Alexion Vendor Code of Conduct
As a pharmaceutical company, Alexion Pharmaceuticals, Inc., its subsidiaries and divisions (collectively “Alexion” or the“Company”) conduct a wide array of activities in the global health care marketplace, including manufacturing, research,
medical and other education, marketing and sales. Also, Alexion is a U.S. public company that interacts with governments
and other third-parties. These activities are subject to numerous legal and ethical standards, many of which are unique tothe health care industry.
Alexion aims to operate in a manner that reflects high ethical standards, and is committed to complying with all applicablelaws, regulations, and other legal requirements in every country in which it operates. Accordingly, Alexion seeks to conductbusiness with third-party vendors who share these commitments, as well as a dedication to high ethical standards.
At Alexion, we work to change lives for the better – ours, people living with rare diseases, and thecommunities we serve – and our commitment to good corporate citizenship helps make it possible.
The Alexion CSR-STAR Platform identifies and prioritizes our most important Corporate Social Responsibility (CSR) related topics. This supports our mission, while creating value for all of our stakeholders.

This mission-driven approach inspires us, giving us even more reason to believe in the importance of our purpose
and to perform at our personal best. We strive to engage and collaborate with our third-party vendors to support
this mission.
We are committed to creating a diverse network of suppliers. We recognise the value of this and strive to work withsmall and diverse businesses where we are able to. Alexion expects our vendors to commit to the same level ofdiversity and inclusivity in their vendor base, just as we do in our own business.

General Responsibilities
Alexion relies on an innovative and competitive vendor base to provide it with products and services that will meet its
business requirements. Alexion employees are required to comply with Procurement and Competitive Bid policies, which
are designed to ensure:•

Vendors are selected with a focus on best total value, including quality, service, and cost•

Alexion intellectual, proprietary, and confidential capital is protected•

Vendors are treated fairly and equitably•

Worker safety and environmental stewardship is a priority

Vendors’ integrity, honesty, and business practices can impact Alexion’s reputation. Vendors are therefore required tocomply with the guidance provided in this Vendor Code of Conduct. Such compliance is required for a vendor to beconsidered in good standing, and as a condition of continuing a business relationship with Alexion.
Vendors are expected and encouraged to seek guidance or raise concerns to contact Alexion to ask questions and/or
report concerns about any potential misconduct or unethical behavior by Alexion or affiliated parties. Alexion offers
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several options to submit questions or concerns, including online, via phone, or via email. The reporting options areavailable at www.AZEthics.com. The online and phone options allow users to submit a report anonymously.
By accepting Alexion’s purchase order or otherwise agreeing to do business with Alexion, all vendors are agreeing tocomply with this Vendor Code of Conduct. This Code, or the demonstration of your compliance with it, does not create
third-party beneficiary rights for any vendor. The standards set forth in this Code are in addition to, and not in lieu of,the provisions of any legal agreement or contract with Alexion; when in conflict the more restrictive or specific provisionapplies.

Quality GxPs
At Alexion, we understand that Quality is for Everyone. We are committed to:•

Delivering safe and effective products that meet or exceed the requirements of our patients and our customers•

Complying with all applicable regulatory requirements•

Operating a Quality Management System and improving our systems and processes•

Ensuring the integrity of our data•

Upholding our individual and collective accountability for quality.

Where applicable, a vendor supplying Alexion with materials or services must comply with the quality requirements as
mutually agreed upon with Alexion. Vendors must ensure appropriate communication mechanisms between Alexion’s
Quality organization and the vendor to ensure that materials and services supplied to Alexion comply with Alexion
requirements and meet all applicable regulatory requirements. A vendor is expected to supply all aspects of the materials
or services (e.g., labor, supervision, machinery, equipment, materials, supplies, licenses, permits, and all otherrequirements necessary to supply the materials or services) in compliance with this Vendor Code of Conduct, and inaccordance with the agreed-upon quality criteria and supply agreements executed between the vendor and Alexion.
Vendors shall have in place a quality management system to ensure that all materials and services supplied to Alexion
conform to specified requirements, and adhere to current quality guidelines and regulations (GxPs) as set forth in the
United States Code of Federal Regulations, and other Health Authority requirements including European, Japanese andother local regulations, where applicable.

