Code of Ethics. Werfen

Code of Ethics

Code of Ethics. Werfen

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Dear Colleagues,
Our world is becoming ever-more complex, and we are all exposed to
unforeseen challenges in which we must demonstrate ethical behavior toensure the right thing is always done. This is especially true in our industry,

Table of contents

healthcare, where the highest standards are always expected.
The Werfen Code of Ethics is the foundation for our commitment to respect,

1 Introduction

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2 Werfen Values 		6

3 Scope and compliance with the Code of Ethics

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compliance, transparency and ethical conduct. It is our “real-world” compass
for the behaviors we embody as a team committed to improving our industry
and providing confidence to healthcare professionals, as well as enhancing
the wellbeing of patients around the world.

4 Our employees		8
Our reputation as an honest, transparent and reliable business has been
4.1 Selection, training, assessment and promotion		
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4.2 Private life and professional development		
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hard-earned worldwide through the adoption of the values found in our Codeof Ethics. This trust underlies our relationship with customers, collaboration
partners, stakeholders and each other. It is fundamental to our continued

4.3 Responsibilities		
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success and for achieving excellence in what we do.

4.4 Conflicts of interest		
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The Ethics Channel, which can be found on the corporate intranet, provides

4.5 Assets and property		
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a direct line of communication to the Compliance Officer. Please use this

4.6 Confidential information		11

5 Interactions with customers, suppliers and public administrations

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channel if you need clarification on the application of the Code of Ethics or
to report conduct that you believe conflicts with any of the ethics, legality or
standards that govern Werfen.

5.1 Company events for product training and education		
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Please take the time to read the Werfen Code of Ethics and consciously

5.2 Supporting third-party educational events		
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implement it in all your daily business activities.

5.3 Sales, promotional and other business meetings		
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Thank you so much for your personal commitment!

5.4 Donations		
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5.5 Gifts		
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5.6 Arrangements with consultants		
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5.7 Interactions with public administrators and healthcare and scientific 		
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Marc Rubiralta

President
5.8 Suppliers		
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6 Our products		
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7 Regulatory compliance		
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8 Environment, health and safety		18
8.1 Environment		
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8.2 Health and safety		
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9 Internal control		18
10 Dissemination of the code of ethic		
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11 Ethics Channel 		193Code of Ethics. Werfen

4This Code sets out the general principles and values,
as well as the ethical commitments that govern
the development of business activities and the
management of the businesses of all companies
that make up Werfen.

1 Introduction
All of us that work at Werfen are responsible for accepting and defending thevalues that define and unite us. The principles set out in this Code therefore
apply to all of us. The contents of this Code shall also apply to the external
partners with whom Werfen has relationships or links.
The aim of the Code is for all the people to whom it applies to carry out theiractivities with integrity and professionalism, demonstrating their commitment
to Werfen and its values.
This Code sets out a control mechanism that involves the implementation ofan ethics channel through which employees of Werfen can make enquirieson the application of the code or disclose conduct that they believe could becontrary to the ethics, legality and standards that govern Werfen.
Breach of the provisions set out in this Code of Ethics shall entail theapplication of legally appropriate sanctions or penalties. Werfen shall also
be entitled to take the measures it deems appropriate depending on theseriousness and the consequences of such breach.

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Code of Ethics. Werfen

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2 Werfen Values
The values of Werfen are:→Integrity: We strive to demonstrate open, honest and ethical behavior
in all dealings with our customers, clients, employees, suppliers, 		partners, general public and government bodies.

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Respect for People: We value the contribution, thoughts, ideas, 		differences and diversity others bring, and show the utmost respectfor everyone we interact with.

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Honesty & Humility: We endeavor to be open, honest and reliable andlisten to others as we communicate, building trustworthy relationships
inside and outside the organization. We aspire to be humble about 		
how we approach our work and our achievements.

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Leadership and Management: We seek to inspire and motivate our 		
employees in their work, aligning their objectives and goals with the 		
Vision and Strategy of Werfen, through frequent formal and informal
communication.

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Teamwork: We understand our unique contribution to the business 		
and we work together to achieve common goals, helping 			and supporting others along the way and striving for 			high performance in everything we do.

→Innovation: We encourage our employees to execute better or different
ways of doing things that derive greater value for our customers andstakeholders, as well as to make processes and systems more 		
efficient and effective.

