
Your most immediate resource for any matter related
to the Code is your manager. However, you may

Our commitment to integrity
requires us to report any
suspected misconduct using
the reporting procedures
provided in the Code.

also seek guidance or report a concern to any other
Company supervisor, Executive Committee member,

Confidentiality

the Human Resources Department, the Legal and

BeiGene strives to create an environment

Compliance Department, or the BeiGene Legal &where employees feel secure in raising concerns.

Compliance Helpline. The BeiGene Legal & Compliance

Confidentiality will be maintained to the fullest

Helpline allows for anonymous reporting (where

extent possible and information will be sharedallowed by applicable law) by phone or web portal

only with those who need to address or investigate

and is available 24 hours a day, 365 days a year at:

the matter. Should you identify yourself, every

Beigene.Ethicspoint.com.

reasonable effort will be taken to keep your identity
confidential. However, there may be circumstances

For more information about reporting suspected

where it is not possible to keep your identity

misconduct or any compliance concerns, please refer toconfidential due to the nature of the investigation

BeiGene’s Reporting Misconduct Policy.

and/or legal requirements.

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BEIGENE CODE OF CONDUCT > A CULTURE OF QUALITY AND EXCELLENCE

Investigative Process
BeiGene takes violations of applicable laws and

If I report suspected misconduct,

regulations, the Code, and Company policies andwill I be kept informed of any actions

procedures seriously. BeiGene will promptly andtaken by the Company?

thoroughly investigate all reports of suspected

We recognize that reporting suspected

misconduct. Company Personnel are expected to

misconduct can be a challenge. Reporters will

cooperate fully with any investigation.

always receive confirmation that their reporthas been received and will be reviewed. When

Non-Retaliation

appropriate and allowed by applicable law, we

BeiGene prohibits any form of retaliation against

will seek to update you on the status of any

anyone who, in good faith, reports a concern or

actions taken by the Company.

provides information in an investigation. Examplesof retaliation include harassment (unwelcome
and offensive comments or actions); reduction incompensation; demotion; threats; suspension; orDisciplinary Action

termination. Reports of suspected retaliation should

Failure to comply with the standards outlined in thebe made promptly to the Legal and Compliance

Code may result in disciplinary action, up to andDepartment.

including termination of employment. Moreover,any manager who directs or approves of conduct inviolation of the Code, or who has knowledge of suchconduct and does not immediately report it, may also
be subject to disciplinary action.
It is important to note that some violations ofapplicable laws and regulations may require theCompany to refer the matter to the appropriate
governmental or regulatory authorities for investigationor prosecution.

Integrity in
the Marketplace
Our success depends on our ability to earn the trustof our stakeholders—including patients, healthcare
professionals, and regulatory authorities.

Code of Conduct

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BEIGENE CODE OF CONDUCT > INTEGRITY IN THE MARKETPLACE

Compliance with Laws and Regulations
We operate in a highly regulated industry where

for the purchase, sale, or formulary placement of

virtually every area of our operations is subject toprescription drug products. Healthcare professionals

numerous laws and regulations. Our success depends

may include physicians, nurses, nurse practitioners,

on each of us understanding the legal and regulatory

physician assistants, pharmacists, or health planrequirements that affect our roles, including but notadministrators.

limited to those that govern the research, development,
manufacturing, marketing, promotion and distributionof our therapies.
In the event that applicable laws and regulations differ
from the Code and/or other Company policies andprocedures, the stricter requirements shall apply.

Our success depends on ourability to earn the trust of our
stakeholders, including patients,
healthcare professionals andregulatory authorities. While thistrust takes time to cultivate, wemust be mindful that it can belost in an instant.
Interactions with Healthcare Professionals
BeiGene is committed to complying with applicablelaws and regulations in all of its interactions withhealthcare professionals. Accordingly, none of ourinteractions with healthcare professionals should everbe intended to improperly influence a healthcare
professional’s decision to purchase, prescribe, use, orotherwise recommend BeiGene therapies.
For purposes of the Code, a “healthcare professional”
is any individual licensed or authorized to prescribe,purchase, dispense, recommend, influence, or arrange

All of our interactions withhealthcare professionals areintended to advance medical
and scientific progress, enhancepatient care and, whereappropriate, support the safe andeffective use of our therapies.
Any interactions where BeiGene therapies are
discussed must be conducted in a manner that is fairand balanced, scientifically rigorous, accurate, truthfuland not misleading. Further, interactions focusing
on the promotion and advertising of our therapies
must be consistent with the prescribing information
approved by the relevant regulatory authorities. Underno circumstances may a product be promoted prior to
its approval or for a use that has not been approved by
the relevant regulatory authorities.