Business Conduct and Ethics
At Alexion, we are committed to acting with the highest ethical standards in all countries where
we conduct business, and integrity is anchored in our culture. By operating with the highest
standards of ethics, quality, compliance and integrity, we continue to build trust with patients and themarketplace. We are committed to:••••

Being a key influencer of compliance standards across the industry through ongoing, proactive thought leadership;
Zero-tolerance toward bribery and corruption. We prohibit all forms of bribery;
Handling personal data fairly and transparently in accordance with the laws and regulations that govern dataprotection and privacy; andTransparency and making full, accurate, timely, and understandable disclosures about our business.

Alexion requires that vendors conduct their business in an ethical manner and act with integrity. The ethics
elements include:

Animal Welfare
Treat animals humanely with pain and stress minimized. Alexion Pharmaceuticals seeks to work with partners andsuppliers that are accredited by The Association for Assessment and Accreditation of Laboratory Animal Care
International (AAALAC). AAALAC International accreditation shows that an institution is serious about setting, achieving
and maintaining high standards for animal care, is committed to animal welfare in science, promotes scientific validity,
and is aware of, and engaged in, current best practices. If an institution is not accredited, it must have an Institutional
Animal Care & Use Committee or similar oversight board governing the use of animals in research to ensure that eachanimal is treated humanely with minimal pain and distress. The institution must ensure that research with animals be
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performed only after considering options to replace animals, reduce the number of animals, and refine procedures inorder to minimize distress to animals. Alternatives should always be used wherever scientifically valid and acceptable toregulators.

Anti-Bribery/Anti-Corruption (“ABAC”)
Never participate in bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private
sector. Alexion and its employees, as well as third-parties acting on the Company’s behalf, can be held civilly andcriminally liable for the misconduct of its partners and vendors. Alexion will conduct due diligence on certain third-parties
before working with them, and manage the relationship for its duration, to ensure the activities of third-parties acting on
Alexion’s behalf are transparent and consistent with the Company policy.
Alexion is committed to observing the U.S. Foreign Corrupt Practices Act (the “FCPA”), the U.K. Anti-Bribery Act (2010),
and the anti-corruption and anti-money laundering laws of the countries in which Alexion operates. Vendors must comply
with all applicable ABAC and anti-money laundering laws, as well as laws governing lobbying, gifts, and payments topublic officials, political campaign contribution laws, and other related regulations.

Antitrust
Conduct business in full compliance with antitrust and fair competition laws that govern the jurisdictions in which they
conduct business.

Business and Financial Records
Honestly and accurately record and report all business information and comply with all applicable laws regarding theircompletion and accuracy. Create, retain and dispose of business records in full compliance with all applicable legal andregulatory requirements. We expect vendors to provide honest and accurate invoices. Invoices should be itemized, quote
the PO number (where relevant), be supported by appropriate documentation and comply with all other requirements as
set out in the relevant contract(s). Invoices may not be split to circumvent approval requirements.

Confidentiality
Never communicate externally, including in marketing presentations, about Alexion’s prospects, performance, or policies,
nor disclose Insider Information without prior written approval from Alexion. Insider Information can be defined as a nonpublic fact regarding the plans or condition of a publicly traded company that could provide a financial advantage whenused to buy or sell shares of the company's stock. Vendors must safeguard Alexion’s confidential or proprietary
information.

Intellectual Property
Comply with the intellectual property ownership rights of Alexion, as well as intellectual property rights of others including
but not limited to copyrights, patents, trademarks and trade secrets; manage the transfer of technology and know-how ina manner that protects intellectual property rights.

Marketing and Promotional Practices
Maintain only marketing and promotional materials and activities that conform to high ethical, medical, and scientificstandards, and comply with all applicable laws and regulations. Promotional materials and activities that mention the
products or services of third-parties (e.g., Alexion competitors) must fairly and accurately represent those products andservices. Use of Alexion’s name, trademark and any representations of our products or services are prohibited unlesswritten authorization has been provided by Alexion’s legal department.

PrivacyComply with all applicable privacy and data protection laws and regulations related to the collection, use, disclosure,destruction or otherwise processing of personal information. Vendors must have documented, implemented, andmaintained a written information security and privacy program containing the appropriate administrative, technical andorganizational measures, procedures, and other safeguards, appropriate to the size and complexity of the vendor’soperations, the nature and scope of its activities, and the personal information involved, to protect personal information
against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against
all other forms of unlawful use or processing, including, but not limited to, unnecessary collection or further usage orprocessing. Vendors use and disclosure of personally identifiable information must be limited to those purposes for which
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they are engaged by Alexion, in accordance with Alexion’s directions or as required by law to ensure that individuals’
privacy rights are protected. Personal information means any information relating to an identified or identifiable person.