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Delivery of results: We all take responsibility for the delivery of results
and achievement of success at an individual and team level. In 		
knowing what is expected of us, we strive for top performance in 		
everything we do.

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Quality and Excellence: All our business practices, processes 		
and systems are designed to achieve quality results that exceed the
expectations of all our stakeholders. We work to the highest standards
in everything we do and hold others accountable for ensuring these 		same levels of excellence.

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Costumer focus: We involve our customers through the full product 		development lifecycle to ensure we deliver true value through our 		
portfolio of solutions; we provide the support they need through 		
constant communication; and we do all of this because behind every
blood sample there is a human being.

All of the foregoing values seek a common aim: to improve patient care andmaintain the good reputation and name of Werfen for the benefit of everyone.

3 Scope and compliancewith the code of ethics

Ethical conduct forms part of everyone’s job. Thus, everyone, without
exception – that is all Werfen employees, including executives and membersof the governing boards of all Werfen companies, third parties who interact onbehalf of Werfen, commercial distributors and agents, external service agents,
recruitment agencies, consultants and any person or entity that directly or
indirectly represents any of the Werfen companies - must understand andcomply with all of the Code of Ethics standards set out in this document.
It shall be the accountability of Werfen employees responsible for contracting
outsourced services to ensure that these entities or companies understandand share the operating principles set out in this Code of Ethics.

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Code of Ethics. Werfen

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4 Our employees
Our employees are our greatest strength. For this reason, Werfen is responsible
for ensuring that the workplace has high professional standards, encourages
motivation and supports diversity. We want Werfen to be an “employer of choice”
due to its:→

Corporate Vision→

Product-development pipeline→

Personal and professional growth and development opportunities→

Pleasant working environment based on the spirit of teamwork, 		
respect and consideration→

Team of honest people→

Merit-based rewards Werfen employees must base their conduct on
the principles of this Code of Ethics.

4.1 Selection, promotion, assessment

4.2 Private life and professional development
Werfen promotes a working environment that is compatible withpersonal development and which respects the private life of its
employees and the activities they perform outside the workplace andwork hours, providing these activities do not have a negative effecton the good name, brand or image of Werfen or on the professional
development of the employee, and that they do not create a conflict ofinterest.

4.3 Responsibilities
The relationship between Werfen and its employees is based on loyalty and fidelity according to the following key patterns of behaviour:→

Dedicating working hours solely to professional matters in thebest interest of Werfen.

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Avoiding attitudes that may directly or indirectly be 		
considered harassment.

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Avoiding activities that may directly or indirectly be 		
considered illegal or corrupt.

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Safeguarding passwords, access cards and other electronic
access methods to information systems, as employees are
responsible for any improper use resulting from negligence
while items are their responsibility.

Werfen promotes non-discrimination by reason of race, colour,
nationality, social origin, age, sexual orientation, gender, marital status,
ideology, political opinion, religion or any other personal, physical or social
condition or disability of its employees, as well as equal opportunities
among them.

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Defending free and fair competition→

Treating others with respect and consideration and having a
positive attitude towards them.

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Admitting mistakes with transparency and humility.

Communication with employees must be clear and precise both in theassessment of work as well as in the setting of professional objectives.

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Accepting constructive criticism (feedback) at all levels of theorganisation and asking for or proposing alternative solutions.

→Appreciating that they are responsible for the consequencesof their actions (and assuming that others always act with 		positive intentions).

and promotion

We take care of our employees’ well-being in the workplace. We selectand promote our employees on the basis of their individual and collective
skills, as well as the development of their professional performance.
Our first challenge must always be to recruit and retain the most talented
people at all levels of experience. We are responsible for the growth anddevelopment of our team, and we, therefore, must create appropriate
and secure working conditions, as well as providing adequate support,
counselling and training.

9Code of Ethics. Werfen

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4.4 Conflict of interest
Werfen employees must avoid taking part in situations that cause any
conflict of interest. A conflict of interest is considered to exist in thosecircumstances where there is a direct or indirect conflict between the
personal interest of the employee or person related to him/her, and theinterest of any of the Werfen companies.
Examples of conflicts of interest where a personal interest is valued
above the interest of Werfen include, but are not limited to, the following:
the use of confidential information, making investments or contractingwith third parties on behalf of Werfen that lead to a personal benefit, theuse of work time for unconnected activities or the hiring of customers’
or personal relatives or friends, without such hiring complying with therecruitment policy.