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BEIGENE CODE OF CONDUCT > INTEGRITY IN THE MARKETPLACE

healthcare professionals for the purposes of obtaining

Interactions with Healthcare Professionals Who
May be Considered Government Officials

necessary consulting services (e.g., advisory board

Healthcare professionals working at public hospitals

or speaker), sponsoring travel to attend Company

or government institutions may be consideredmeetings or scientific congresses, participating in meals“government officials” in which case interactions

to discuss Company business, or providing healthcarewith such healthcare professionals may be subject

professionals with educational items for patientto additional anti-bribery and anti-corruption laws

or healthcare professional education (e.g., medical

and regulations. Always consult with the Legal

textbooks or anatomical models). Whenever we offer

and Compliance Department before engaging or

something of value to a healthcare professional, weinteracting with healthcare professionals who may bemust be vigilant to ensure that such transfers of value

government officials.

In addition, from time-to-time, we may interact withare: modest and appropriate by local standards;
compliant with local legal and regulatory requirements;
and as further discussed in the Code, not perceived as“bribes” or “kickbacks” in return for favorable businesstreatment.

Items, activities or gifts for the
personal benefit of a healthcare
professional, such as tickets toevents, sports equipment, jewelry,recreational activities, or gifts ofcash or cash-equivalents, such as
gift cards, are never acceptable
and are strictly prohibited.
BeiGene has established internal Company policies andprocedures to help ensure that all of its interactions
with healthcare professionals comply with applicablelegal and regulatory requirements.

For further information regarding interactions withhealthcare professionals who may be government
officials, please refer to BeiGene anti-bribery policies
and procedures and the appropriate country
compliance policies for interactions with healthcare
professionals.

Interactions with the Patient Community
We always put the best interest of patients first.
BeiGene primarily interacts with patients through theconduct of clinical research and, where permitted,
supporting patient advocacy and disease awareness.

For further information regarding interactions with

The intent of these activities is to enhance patient

healthcare professionals, please refer to the appropriate

education and access to medicines and care.

BeiGene country compliance policies for interactions
with healthcare professionals.

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BEIGENE CODE OF CONDUCT > INTEGRITY IN THE MARKETPLACE

Where permitted under local laws and regulations,

We are obligated to securely collect and protect

we are committed to ensuring our communications

patients’ personal data to prevent data privacy

with patients are transparent and that they focus

breaches. Company Personnel must report any

on providing the information patients need topotential misuse or loss of patient personal data to themake informed, personal medical decisions. Such

Privacy Office as soon as it is known or suspected.

communications must be tailored for patient
audiences and not healthcare professionals.

All interactions and activities with patients must
adhere to applicable laws and regulations, the Code,and Company policies and procedures. Do notassume that data privacy requirements are the samein all countries. Different countries have different
requirements.
For further information regarding interactions with thepatient community, please refer to BeiGene privacy
and data protection policies and procedures.

Safety Monitoring and Adverse Event Reporting
We also seek to protect the privacy of every patient.
During our business activities, we may encounter or
obtain patient personal data. Generally, personal data,also known as personal identifiable information, is any
information that relates to an identified or identifiable
living individual. Different pieces of information, whichcollected together can lead to the identification ofa particular person, also constitute personal data.
Examples of personal data include date of birth, name,age, gender, home address, phone, or data held byBeiGene or a third-party, which could be a code or
subject ID number that uniquely identifies a person.
At BeiGene, we respect Privacy, and everyone in thecompany worldwide has a role to play in complying
with BeiGene privacy policies and procedures andapplicable privacy laws, which among other things
may require the provision of adequate notice and/or obtaining patient consent before we use patient
information for business activities.

Supporting the health and safety of our patients is aCompany-wide responsibility. We take great pride inensuring our therapies maintain an acceptable riskto-benefit profile when used in accordance with theapproved prescribing information and good medical
practice. We perform rigorous testing to characterize
the safety and tolerability profile of our therapies
and continuously monitor their use through postmarketing surveillance. Adverse events are tracked
and reported to regulatory authorities as required byapplicable laws and regulations.

We are committed to a quality
culture in which all BeiGene
Personnel understand and takeownership of the responsibility forprotecting patient safety and theintegrity of our therapies.

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BEIGENE CODE OF CONDUCT > INTEGRITY IN THE MARKETPLACE

While all prescription therapies can have possible

Additionally, we understand our role in protecting

side effects, we are vigilant in our efforts to provide

patients from counterfeit or tampered goods.

regulators, healthcare professionals, patients and theirCounterfeit or tampered goods present a danger

caregivers with accurate and timely information toto patients, our reputation and our trust within the

promote the safe and effective use of our therapies.

broader healthcare community.

