Code of Conduct

DKSH | Code of Conduct | 2024

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Contents

Do the Right Thing ............................................................................................................................ 3
Code of Conduct ................................................................................................................................ 4
Compliance with this Code of Conduct............................................................................................. 4
Reporting non-compliance ................................................................................................................ 5
Business Integrity ............................................................................................................................. 5
Compliance With Laws, Rules, and Regulations .............................................................................. 6
Trade Compliance ............................................................................................................................ 6
Fair Competition ............................................................................................................................... 6
Environment Health & Safety ........................................................................................................... 7
Employment at DKSH ....................................................................................................................... 7
Sustainability ..................................................................................................................................... 8
Conflict of Interest ............................................................................................................................. 9
Protection and Use of Company Assets………………………………...………………………………..9
Accurate Books and Records ......................................................................................................... 10
Retention of Business Records ...................................................................................................... 10
Confidential Information .................................................................................................................. 10
Data Privacy ................................................................................................................................... 11
Financial Integrity ............................................................................................................................ 11
Anti-Bribery and Anti-Corruption ..................................................................................................... 11
Third Party Management ................................................................................................................ 12
Political Donations & Charitable Contributions ............................................................................... 12
Business Courtesies and Gifts ....................................................................................................... 13External Communication ................................................................................................................ 132

Do the Right Thing
Welcome to our Code of Conduct.
Integrity is a value that we never question at DKSH. As an international
services provider, we are committed to observing high ethicalstandards in the way that we conduct our business. This is a crucialpart of our service offering and one on which we do not compromise.
It is everyone’s responsibility within DKSH to nurture and protect ourcompany’s reputation. The Code of Conduct provides specificguidance on how to act in our day-to-day activities and practice ourcorporate
values:integrity,empowerment,
collaboration,
entrepreneurship, and sustainability.
At DKSH, we foster an entrepreneurial, performance-driven culture, delivering outstanding services toour clients and customers. To achieve our goals, we aim to attract and retain employees who are
passionate about their work and committed to performing in a transparent, fair, and honest manner.
Please take time to read this Code of Conduct and personally implement and comply with it in all yourbusiness activities. At DKSH, we measure performance not only by the results achieved, but also how
these results were achieved.
If in doubt, remember, always do the right thing! If you are suspicious, then please speak up by contacting
your local HR, compliance, or legal counsel or by reporting through our anonymous Integrity Line. Should
you have any questions or concerns, please get in touch with compliance@dksh.com.
Stefan P. Butz
CEO

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Code of Conduct

Compliance With This Code of Conduct

We will consult the Code and comply with all its provisions
This Code of Conduct applies to all DKSH employees (including those in DKSH affiliated companies andjoint ventures under our control). DKSH also endeavors to ensure that all aspects of this Code of Conduct
which are not specifically related to DKSH employees shall also be adhered to by business partners
DKSH engages for conducting its business.
It is the personal responsibility of each employee to read, understand, and ensure full compliance withthis Code and its principles. Employees will be invited to participate in periodic integrity and compliancetrainings. Employees in management roles must ensure that employees reporting to them have been
properly trained, and fully understand and comply with the Code.
This Code of Conduct is not an exhaustive document; employees are required to familiarize and comply
with all relevant DKSH policies which provide more detailed guidance in relation to topics covered in thisCode of Conduct
We do the right thing in the right way and seek advice when unsure
When in doubt as to how to act, employees should seek advice by turning to their managers, local Human
Resources (HR), or Compliance Managers, either at local or corporate level. If the answer to one of thefollowing questions is “yes” or “maybe,” you have identified a potential issue and should discuss it withthe persons mentioned above:• Could my behavior be viewed as dishonest, unethical, or unlawful?
• Is my behavior in line with DKSH internal rules and expectations?
• Could my behavior have negative consequences for DKSH or myself?
• Would I be uncomfortable if it was reported in the media, or if I discussed it with family and friends?
• Is my behavior endangering the personal health and safety of others?
We take a clear stance
DKSH does not tolerate unlawful or unethical behavior: any failure to comply with this Code may result in
disciplinary actions, including the possibility of dismissal and, if warranted, legal proceedings.

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Reporting Non-Compliance

We always seek to do the right thing and speak up when in doubt
Employees shall report any actual or suspected non-compliance with this Code to their managers, orappropriate members of the HR, Legal, or Compliance Functions. If the circumstances do not allow forthis or if employees do not feel comfortable reporting to any of these persons, or have been unsuccessful
in discussing their concerns, reports of violations may be made directly to higher levels, including
members of senior management or the Executive Committee.
DKSH also provides employees and external parties with a secure online whistleblowing platform called
the “Integrity Line” for reporting any potential misconduct in confidence and, at the reporter's discretion,
anonymously. The Integrity Line can be accessed here.
All complaints shall be adequately reviewed or investigated. DKSH protects the confidentiality of theemployee who makes a report and strictly prohibits any form of retaliation against an employee who
raises genuine concerns in good faith, while also protecting the rights of employees reported for noncompliance.