4.6 Confidential information
Werfen employees are responsible for protecting confidential information, business information and trade secrets and ensuring they cannot
be used for personal or third-party gain. In this regard, key confidential
information includes, but is not limited to, the following:				

4.5 Assets and property
Werfen employees must protect all corporate assets, such as intellectual
property, electronic media, equipment, funds, products and services,and promote their efficient and legitimate business use.
The excellent reputation of Werfen is one of its most valuable and fragile
assets. Each employee is personally responsible for preventing potential
actions that could damage this reputation.
Valuable or confidential information is an important asset and must betransmitted internally and/or externally by the appropriate authorised
employee.
If there is any doubt, the employee should discuss the matter with the
Werfen Compliance Officer.

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Pricing policy.

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Cost strategy.

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Business and marketing strategy for products.

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Employees, customers and patients’ data as defined by the
Data Protection Act or other privacy laws→

Financial operations or financial data that is not yet published.

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R&D, production information, any other know-how and 		
investment strategy.

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5 Interactions withcustomers, suppliers andpublic administrations
All Werfen employees must work to ensure that we are our customers’
first choice.
Werfen is a service-oriented business from which the customer should receive
the best attention, dedication and attitude. Werfen Employees, should at all
times, consider the image and perception of Werfen that will be projected tothe public when interacting with Healthcare professionals. Interactions with
Healthcare professionals should not influence medical decisions throughimproper advantatges.
Interactions with healthcare, science and other professionals must betransparent; to do this, employees must provide reliable information about
products, services and prices in order to facilitate purchasing decisions, basedon real and objective features and services.

5.1 Company events for product training
and Education

When appropriate, and permitted under national laws, regulations, andindustry codes of conduct, Werfen may organise educational eventsand provide financial support to cover the cost of training and education
for customers and health care professionals on Werfen products. Suchfinancial support is subject to the following limitations:
		
		
		
		
		
		
		
		
		
		
		
		
		
		
		
		

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Event Programme. Werfen may conduct training and 		
education programs that are directed primarily at training 		
customers on the safe and effective use of company 		
products or medical technologies, or to provide scientificeducation on the disease areas in which our products
are used.

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Event Location and Venue. Location and venue must bewithin suitable proximity for attendees as well as being 		
conducive to the effective transmission or exchange 		
of scientific or medical knowledge. Leisure, entertainment
and tourist activities and locations are not suitable.

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Travel and Accommodation. Where there are objective 		reasons to support the need for out of town travel to efficiently
deliver the company product training and education, we may
provide reasonable travel and hospitality to Healthcare
Professionals. Travel and accommodation must be 		
subordinate in time and focus to the event purpose.

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Modest meals and refreshments may be provided if they aremodest in value and subordinate in time to the training andeducation program.

		
		
		
		

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Training Staff. Training staff must have the appropriate 		qualifications and expertise to conduct such training.

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Guests. We cannot facilitate or pay for meals, travel or otherexpenses of guests of Healthcare Professionals or for any 		
other person who does not have a bona fide professional 		interest in the training and education program.

All events and payments must be detailed, documented and approvedby the appropriate level of authority in order to guarantee transparency
before the appropriate authorities, such as hospital administrators andconference organisers.

5.2 Supporting third-party educational events
Where permitted under national laws, regulations and industry codes ofconduct, Werfen may support third-party organised educational events
through educational grants and other types of funding.
Educational grants can only be provided to Healthcare Organizations
or conference organizers to reduce the conferences costs as well as toallow the attendance of Healthcare Professionals when:
		
		
		
		
		
		

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The Event is primarily dedicated to promoting objective 		
clinical scientific and educational activities.

→

The Healthcare Organization or conference organizer whichis the beneficiary of the grant is solely responsible for 		
selecting the attending Healthcare Professionals as well as 		
the program content, faculty and materials.

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The educational grant is not subject to the purchase, lease, 		recommendation, prescription, use or supply of 			Werfen products.

Under no circumstances shall Werfen personnel directly designate or
influence the nomination of grant recipients. It is the obligation of therecipient organization to apply objective and impartial criteria for theaward of grants, without the influence or input of Werfen personnel.