As such, you are required to report any suspected

Timely reporting of any potential product complaints

patient adverse events that could be associated withor quality concerns is critical to ensuring the integrity

one of our therapies to the BeiGene Drug Safety andof our therapies.

Pharmacovigilance Department within 24 hours ofreceipt of such information at: adverse_events@
beigene.com.
For further information regarding adverse event
reporting, please refer to the BeiGene Adverse Eventand Product Complaint Reporting SOP.

Achieving our goal of making a
difference in patients’ lives starts
with ensuring the quality of ourtherapies.

Quality, Manufacturing, and Supply Chain
BeiGene’s mission to deliver safe, effective, quality drug
products that consistently meet or exceed customer
and regulatory requirements is championed throughthe application of a Quality Management System(QMS) that promotes continuous improvement. We
earn and preserve stakeholders’ trust by adhering
to strict quality control standards in the testing,manufacturing, packaging, storage and distributionof our therapies. We maintain a comprehensive

As such, you are required to report any suspected

quality assurance and control program to generate

product complaints or quality concerns that could beawareness, foster a culture of quality, and to support

associated with one of our therapies to the BeiGene

our compliance with applicable laws and regulations

Quality Assurance Department within 24 hours ofand internationally recognized standards for Good

receipt of such information at: productcomplaints@

Manufacturing Practice (GMP) and Good Distribution

beigene.com.

Practice (GDP). Furthermore, we require the same
quality control standards from our suppliers andbusiness partners.

For further information regarding the Company’s
Quality Program or product complaint reporting, pleaserefer to the BeiGene Quality Policy or the BeiGene
Handling of Product Complaints SOP, respectively.

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BEIGENE CODE OF CONDUCT > INTEGRITY IN THE MARKETPLACE

Anti-Bribery and Anti-Corruption
BeiGene has a zero-tolerance policy for bribery

Special requirements apply when interacting withand corruption. We respect and comply with alla government official, which is broadly defined andapplicable anti-bribery and anti-corruption laws

includes any employee of a government agency orin the countries in which we operate. In addition

department, any employee of an enterprise that is

to exposing the Company to severe sanctions andgovernment-owned, operated or controlled, political

reputational damage, anyone who violates these laws

party representative or official or candidate for political

can be subject to substantial fines and/or criminal

office. Paying, offering, or promising to pay bribes orprosecution.

kickbacks to government officials to secure businessis strictly prohibited. Further, many countries prohibit
providing anything, regardless of value, to government
officials, including but not limited to meals, gifts, travel,lodging and/or compensation for consulting services.
For further information regarding interactions
with government officials, please refer to BeiGene
Anticorruption Compliance Policy.

Company Personnel are strictly prohibited fromoffering, giving or facilitating any form of bribe or
kickback. A “bribe” or “kickback” is any money, fee,
commission, credit, gift, gratuity, thing of value orcompensation of any kind that is provided, directly or
indirectly, and has as one of its purposes the improper
obtaining or rewarding of favorable treatment in abusiness transaction.
Business courtesies such as nominal gifts and modest
meals may only be offered or provided if appropriate
under local standards and consistent with applicablelaws and regulations. No business courtesy may, under
any circumstances, be offered where a reasonable
person might conclude that the courtesy wasoffered with an expectation or obligation of favorable
treatment in a business transaction.

Remember that manyanti-bribery and anti-corruption
laws apply internationally, soeven if an activity may beconsidered “acceptable” in
one country, it can constitute a
violation with significant
penalties in other countries
where BeiGene operates.

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BEIGENE CODE OF CONDUCT > INTEGRITY IN THE MARKETPLACE

Anti-competition
Anti-competition laws are designed to protect freesuch as websites, published articles, price bulletins,enterprise and prevent restraints on trade that could

advertisements, brochures, public presentations, andlead to unfair and abusive trade practices. These laws

other sources of public information. However, suchare based on the principle that the public interest andinformation should only be collected and used in a way

consumers are best served by vigorous competition.

that does not violate anti-competition and third-party

Violations of anti-competition laws can carry severe

confidentiality obligations.

penalties, including criminal prosecution andsignificant fines. You are not expected to understandthe anti-competition laws in the various countries
where we operate. However, the Company expects you
to consult with the Legal and Compliance Department
whenever you have a question relating to these laws or
believe a potential business arrangement could violate
anti-competition principles.
The following activities are examples of prohibited
conduct:• Discussing confidential information with competitors,
including but not limited to information relating
to product pricing, cost of goods, sales data, supply
information, and bids and contracts with vendors;• Entering into agreements that prevent suppliers
or customers from supplying or buying fromcompetitors; and• Entering into agreements with competitors for the
allocation of markets or customers in contraventionof anti-competition and other applicable laws.