Sub-suppliers and Subcontractors
Have a program to support compliance by their own suppliers and subcontractors (including, without limitation, anyintermediaries, agents, manufacturers’ representatives, distributors or any other business partners) with the standards
set forth in this Code.

Trade
Comply with all applicable trade controls, as well as all applicable export, re- export, and import laws and regulations.

Transfers of Value to Third-Parties
Ensure compliance related to transfers of value to third-parties. Many countries have adopted transparency legislation orcodes that require the retention and reporting of payments and other transfers of value made to Healthcare
Professionals, Healthcare Organizations, Patient Advocacy Organizations, and other stakeholders in the healthcare
industry. Vendors (e.g., Meeting Management companies, Clinical Research organizations, etc.) who make suchpayments and/or transfers of value are expected to retain such records and provide them in a format and frequency
specified by Alexion in order to meet its reporting requirements under these laws and codes where applicable.
Relevant Definitions:
Healthcare Organization (HCO): Any organization or facility involved in the provision of healthcare services. Examplesof HCOs include (but are not limited to): Hospitals, Teaching Hospitals, Clinical Trial Sites, Nursing Homes, Clinics,
Physician Groups, & Pharmacies.
Healthcare Professional (HCP): Any person who is (1) a trained healthcare professional who is licensed to prescribe or
dispense prescription drugs or to furnish healthcare services to patients; or (2) an employee of a managed careorganization, insurance company, pharmaceutical benefits management company, pharmacy or similar organization,
including anyone on a formulary committee or otherwise responsible for prescription drug coverage decisions. Thisdefinition includes healthcare professionals organized as a professional association, corporation or other entity and to theentire staff of a healthcare professional’s practice, including office managers, receptionists and other employees even if
they are not themselves trained healthcare professionals.
Examples include, but are not limited to: Physicians, pharmacists, nurses, mid-level practitioners (e.g. nurse
practitioners, physician assistants, medical students), other allied healthcare professionals, health plan administrators,
formulary/pharmacy and therapeutics committee members and research personnel conducting clinical studies involving
patients.
Patient Advocacy Organization (PAO): Any not-for-profit organizations (including umbrella organizations to which they
belong), mainly composed of patients and/or caregivers that represent and/or support the needs of patients and/or
caregivers.
Transfer of Value (ToV): Any item of value including, but not limited to, payments, meals, transportation, lodging,registration fees, medical education items such as textbooks and reprints.

Labor and Human Rights
At Alexion, we are committed to high labor standards and human rights and we trust, value,
and respect our employees. Our people are empowered to make a difference, with their diversity ofbackgrounds and ideas being encouraged and embraced. We are committed to:
•
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Treating everyone with fairness, respect, and dignity;
Creating a workplace free of hostility, intimidation, and bullying;
Encouraging and listen to those who voice their opinions and share their thoughts;
Creating a culture where every voice matters;
Being respectful of differences and embrace diversity; and4/8

•

Avoiding making offensive or derogatory remarks.

Alexion expects its vendors to share its commitment to labor and human rights and equal opportunity in theworkplace. Vendors’ commitment to labor and human rights should adhere to Alexion’s own global EHS Policy and Codeof Conduct as a minimum, whilst maintaining full compliance with all applicable laws and regulations in the vendors’
country of operation.
Vendors shall work with employees to promote a positive working environment in which individuals can thrive; throughpromoting equal opportunities, embracing diversity and creating a good workplace culture where every voice matters.
Vendors should be aware that they will need to complete a pre-engagement screening and will be subject to Alexion’s
due diligence process. Vendors must be in compliance prior to commencement of an engagement. Alexion requires all
contracted vendors providing contingent workers to be in compliance with Alexion’s Global Background Screening
Components and Thresholds requirements enacted by Alexion’s Global Security Policy.

Fair Labor and Hiring Practices
All workers in our supply chain deserve a fair and ethical workplace. Workers must be treated with the utmost dignity andrespect, and Alexion vendors shall uphold the highest standards of human rights.
Vendors shall ensure that all work is voluntary. Vendors shall not traffic persons or use any form of slave, forced, bonded,indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or
employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control
over another person for the purpose of exploitation. Vendors shall abide by all applicable laws regarding child labor,
including requirements relating to minimum age for workers and working conditions.
No Vendor shall discriminate against any worker based on age, disability, ethnicity, gender, marital status, national origin,political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected byapplicable national or local law, in hiring and other employment practices. All Vendors shall commit to a workplace free ofharassment and abuse. Vendors shall not threaten workers with, or subject them to, harsh or inhumane treatment,
including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, andsexual harassment.
Vendors shall abide by all applicable laws regarding hours of work, the payment of wages and mandated benefits,
including minimum wages and overtime payments.
Suppliers shall respect the rights of workers, as set forth in local laws, to associate freely, join or not join labor unions,seek representation and join workers’ councils. Workers shall be able to communicate openly with management
regarding working conditions without threat of reprisal, intimidation or harassment.