5.3 Sales, promotional and otherbusiness meetings

Where appropriate, Werfen can organise sales, promotional and otherbusiness meetings to discuss Werfen products and related services,conduct contract negotiations or discuss sales terms. As a general rule,such meetings should occur at or close to the healthcare professional
place of business. However, it is appropriate to pay for reasonable travel
costs of attendees when necessary (for example, for plant tours ordemonstration of non-portable equipment) and provide modest meals
in connection with such meetings.

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Code of Ethics. Werfen

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5.4 Donations
It is Werfen’s policy that donations can only be awarded to organisations
entitled to receive such a contribution (e.g., charities, non-profit
organisations, foundations) and that such support must be given incompliance with applicable national or local laws and regulations.
Furthermore, donations must be officially accepted by the relevantorganisation, be justifiable and appropriately documented, specifying
the purpose and nature of the supported activity. Payments cannot bemade for personal use or to private accounts

5.5 Gifts
Werfen may occasionally provide inexpensive gifts to healthcare orscience professionals or receive similar ones from them, which dueto their nature and value cannot be interpreted as intended to provide
preferential treatment to the recipients of the same. Gifts must relate to
the healthcare or science professional’s practice, cannot be given in theform of cash and must comply with national and local laws.
Furthermore, under no circumstances may gifts be given to civil servantsor public officers, auditors, directors of Werfen and its subsidiaries or totheir relatives, if such a gift could have an influence on their independent
opinion or induce any kind of favour.
In the event of any doubt as to what can be accepted or not, the offer
should be turned down and where necessary the Werfen Compliance
Officer should be consulted.

5.6 Arrangements with consultants
Healthcare and science professionals may work for Werfen companies
by providing consultancy services such as research and development,
educational conferences, scientific advisory committees, productdevelopment and clinical trials.
These consultancy services must satisfy the following standards:
		
		
		

→

The legitimate purpose of hiring such services must be 		
identified in advance.

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The selection of a consultant must be made on the basisof how well his/her qualifications and expertise meet the 		
identified need.

		
		
		
		
		
		
		
		
		
		
		

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The consultancy arrangement must be set out in a written 		agreement which establishes the services to be provided
and the compensation to be paid. The consultancy 		arrangement must also be authorised by the appropriate 		level of authority and must be completely transparent with 		the hospital and/or the management of relevant entities.

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Consultants must act in accordance with the provisions 		included in this Code of Ethics.

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Compensation must be made at fair market value and 		must comply with applicable tax legislation and national
and local laws. Sponsored hospitality and travel costs must
be reasonable in value, and must coincide time-wise withthe service provided and be focused on the primary 		
purpose of the consultancy.

5.7 Interactions with public administrations andhealthcare and science professionals

All relationships with public administrators and healthcare or science
professionals must maintain the utmost transparency, honesty andcorrectness.
Werfen employees are forbidden, directly or through intermediaries, tooffer, grant, solicit or accept unjustified advantages or benefits that are
intended to benefit Werfen, themselves or a third party. In particular,
they may not give or receive any type of bribe, commission or bonus toor from any other party involved, such as government officials or public
sector personnel or personnel of other companies or political parties,
suppliers or shareholders.

5.8 Suppliers
When engaging or dealing with suppliers, Werfen employees are required
to select suppliers based on an objective and impartial assessment,
avoiding any conflict of interest or favouritism in the selection thereof.
They must also provide suppliers with reliable information, with no intent
to mislead or to induce them to perform any illegal or improper activity.

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6 Our products
We are responsible for the products and services used by our customers,
who make decisions on their patients’ healthcare and treatment. We
must guarantee that our products meet the expectations and needs ofour customers. To this end, our products must be of the highest quality,
something that can only be achieved through our continuous commitment
to innovation, excellence in production and quality control. Excellencein production is based on discovering new and better ways to improve
productivity and processes and to reduce costs without compromising thehigh level of quality standards of Werfen.
Our products must comply with current legislation at any given time,
as well as with the guidelines and directives of the official healthcare
registers of every country where Werfen has business activities related toresearch, product development, production, distribution or quality-control
procedures.

7 Regulatory Compliance
All people to whom this Code of Ethics applies are required to familiarise
themselves and comply with all national and local laws, regulations andprofessional codes that apply in the areas within the scope of their work
responsibilities.
In particular:
		
		
		
		
		

Our interaction with customers, regulatory entities, certification agencies
and health authorities must always be proactive and transparent.