International Trade Controls
Many countries regulate international tradetransactions — imports, exports, and international
financial transactions — for national security andforeign policy purposes. The Company is committed
to complying with all applicable international tradecontrols in all countries in which it conducts business.
Company Personnel whose job functions involve
international trade must be knowledgeable of andcomply with all applicable trade controls and relevant
Company policies and procedures.
For further information regarding international trade

The above requirements are not intended to restrict

controls, please consult with the BeiGene Legal andCompany Personnel from collecting competitive

Compliance Department.

intelligence about competitors from public sources

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BEIGENE CODE OF CONDUCT > INTEGRITY IN THE MARKETPLACE

Political Activities
BeiGene complies with all applicable laws andregulations relating to political lobbying activities(“Lobbying”) and political contributions. Lobbying
can include communicating with any member or
employee of a branch of government for the purposeof influencing legislation, government action or policy.
Only Company Personnel or third parties authorized
by the BeiGene Government Affairs Department or the
Legal and Compliance Department may engage in
Lobbying on behalf of BeiGene.
Further, where permitted by applicable law andregulations, only authorized Company Personnel may
be involved in making any loan, donation, contribution
or payment to a political party, candidate or politicalaction committee on behalf of BeiGene.

Nothing contained in the Code prohibits Company
Personnel from engaging in political or advocacy
activities in their individual capacity as private citizens,provided that the action is exclusively on their own
accord and time and does not use Company resources.

Responsibilities
in the Workplace
BeiGene values a diverse and inclusive workplace,which ultimately improves innovation andstrengthens our business.

Code of Conduct

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BEIGENE CODE OF CONDUCT > RESPONSIBILITIES IN THE WORKPLACE

Diversity and Inclusion and Equal
Employment Opportunity
BeiGene values a diverse and inclusive workplace,which ultimately improves innovation and strengthens
our business. We welcome diversity. We are firmly
committed to providing equal opportunity for all
applicants and employees and a positive working
environment in all aspects of employment, without
regard to race, color, gender, ethnicity, religion,
national origin, sexual orientation, age, disability or
medical condition or any other legally-protected
status or characteristic.

Anti-Discrimination and Anti-Harassment
BeiGene does not tolerate discrimination orharassment in the workplace, including any formof unwelcome or abusive conduct or action, such

While laws on discrimination andharassment vary from country tocountry, everyone deserves a work
environment that is respectful
and free from discrimination andharassment. BeiGene’s policies on
discrimination and harassment
apply globally. Consult with the
Human Resources Department
if you are unsure whether certain
conduct is consistent with theCode or Company policy.

as verbal, non-verbal, written, electronic or physicalconduct that creates an intimidating, hostile orEnvironmental, Health and Safety

offensive work environment; unreasonably interferes

BeiGene complies with environmental, healthwith an individual’s work performance; or demeans orand safety legal and regulatory requirementsshows hostility toward an individual.

(EH&S requirements) not only for the safety and

We are all accountable for fostering a culturethat embraces the contributions of all Company
Personnel. As such, everyone should be treated with
openness and respect in our interactions with eachother and third parties. Even where disagreement orinterpersonal conflicts may arise, we are committed
to resolving such conflicts in a respectful andprofessional manner.
Company Personnel are required to report any
discrimination or harassment they may witness orexperience in the workplace using the reporting
procedures provided in the Code. By doing so, you
are not only protecting the Company but, more
importantly, your fellow colleagues. We do not tolerate
any retaliation against Company Personnel for asking
questions or making good faith reports of possible
violations of the law, the Code or other guidelines.

protection of Company Personnel but also for the
local communities in which we operate. We arecommitted to maintaining safe workplaces, reducing
the environmental impact of our operations andencouraging environmentally sustainable businesspractices. This extends to our selection of suppliers andbusiness partners who share our commitment.
Company Personnel are responsible for adhering
to EH&S requirements and for taking the necessary
precautions to protect themselves and their colleagues.
This includes identifying any unsafe workplace
practices and conditions and reporting all accidents,
work-related injuries, threats/workplace violence, andsecurity emergencies to the local Workplace Services
manager or Human Resources representative.