Business Integrity

We endeavor to ensure that we, and third parties appointed by us, act with integrity always
DKSH strives to deliver outstanding services to its business partners seeking Market Expansion Services
solutions. Commitment, trust, reliability, and integrity are key ingredients in our service delivery and aprerequisite for DKSH’s sustainable success. DKSH expects its employees to act with the highest degreeof integrity in all their professional dealings to protect DKSH’s reputation and business.
Business shall be always conducted with integrity. Employees shall only enter and maintain commerciallysound business arrangements that are fully compliant with DKSH’s standards of doing business. In doing
so, employees shall strictly observe their levels of authority.
During its business, DKSH may engage third parties in support of its service delivery or for the
procurement of goods or services for own use. Employees shall exercise adequate diligence and due
care when appointing third parties. No third party shall be engaged which may negatively affect DKSH’s
or its business partners’ integrity and reputation.

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Compliance With Laws, Rules, and Regulations

We always respect the law and our internal rules and regulations
Business shall be conducted in strict compliance with laws, regulations, rules as well as internal policies
and standards. Employees need to know the rules that apply to DKSH’s business in the markets in which
DKSH operates and to comply with them as individuals and in their professional roles and responsibilities.
If in doubt, legal advice shall be sought.
In the event when internal regulations are stricter than the law, the more stringent standard shall befollowed. In the unlikely event of a conflict between the law and internal rules, the law shall be followed,
and the conflict shall be reported to management.

Trade Compliance

We carefully observe the rules that govern international trade
As an international Market Expansion Services provider, DKSH plays an active role in business
transactions that cross national boundaries, exposing DKSH to various trade-related compliance risks.
Employees shall maintain compliance with applicable laws, regulations, and rules governing the crossborder exchange of goods, services, and data, including but not limited to export controls, embargoes,
trade sanctions, customs, and anti-boycott laws.

Fair Competition

We fully endorse the principles of free competition
DKSH believes in free markets and fair competition. DKSH conducts its business by making use of fairmarket practices and in compliance with applicable competition/antitrust laws.
DKSH prohibits any business behavior by its employees which has the objective or the effect ofpreventing, restricting, or distorting competition. Employees are expected to understand the principles ofcompetition law applicable to them and how it affects their business. Employees who are uncertain about
specific competition law matters shall seek assistance from DKSH’s legal specialists.

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Environment, Health, and Safety

We provide a safe and healthy workplace and protect the environment
DKSH is committed to conducting its business in an environmentally sustainable manner by minimizing
the impact of its business on the environment, using practices that are socially responsible andeconomically sound.
DKSH conducts its operations in compliance with applicable environmental, health and safety laws andregulations as well as company standards to provide employees with a safe, healthy, and clean working
environment.

Employees are personally responsible for safety, health, and environmental protection at the workplace,in line with their duties and responsibilities and to the best of their knowledge, experience, and ability.
Employees becoming aware of circumstances representing a health and safety hazard, or posing anenvironmental risk, shall report this promptly to their manager or the respective officer in charge of health,safety, or environmental matters.

Employment at DKSH

We offer an attractive work environment that builds on merits and embraces diversity and fair
employment practices
DKSH provides a challenging performance culture that allows employees to contribute to DKSH’s
success while growing individually.
We respect human rights, freedom of association, and do not tolerate forced labor
DKSH is committed to fair employment practices, based on trust and mutual respect, respecting humanrights. DKSH does not engage in, or tolerate, any form of forced, compulsory, or child labor whether by
DKSH, DKSH affiliated companies, joint ventures, suppliers or vendors. The right of all employees tofreedom of association and collective bargaining is well respected within DKSH.
We value diversity and do not tolerate discrimination and harassment
DKSH operates in many markets and diverse cultures. DKSH is committed to fair, respectful, and equal
treatment of all its employees and those who seek employment with DKSH. It is DKSH’s policy to maintaina workplace free from discrimination and harassment. Employees shall not discriminate or bediscriminated against or harassed, based on origin, nationality, religion, race, gender, age, disability,

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sexual orientation, or any other relevant category. Employees who feel that they, or observe that other
employees, are subjected to discrimination or harassment, are encouraged to raise their concerns with
Human Resources.
We take decisions on hiring and people development in a fair and objective manner
DKSH pursues an employment policy based on merits, i.e. qualifications, skills, experience, expertise,performance, and achievements. Immediate family members and partners of employees may be hired orretained as employees or consultants solely if based on such merits, only if there is no direct or indirect
reporting relationship between a current and a prospective employee, but also if a relationship develops
during employment. These principles of fair employment shall apply to all aspects of the employment,such as compensation, transfers, and promotions.