				

All Werfen products and services must be provided in accordance with thehighest environmental standards and user-/patient-safety considerations,and following all applicable regulations on safety, data protection andintellectual property. We must ensure that all product information is true,
accurate, fully informative, complete and consistent with the product’s
approved labelling and applicable legal requirements.

		
		
		
		
		
		
		
		
		
		
		
		
		
		

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They shall avoid establishing business relations with people
or entities that do not comply with the national and 		international regulations and provisions on the preventionof money laundering and financing of terrorism.

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They shall avoid carrying out any act that could lead to a 		crime of corruption or bribery, pursuant to applicable 		legislation in each case.

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They shall perform the processing of personal data duly 		
guaranteeing the privacy of such data and at all 			times observing applicable legislation.

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They shall defend and protect patents, commercial 		trademarks, copyrights, trade secrets and other information
subject to an intellectual and industrial property right 		
of Werfen. They shall, likewise, respect the intellectual 		and industrial property rights of third parties.

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They shall comply with the standards and principles 		
governing competition, undertaking to compete fairly 		with other market operators, without infringing the applicablelaws governing the defence of competition.

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They shall comply with applicable tax, accounting, financial
and employment regulations.

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They shall comply with public health regulations that could 		
apply in the creation and distribution of products.

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They shall comply with applicable regulations governing 		international trade issues.

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They shall comply with regulations on the protection of 		animals used for experimentation and other scientific 		
purposes and shall apply the recommendations of 		the international organisations and other specialised bodies inthis field.

Furthermore, Werfen relies upon the commitment of its employees to familiarise
themselves and comply with company policies, rules and or procedures, as wellas the contractual obligations agreed upon with third parties

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8 Environment, healthand safety
8.1 Environment
Werfen is involved in protecting the environment by minimising thenegative environmental impact of its companies’ operations and bypromoting sustainable use of natural resources.

10 Dissemination of

the code of ethics
The Werfen Code of Ethics shall be distributed to all its employees in hard copy
as an official and formalised document, and shall also be available for any
consultations on the local intranet and on the corporate website.
Where appropriate, this Code shall be completed and/or developed throughsuch internal action policies or protocols as are considered necessary at any
given time.

We must comply with all applicable environmental laws, rules andregulations in the countries where we carry out business activities, aswell as with the operating and environmental policies and proceduresof Werfen.

8.2 Health and safety
Protecting the health and safety of employees in the workplace is one ofthe priorities of Werfen. It is our responsibility to create optimum and safe
working conditions by following health and safety requirements. This
includes working free from the influence of drugs or alcohol that could
impair one’s ability to work safely and conscientiously. If an employee
is involved in or is aware of an incident or dangerous situation, it is his/her duty to report it to management promptly and, when appropriate, totake corrective action.
Furthermore, it is our responsibility to encourage customer and patient
safety by providing ongoing customer training sessions on Werfen
products, technical assistance, installation, maintenance and service.

11 Ethics Channel
A confidential communication channel has been made available to employees
through which they may send their queries or suggestions concerning this Codeor report situations or concerns surrounding compliance with the same. For
these purposes, Werfen guarantees that there will be no retaliations as a resultof reporting conduct, as well as guaranteeing the confidentiality of the reporter,with regard to third parties and principally with regard to the person involved in
the report and their superiors. Their identity may only be revealed, confidentially,to the relevant people involved in any subsequent internal or legal investigation.
Communication of the foregoing queries or situations may be sent via the
Werfen intranet or sent to the following postal address:

Compliance Officer
WerfenPlaça Europa, 21-23(08908) L’Hospitalet de Llobregat, Barcelona, Spain.

9 Internal Control
Werfen hereby reserves the right to carry out internal checks, always inaccordance with current legislation, to verify the application of this Code, andto prevent activities that could affect legal compliance, integrity, confidentiality
and availability of information.

The aforementioned queries and/or situations shall be handled by theCompliance Officer of Werfen.
Personal data provided through the Ethics Channel or obtained in theadministration of such Channel shall be included in a fi le controlled by Werfen.
Werfen shall keep said data confidential, except for any disclosures that arelegally required.
The Ethics Channel shall be used for the purpose of maintaining compliancewith this Code as well as internal and external standards, and the Code shall be
used to administer those cases in which breach of such standards could haveconsequences in the contractual relationship between the reported employee
and the Werfen company to where they sit.

1908908 Barcelona
Spainwerfen.com

12-2021

Plaza de Europa 21-23
L´Hospitalet de Lobregat