Mechanism for Reporting Concerns
Vendors shall provide means for their employees to report concerns or potentially unlawful activities in the workplace
without threat of reprisal, intimidation or harassment. If concerns are reported, vendors will investigate and takecorrective action where needed. Vendors will not tolerate retaliation against their employees for reporting concerns ingood faith.

Health & Safety
At Alexion, we are committed to taking a proactive approach to protecting the health and safety of ourworkers and the communities where we operate. We see this as essential in living out our corporate
values. We are committed to:•••

Following established policies, procedures, and share best practices to create safe and compliant
workplaces;
Encouraging and empowering our workers to identify, understand and mitigate, when possible, thesafety risks associated with their roles;
Promoting our “speak-up” culture so workers report all potential and actual risks and incidents;
and
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•

Providing a culture that promotes physical and mental well-being to help our workers live healthy, full andproductive lives.

Alexion requires that vendors provide a safe and healthy working environment, including for any companyprovided living quarters, and shall engage with workers regarding health and safety issues through regularawareness training and updates. Health and Safety measures shall extend to contractors and subcontractors
on vendor sites. The Health and Safety elements include:

Worker Protection
Vendors shall protect workers from over exposure to chemical, biological, physical, and radiological hazards as well as
excessive physical or psychologically demanding tasks in the workplace and in any company provided living quarters.
Vendors shall ensure appropriate housekeeping and provide workers with access to potable water and sewer/septic andwaste disposal facilities.

Hazard Information
Safety information relating to hazardous materials, including pharmaceutical compounds and pharmaceutical intermediatematerials, shall be available to educate, train and protect workers from hazards. Such safety information shall be available
in written documents, such as Safety Data Sheets (SDS) in languages commonly used by the Vendor’s workforce.
Vendors shall ensure appropriate communication to other business partners in the value chain, as appropriate, including
Alexion and its logistic and distributor partners, to ensure hazards are appropriately disclosed and managed.

Process Safety
Vendors shall have programs in place to identify the risks from chemical and biological processes and to prevent, mitigate
or respond to catastrophic events, including but not limited to releases of chemicals or biological agents, fires, andexplosions.

Emergency Preparedness and Response
Vendors shall identify and assess emergency situations in the workplace and any company-provided living quarters andminimize their impact by implementing emergency plans and response procedures.

Physical and Mental Wellbeing
Vendors shall provide a culture that promotes physical and mental well-being to help workers live healthy, full andproductive lives.

Environment
At Alexion, we are committed to excellence in managing and reducing our environmental
footprint relative to production and making a positive impact in our communities. To manage
our environmental risks, we pursue a path of continuous improvement – investigating, assessing,understanding, and improving environmental aspects and impacts. We manage our EHS in alignment
with widely accepted global standards, such as like ISO 14001. We are committed to:
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Following established policies, procedures, and share best practices to create environmentally responsible
operations;
Reducing our greenhouse gas emissions (absolute and intensity);
Increasing the amount of water we recycle and reuse;
Maintaining zero process waste-to-landfill enterprise wide year over year; andMinimizing the volume and/or toxicity of regulated waste that is generated.

Alexion requires that vendors shall be responsible stewards of the shared environment and be a goodneighbour in the communities they work in. The environmental elements include:

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Environmental Authorizations
Vendors shall comply with all applicable environmental regulations. All required environmental permits, licenses,
information registrations and restrictions shall be obtained, and their operational and reporting requirements followed.

Waste and Emissions
Vendors shall have systems in place to ensure the safe handling, movement, storage, recycling, reuse, or management ofwaste, air emissions and wastewater discharges. Any waste, wastewater or emissions with the potential to adversely
impact human or environmental health shall be appropriately managed, controlled, disposed of or adequately treated prior
to release into the environment.

Spills and Releases
Vendors shall have systems in place to prevent and mitigate accidental spills and releases to the environment. Vendors
shall provide a safe and healthy working environment, including for any company-provided living quarters.