Sustainability

We embed sustainable business practices within our company and through our operations
At DKSH, we strive towards conducting our business in an environmentally, socially, and economically
responsible manner.
In our pursuit of being a responsible corporate citizen, we see corporate sustainability as an actively
managed theme, by proactively addressing adverse impacts and risks, as well as pursuing beneficial
opportunities. This positively contributes to our purpose of enriching people's lives.
We adopt the principle of materiality to identify the impacts our activities have on societies, people, andthe environment in which we operate. We consider our actual and potential opportunities and risks,
whether positive or adverse.

8Conflict of Interest

We always act in the best interest of DKSH and not based on personal interest
A conflict of interest may arise when personal interests of an employee or the interests of a related third
party compete with the interests of DKSH. Employees shall avoid conflict of interest situations wheneverpossible. If a Conflict-of-Interest situation occurs, or may occur, the employee shall disclose it to their
manager to resolve the situation in a fair and transparent manner. An employee in such a situation cannot
be part of the decision-making process or in any other form of influence relating to the conflict.
We are fully committed to advancing DKSH’s business
Employees shall not pursue outside activities if these may interfere with an employee’s responsibilities
for DKSH, or if they create risks for the reputation, or in any way conflict with the interests of DKSH and/or
its business partners. Whenever in doubt whether an outside activity is acceptable, employees shallconsult with the HR department.

Protection and Use of Company Assets

We protect our company assets and make use of them carefully
Employees shall diligently safeguard and protect DKSH assets and property from loss, damage,destruction, misuse, theft, fraud, and embezzlement, both for tangible and intangible assets and ensure
they are used responsibly.
DKSH protects its intellectual property and respects the intellectual property rights of others. Intellectual
property can take many forms, including trade information, processes, methods, commercial or marketingstrategies, pricing and costing models, and customer information. Employees shall not disclose, copy, or
use intellectual property except for its intended, authorized purpose. Employees shall not knowingly
infringe upon a third party’s intellectual property, by making use of unlicensed software or by reproducing
copyrighted materials.
DKSH provides employees with electronic devices and communication tools at DKSH’s discretion.
Employees who have access to such devices and tools must handle these with due care and in line withapplicable internal IT policies. Furthermore, employees shall comply with DKSH’s IT security standards.
To the extent permissible under local law and company policy, DKSH reserves the right to monitor andinspect how its assets are used by employees, in particular electronic files and data kept on DKSH’s IT
platforms and devices

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Accurate Books and Records

We never falsify or distort any business or accounting records
DKSH must comply with applicable accounting laws and standards. Any entries into financial books andaccounts shall be timely, accurate, true, and fair, and in line with our finance and accounting rules andpolicies. All transactions must be properly and accurately recorded and supported by proper
documentation.
Employees shall never make false or misleading statements or entries into any report, publication, or
expense claim. Falsifying records and accounts or misrepresenting facts may constitute fraud. Employees
who engage in such behaviors are subject to disciplinary measures.

Retention of Business Records

We pay due attention to the retention of business records
Business records may be created and retained in various formats, such as paper, electronic, audio/video,
microfilm, etc. Any business records created by an employee are the exclusive property of DKSH.
Employees must ensure that company records are properly handled in line with applicable law andcompany policy.

Confidential Information

We value and protect confidential information
Employees may have access to confidential information relating to the business of DKSH or its business
partners. Confidential information is information not or not yet publicly available, and may be in the formof trade secrets, business plans, marketing and sales strategies, client information, financial information,etc. Employees shall respect and protect confidential information they are exposed to, whether
intentionally or by coincidence, and they shall take appropriate measures to prevent accidental disclosure.
No employee shall seek access to confidential information unless for a legitimate business purpose.
Employees must always maintain confidentiality of information, and unless required by law or authorized
by their management, shall not make use of or disclose confidential information or allow such disclosure.
If the disclosure of information to third parties is authorized by management, such an exchange is subject
to the signing of an adequate confidentiality agreement.
Secrecy obligations are part of the employment contract and continue to be in force after termination ofan employment.

10Data Privacy

We process and protect personal data with due care
All processing of personal data, including the exchange of personal data with third parties must comply
with applicable data protection laws and DKSH’s principles. DKSH respects the privacy and confidential
nature of employees’ personal information. DKSH only acquires and maintains the personal data of
employees and external parties to the extent required by law or for the operation of its business.