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BEIGENE CODE OF CONDUCT > RESPONSIBILITIES IN THE WORKPLACE

Substance Abuse

Department and Human Resources Department

The abuse of illegal drugs, prescription drugs, or alcohol

at https://Beigenecoi.ethicspoint.com. Written

in the workplace poses serious safety and healthapproval must be provided by the BeiGene Legal andconcerns and has no place at BeiGene.

Compliance Department before starting or continuing
to engage in such activity.
It is impossible for the Company to identify every
situation that may pose a potential conflict ofinterest, so it is critical that we apply good judgment
and common sense before undertaking activities that
could impair our work. While not a complete list, thefollowing activities should always be disclosed andpre-cleared:

On Company designated occasions, alcohol may be• Creating an outside business;served in connection with a Company-sponsored• Hiring, referring or making employment decisions

function or event and, if consumed, must be done(e.g., compensation, promotion and other terms

responsibly using good judgment. In addition,and conditions of employment) relating to a family

Company Personnel should not work in BeiGene

member, relative or personal friend;

facilities, operate a Company vehicle or a vehicle
subsidized by the Company, or conduct any other
BeiGene business if their ability to work responsibly is
impaired by alcohol or drugs.

Conflicts of Interest
We must always act in the best interests of the• Accepting an additional job outside of BeiGene;• Accepting a speaking engagement relating to yourwork at BeiGene;• Serving as a director, officer or substantial
shareholder of another company; or• Conducting Company business with a friend, relative

Company and refrain from engaging in any personalor someone else with whom you have a close

activity that interferes with the interests of thepersonal relationship.

Company. A conflict of interest may take many
forms — personal, social or financial — but is generally
characterized by a situation or activity that prevents
an individual from performing Company duties andresponsibilities honestly, objectively and effectively.

Would it be a conflict of interest if
I work as a consultant for anothercompany during my free time?

Situations that may create even the appearance of a

Maybe. If the other company is in the same line

conflict of interest should be avoided.

of business as BeiGene, if BeiGene’s resources areused, or the activity negatively affects your job

If you plan to engage, or have already engaged, in

performance or limits your capacity at BeiGene,an activity that you think may constitute, or may

this would be a conflict of interest. Such outside

be perceived by others as constituting, a conflict ofbusiness activities should be disclosed to andinterest under BeiGene’s Code of Conduct and Conflictpre-cleared by the Human Resources Department

of Interest Policy, you must disclose the activity toor Legal and Compliance Department.

your manager, BeiGene’s Legal and Compliance

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BEIGENE CODE OF CONDUCT > RESPONSIBILITIES IN THE WORKPLACE

Action by members of your immediate family,

Moreover, any Company Personnel involved insignificant others or other persons who live in yourprocurement decisions must ensure that suchhousehold (“family members”) may also present

decisions are based exclusively on normal businessethical issues to the extent that they involve Company

considerations, such as quality, cost, availability, service

business. For example, acceptance of a gift by a family

and reputation, and not on the receipt of special favors

member from one of our suppliers could create aor personal benefit.

conflict of interest and result in a Code violation
attributable to you. Consequently, in complying with

Corporate Opportunities

the Code, you should consider not only your own

All Company Personnel have a duty to advance theconduct, but also that of family members.

legitimate interests of BeiGene. Therefore, you may
not take for yourself corporate opportunities that are

Gifts, Gratuities, and Entertainment

offered to you as a result of your relationship with the

We must always use caution when accepting gifts,

Company without first offering such opportunities tomeals or entertainment from any vendor, contractor,

the Company.

supplier or other person doing or seeking to dobusiness with the Company.
With manager approval, Company Personnel may
accept modest and inexpensive gifts, meals or
entertainment from third-party vendors, contractors or
suppliers of BeiGene, provided that such gifts, meals
or entertainment are not (a) cash or a cash equivalent(e.g., a gift card); (b) susceptible of being construed asa bribe or kickback; (c) made or received on more thanan occasional basis; (d) solicited by Company Personnel;(e) a potential conflict of interest; or (f) in violation of
applicable laws or regulations. Any gifts inconsistent
with these requirements should be returned
immediately and reported to your manager or throughthe reporting procedures provided in the Code.

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BEIGENE CODE OF CONDUCT > RESPONSIBILITIES IN THE WORKPLACE

Company Information Technology Assets
BeiGene’s information technology assets, systems,

Protecting Our Informationand communication networks are intended for theTechnology:sole purpose of conducting Company business and• Always be professional when using

may only be used in accordance with the BeiGene
Acceptable Use Policy, Bring Your Own Device

Company systems• Stop, look, and think before clicking on links“BYOD” Policy and other applicable Company policies

or opening attachments in email. Reportand procedures. Company equipment, electronic

phishing emails using the Phish Alert button

messaging applications such as email, and other• Do not create, send or download content or

systems must never be used to access, receive orcommunications that could be consideredtransmit material that is illegal, inappropriate, or

offensive, derogatory, defamatory, harassing,otherwise violates applicable laws and regulations,obscene or vulgar

the Code, and/or Company policies and procedures
Inappropriate use of such assets owned or leasedby the Company, or otherwise in the Company’s
possession, may expose our data and systems tosubstantial risk.