Resource Efficiency
Vendors shall take measures to improve efficiency and reduce the consumption of resources, including conserving
energy, reducing water consumption in areas of water stress and scarcity, and increasing the amount of waste and waterreused and recycled.

Sustainable Sourcing and Traceability
Vendors shall carry out due diligence on the source of critical raw materials to promote legal and sustainable sourcing.
This requirement should also be pushed further up the supply chain through to their vendors.

ClimateAlexion will work with vendors to influence greenhouse gas emissions reductions in our industry’s supply chain. Vendors
shall demonstrate that they are committed to reducing greenhouse gas emissions from their own operations andminimising their impact on climate change. Vendors will provide Alexion with their scope 1 and 2 emissions data andreport their energy consumers.

Management Systems
Vendors shall use management systems to facilitate continual improvement and compliance with the expectations ofthese principles. The management system elements include:

Business Continuity
Vendors are responsible for the development and implementation of appropriate business continuity plans for operations
supporting Alexion business. These plans should be designed and kept current to promptly recover and restore partially orcompletely interrupted critical functions to minimize disruption to Alexion’s business and protect Alexion’s reputation.

Commitment, Accountability and Risk Management
Vendors shall demonstrate commitment to the concepts described in this document by allocating appropriate resources.
Vendors shall have mechanisms to determine and manage risks in all areas addressed by this document.

Continual Improvement
Vendors are expected to continually improve by setting performance objectives, executing implementation plans andtaking necessary corrective actions for deficiencies identified by internal or external assessments, inspections, andmanagement reviews.

Documentation
Vendors shall maintain documentation necessary to demonstrate conformity with these expectations and compliancewith applicable regulations.

7/8Fraud Prevention and Reporting
Vendors shall implement robust fraud prevention and reporting programs. Vendors are required to report all frauds
involving Alexion business, regardless of materiality.

Identification of Concerns
Vendors shall encourage all workers to report concerns or illegal activities in the workplace without threat of reprisal,
intimidation or harassment. Vendors shall investigate and take corrective action if needed.

Legal and Customer Requirements
Vendors shall identify and comply with applicable laws, regulations, standards and relevant customer requirements.

Training and Competency
Vendors shall have a training program that achieves an appropriate level of knowledge, skills and abilities inmanagement and workers to address these expectations.

Alexion Guidelines and Policies
In addition to the principles herein, Alexion has a defined employee Code of Conduct stating Alexion’s policy on thefundamental standards to be followed by Alexion employees in their everyday actions on behalf of Alexion and topromote honest, legal and ethical conduct. Accordingly, Alexion’s vendors interacting with Alexion employees should
understand and comply with Alexion’s principles regarding conflicts of interest, and gifts and entertainment, as noted
below:

Conflicts of Interest
Alexion expects all of its employees to be free from actual, potential or perceived conflicts of interest—including in theirinteractions with vendors. A conflict of interest occurs whenever the prospect of direct or indirect personal gain may
influence, or appear to influence, an employee’s judgment or actions while conducting Alexion business.

Gifts, Meals, Hospitality and Entertainment
A conflict of interest may exist if a vendor offers or provides gifts, meals, hospitality, or entertainment to a colleague.
Vendors may provide gifts, meals, hospitality and entertainment to Alexion employees only when such items are:•Lawful and ethical under local laws and regulations;•Reasonable in frequency and nominal value;•

Occasional;•

Related to a legitimate business purpose; and•Not intended to, and could not be reasonably perceived as intended to, improperly influence a pending or prospective
business decision.

At least one vendor representative must be present during any of these instances (e.g., meals, entertainment, etc.).
Notwithstanding the aforementioned, vendors must not provide Alexion employees with any gifts of cash or cashequivalents.
Any exceptions must be approved by, at a minimum, both Alexion’s Global Sourcing (“Global Sourcing”) and Global
Compliance (“Compliance”) Departments. Vendors seeking exceptions should contact Global Sourcing, while other thirdparties or Alexion employees should contact Compliance for further guidance. Alexion employees must also comply with
Alexion’s Conflicts of Interest Policy in determining whether to accept gifts, meals, hospitality, or entertainment from avendor.
Vendors should be aware that Alexion employees and their immediate family members are subject to additional
restrictions while the Company is actively engaged with a vendor prior to, during, or after sourcing events, contract
negotiations, or periods of award reviews (“the Pre-Award Period”). Employees must not accept any gifts orentertainment from vendors or potential vendors during this time.

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