Financial Integrity

We do not compromise our financial integrity
Financial risks and operational measures must be appropriately reviewed and approved. DKSH provides
timely, accurate, and complete financial information to shareholders and financial markets. DKSH
maintains effective controls over financial reporting to ensure a complete and accurate record of financialtransactions.
We protect insider information and refrain from insider trading
Employees are prohibited from trading, directly, or indirectly, in DKSH securities while in possession of
non-public information which, when disclosed, could potentially influence the price of DKSH securities.
Information is non-public if it has not been officially disclosed by DKSH in line with financial market
regulations.
Employees may be exposed to non-public information regarding DKSH business partners through theirwork. Employees are prohibited from trading in securities of these business partners while in possessionof confidential information which, when disclosed, could potentially influence the price of the business
partners’ securities.
Employees are also prohibited to pass on any confidential information to third parties (including but notlimited to family members and friends), for their own benefit or for the benefit of others.

Anti-Bribery and Anti-Corruption

We do not tolerate bribery or any other form of corrupt behavior
DKSH prohibits any form of bribery and corruption. Employees shall never, directly or throughintermediaries, offer/promise or receive any personal or improper financial or other advantage to obtain11

or retain a business or other advantage from a third party, whether public or private. Moreover, employees
shall avoid situations that may create the appearance of an improper influence over business decisions.
DKSH considers facilitation payments as bribes. Facilitation payments are payments in cash or in kind to
public officials in their performance of a routine action to which DKSH is entitled. Demands for facilitation
payments must be strongly rejected.
Employees shall never hire third parties to do things employees are not allowed to do themselves, likepaying bribes. Third parties acting for or on behalf of DKSH must therefore never give or receive bribes.
Any DKSH employee who receives a demand (or clear hint) for a bribe (including facilitation payments)
must report the matter immediately to his or her manager and/or the Group Governance, Risk andCompliance department (compliance@dksh.com) or through the Integrity Line.

Third Party Management

We work with reliable third parties that share our corporate and social values
At DKSH, we work with different Business Partners. Our dedication to doing what is right is unwavering,
and we consistently adhere to the highest ethical standards in all our business dealings.
In all our operations, we conduct risk-based due diligence and seek for reliable third parties that mirror
our commitments, ensuring actions and decisions resonate with DKSH Business Partner Code of
Conduct, embody ethical business practices, and remain compliant with all laws and regulations
applicable in their business.

Political Donations and Charitable Contributions

We do not engage in politics and only make charitable contributions when supporting local
communities, we operate in
DKSH does not engage in political processes and for that matter refrains from any form of donation topolitical parties, elected officials, or candidates for public office, or in support of any political campaigns.
DKSH is committed to the communities it operates in and supports local initiatives in line with its policies
on community engagement and this Code of Conduct. No charitable contributions shall be made that are
intended or appear to influence public officials or third parties by granting improper advantages.
Prior approval must be obtained in accordance with the Global Donations Policy before making donations
on behalf of DKSH and shall follow the specified approval process.

12Business Courtesies and Gifts

We do not accept or grant favors that could raise concerns about our integrity
Employees shall not be influenced by receiving favors (e.g. gifts, meals, or other forms of hospitality or
benefits), nor shall they try to influence external parties by providing favors. Employees may only offer or
accept reasonable and moderate gifts or courtesies which are appropriate under the circumstances, butnever if such behavior could create the impression of improperly influencing a business relationship.
Gifts and other courtesies may only be acceptable if in accordance with the law, DKSH’s Gifts, Hospitality& Entertainment Policy and accepted local business practices. For further guidance, employees shallconsult the respective laws and internal DKSH policies applicable to the markets they operate in.
Employees involved in the procurement of goods or services shall pursue this activity in the best interestof DKSH. They shall not accept gifts, favors, or courtesies if these could raise concerns about theirpersonal integrity. Invitations for participation in professional events (e.g. trade fairs) or similar activities
are acceptable subject to reporting and clearance in line with the applicable policy.
Employees may not use their own money or resources to circumvent the rules in DKSH’s policies or as
set out in this Code of Conduct. All gifts and hospitality offered and provided to others on behalf of DKSH
must be properly reflected in DKSH books and records.

External Communication

We protect the reputation of DKSH and communicate with due care
Information on DKSH provided to external stakeholders must be clear, concise, accurate, and consistent.
Employees shall always protect the reputation of DKSH. No employee shall speak on behalf of DKSH,
discuss or disclose any information regarding DKSH to the media or the financial community, or issue
any public statement on behalf of DKSH, unless specifically authorized to do so, in line with internal
communication policies and standards.
When participating in online discussion forums and social media, employees must comply with DKSH’s
Social Media policy.

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Contacts
DKSH Management Pte. Ltd.
Attn. Governance Risk Compliance
238 A Thomson Road
#25-01 Novena Square, Office Tower A
Singapore 307684+65 6578 9830
compliance@dksh.com

DKSH Holding Ltd.
Attn. General Counsel
Wiesenstrasse 88034 Zurich
Switzerland+41 44 386 7434
corporate.legal@dksh.com

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