• Do not download unauthorized software orother programs
Take precautions to protect the security ofcomputer systems, including corporate data,
electronic communications, and applications.

Computers, smartphones, tablets and other personal
devices used for conducting Company business shouldbe password protected with multi-factor authenticationand properly secured at all times. Software thatis not properly licensed or lawfully acquired may
not be introduced into a Company computer orcommunication device. Further, no software of any
kind may be introduced into Company-provided
devices and communication systems without theprior approval of the BeiGene Information Technology
Department, in accordance with Information Security
policies and standards.
While the Company recognizes that Company
Personnel may occasionally use BeiGene devices andemail for incidental personal matters, such use should
be reasonable and kept to a minimum.

Moreover, subject to applicable laws and regulations,Company Personnel shall have no expectation ofprivacy regarding any communications or materials(including emails or text messages) that are created,viewed, accessed, received or stored on BeiGene
systems, applications or networks, including through
BeiGene email and other systems used on yourpersonal device. The Company’s business records,
including email and computer records, may become
subject to internal review and/or public disclosure
during internal investigations, audits, litigation, or
government investigations.
Report any suspicious or malicious activity andsecurity incidents to Information Security at
itsecurity@beigene.com.
For further information regarding the acceptable
use of Company assets, please refer to the BeiGene
Acceptable Use Policy, BYOD Policy, and Information
Security Policy.

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BEIGENE CODE OF CONDUCT > RESPONSIBILITIES IN THE WORKPLACE

Confidential Information andIntellectual Property

What do I do if I receive confidential

Confidential information is one of the Company’s

information about a competitor?

most valuable assets. Confidential information is a

The confidential information of thirdsource of our competitive advantage and must be

parties, including our competitors, must be

protected. “Confidential information” includes but isrespected and must not be used by BeiGene. If

not limited to all non-public information that might

you become aware of information about a third

be of use to competitors or harmful to the Company

party you believe to be confidential, refrain fromor its customers if disclosed, such as our intellectual

further sharing or distributing the information

property as well as proprietary information about

and immediately contact the Legal andthe Company’s operations, performance, technology,

Compliance Department for guidance.

products and/or personnel.
Company Personnel must only use confidential
information for legitimate business purposes, inaccordance to the Data Classification Standard, andmay not disclose or distribute such information, except
when disclosure is authorized by the Company or
required by legal or regulatory requirements.
Company Personnel must also be careful to maintainthe confidentiality of information entrusted to them by
the Company’s customers, suppliers, business partners
and collaborators..

• Report any incident of improper or accidental
disclosure to your manager or the Legal andCompliance Department; andTo help protect BeiGene confidential information,
always keep the following principles in mind:• Utilize care when conducting BeiGene businessin public areas;• Use screensavers when working on computersin unsecure spaces;• Beware of requests for information fromexternal sources;• Dispose of confidential information properly;• Exercise care when storing and transmitting
confidential information;• Protect and do not share any login accountnames, usernames, and passwords used for
Company business;• Do not provide confidential information tothird parties, including vendors or contractors,
without appropriate authorization and required
confidentiality agreements.
The obligation to preserve and protect BeiGene
confidential information continues even after
employment with the Company ends. Additionally,
Company Personnel must abide by any legal andcontractual obligations that they have to a former
employer restricting the use and disclosure of its
confidential information.

Commitment to
the Company and
our Shareholders
We respect and uphold our obligations to investors,
regulators, patients and the public by maintaining
the integrity of our books and records.

Code of ConductBEIGENE CODE OF CONDUCT > COMMITMENT TO THE COMPANY AND OUR SHAREHOLDERS

25

Integrity of Books and Record Keeping

Examples of media containing business records include

Accurate financial and business records are

paper documents (including hand- written notes or lab

essential for managing our business, maintaining

notebooks), audio or video recordings, and computer-investor confidence, complying with legal andbased information such as email and computer files.

regulatory requirements, and satisfying obligations

Company Personnel are expected to be familiar withto our customers, vendors and others with whom

the document retention requirements applicable to

we do business.

their role and business activities and should consult

Therefore, our corporate and business records mustwith their manager for guidance when needed.

always be completed accurately, honestly and in a

In addition, under some circumstances, such as

timely manner. The making of false or misleading

litigation or government agency requests, thestatements and entries relating to our financial andCompany may be required to preserve documents

accounting records or results is strictly prohibited.

and information beyond their normal retention

Any individual who becomes aware of a departure

period. If required to do so, we must be diligent infrom these standards has a responsibility to promptly

adhering to any document hold requests.

report this information using the reporting procedures
provided in the Code.

For further information regarding records retention,please consult with the Information Governance
Program Office.

Securities Trading
Company Personnel are prohibited from buying,selling or engaging in any transaction with respect
to securities (e.g., shares, ADSs, options, RSUs orderivatives) of BeiGene or any other company withwhom BeiGene conducts business or exchanges
confidential information while in possession ofRecord Retention
BeiGene’s business records must be maintained incompliance with applicable laws and regulations(e.g., regulatory filings, tax filings, employment andcontractual obligations) and, when appropriate,
disposed of in accordance with the Company’s Global
Records Retention and Disposition Policy and Global
Records Retention and Disposition Schedule. “Businessrecords” are any recorded information captured in any
medium that reflects circumstances, events, activities,
transactions or results created or maintained as part of
conducting business for BeiGene. These records may bephysical or electronic.

material, non-public information (“Inside Information”).
This restriction applies to all securities markets where
BeiGene securities are traded (e.g., the NASDAQ
Stock Market and the Stock Exchange of HongKong). “Material information” is any information thata reasonable investor could consider important inmaking an investment decision. Those in possession ofmaterial, non-public information must refrain frombuying or selling relevant securities until market close
after the first full trading day following public disclosureof that information. Also prohibited is the sharing withor disclosing of Inside Information to others—commonly
known as “tipping.”

BEIGENE CODE OF CONDUCT > COMMITMENT TO THE COMPANY AND OUR SHAREHOLDERS

26

To avoid even the appearance of trading on Inside

Privacy and Data Protection

Information, some Company Personnel may be

The majority of countries have adopted strict privacy

designated as “Restricted Insiders” by the Company’sand data protection laws (“Privacy Laws”) governing

General Counsel (the “Insider Trading Compliancethe collection and use of individuals’ personal data.

Officer” under this Policy) and subject to additional

Generally, personal data, also known as personalrequirements under the BeiGene Special Trading

identifiable information, is any information that

Procedures for Insiders (“Trading Procedures”).

relates to an identified or identifiable living individual.

Generally, the Trading Procedures require Restricted

Different pieces of information, which collected

Insiders to obtain pre-clearance of all transactions

together can lead to the identification of a particularin the Company’s securities from the Insider Trading

person, also constitute personal data. Examples ofCompliance Officer, or if unavailable, the Company’s

personal data include date of birth, name, age, gender,

Chief Financial and Strategy Officer.

home address, phone, or data held by BeiGene or athird party, which could be a symbol that uniquely

Examples of material, non-public
information that an investor could
consider important in deciding
whether to buy, sell or hold securities
could include:

identifies a person. Privacy Laws are broad andgenerally apply to the collection and use of personal
data from various sources, including but not limited
to patients, clinical trial subjects, vendors, customers,
healthcare professionals, visitors to our websites andCompany Personnel.

• financial results;• potential mergers or acquisitions;• licenses;• clinical trial results; and• regulatory guidance or action.

Violations of securities laws are taken very seriously. If
you are uncertain about the implications of a purchaseor sale of any BeiGene or other company securities byvirtue of your service relationship with the Company,
you should consult with the Insider Trading Compliance
Officer before entering any such transaction.

Protecting the privacy and securityof personal data is a growing
global concern. The majority
of countries have enacted orare enacting or strengthening
Privacy Laws that govern the useof personal data and holding
transgressors accountable.
We are committed to protecting the privacy and

For more information regarding trading in Company

security of all personal information — including sensitive

securities, please refer to the BeiGene Statement ofhealth information — that comes into our possession in

Company Policy on Insider Trading and Disclosure andcompliance with applicable laws.

the BeiGene Special Trading Procedures for Insiders.

For further information regarding privacy and dataprotection requirements, please refer to BeiGene
privacy and data protection policies and procedures.

BEIGENE CODE OF CONDUCT > COMMITMENT TO THE COMPANY AND OUR SHAREHOLDERS

27

Scientific Integrity
We are committed to conducting our research and

Because our personal use of Social Media to discussdevelopment operations in accordance with applicableCompany activities or business may carry potential

laws and regulations and internationally recognizedlegal and reputational implications for the Company,

quality standards, such as those for Good Laboratory

the following requirements must be observed:

Practice (GLP) and Good Clinical Practice (GCP). We• Only authorized Company Personnel anduphold the integrity of the Company’s research andspokespersons are permitted to use Social Media

clinical development activities by ensuring that all

to communicate information about the Company’s

pre-clinical and clinical development is conductedbusiness and operations, including but not limited toin accordance with the highest ethical, medical, andclinical studies, therapies, financial and operational

scientific standards.

results, and business dealings (e.g., announcement ofa collaboration with a new business partner);• Do not make unauthorized disclosures of confidential
information, and generally avoid mixing personal andbusiness-related content;• Always be truthful and accurate in postings andrecognize that online comments are never truly
anonymous;• Never post anything that could violate the Code andScientific misconduct in all of its possible forms is

Company policies and procedures against unlawfulstrictly prohibited. Examples of scientific misconductharassment, discrimination and retaliation, or that

include, but are not limited to, fabrication, falsification,

would otherwise reflect negatively on the Company,or plagiarism in proposing, conducting, or reportingor disparage other parties; andresearch, disregarding the intellectual contributions
and property of others, impeding the progress of• Use of Social Media must comply with applicablelaws and regulations, the Code, and Company

research, and corrupting scientific records.

policies and procedures related to productWe seek to provide transparency in all of our researchpromotion, privacy and pharmacovigilance.

results and outcomes, whether positive or negative.
In doing so, we strive to advance scientific knowledge,
enhance patient care and preserve the trust of our
stakeholders.

Social Media“Social Media” generally refers to digitally publishedinformation and online content, including, but
not limited to, websites and applications for social
networking (e.g., WeChat, Facebook, LinkedIn, Twitter,
Weibo, QQ, and other online discussion or messaging
forums) and other forms of online communication.

When you refer to BeiGene insocial media, remember thatsuch communications canbe interpreted by externalaudiences, including regulators,
as official statements on the
Company’s behalf.

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BEIGENE CODE OF CONDUCT > COMMITMENT TO THE COMPANY AND OUR SHAREHOLDERS

For further information regarding social media
use, please refer to the BeiGene Social Media Use

If a reporter contacts me about

Policy and/or consult with the BeiGene Corporate

basic information on BeiGene, may I

Communications Department.

provide brief answers?
No. Even simple questions must be

Media, Investor or Other Public Inquiries

forwarded to our Corporate Communications

BeiGene is committed to delivering accurate andDepartment and/or Investor Relations

reliable information to the media, financial analysts,

Department to ensure that all relevant facts areinvestors and other members of the public. This

provided in an accurate and consistent manner.

information should be disclosed only throughThis also helps ensure that potential material

Company-approved channels to ensure that all those

information is publicly disclosed accordingwith an interest in the Company receive equal accessto Company plans and in compliance withto information.

applicable securities laws.

All inquiries or calls from the media, investors orothers should be referred to the BeiGene Investor
Relations Department or Corporate Communications
Department. We have designated specified individuals
in these departments, as well as certain Company
Officers, as our official spokespersons for the Company.
Unless specifically authorized by the Investor
Relations Department or Corporate Communications
Department, these designees are the only Company
Personnel who may communicate with the media,
investors or others on behalf of the Company.

Cooperating with Government Investigations
BeiGene is committed to cooperating with all
government requests for information relating to theCompany or its operations. This commitment does
not limit the Company’s efforts to protect and defend
its interests and rights afforded under law. If you arepresented with a government agency request for
information or access to Company facilities, documents
or assets, and circumstances allow, notify the BeiGene
Regulatory Affairs Department or the Legal andCompliance Department before proceeding.

BEIGENE CODE OF CONDUCT > COMMITMENT TO THE COMPANY AND OUR SHAREHOLDERS

Code Dissemination, Amendments, and Waivers
The Company will distribute the Code to all Company
Personnel and make it available on the Company’s
website. All Company Personnel must acknowledge
that they have read and understand the Codeand that they will comply with it. Violation of theCode may result in discipline, up to and including
termination of employment.
BeiGene reserves the right to amend or alter the
Code at any time and for any reason; provided thatany amendment shall be publicly disclosed to theextent and in the manner required by applicablelegal and regulatory requirements. The Company’s
Board of Directors must approve any material
amendment of the Code.
Any waiver of the Code for BeiGene’s Directors or
Executive Officers may be made only by the Company’s
Board of Directors and shall be promptly disclosed,
along with the reasons supporting such waiver, to theextent and in the manner required by applicable legal
and regulatory requirements.

29

BeiGene Code of Conduct
Effective December 2021