DFE Pharma Code of Conduct for Business Partners
Scope
The present DFE Pharma Code of Conduct for Business Partners sets forth the basic
principles of good business practices that DFE Pharma GmbH & Co. KG and its affiliates(jointly: “DFE Pharma”) expects all of its supply chain business partners - suppliers of
any type of goods or services, logistics and transport service providers, distributors, agentsand other sales intermediaries - (the “Business Partners”) to comply with.
1 Safety with respect to products and people
All products supplied to DFE Pharma or distributed under DFE Pharma’s brands must meet
our strict standards for product quality, consumer health and product safety. Therefore,
DFE Pharma expects its Business Partners to comply with the following requirements
Quality control: Business Partners will meet generally recognized or contractually agreed
quality requirements in order to provide goods and services that consistently meet DFE
Pharma’s expectations.
Health and safety: Business Partners shall comply with all applicable quality, health, safety
and environmental regulations, and will protect their employees from any chemical,
biological and physical hazards. Business Partners will provide appropriate controls, safe
work and emergency procedures, including preventive measures and/or protective
equipment and training to exclude or mitigate health and safety risks in the workplace.
2 Rights of employees and human rights
DFE Pharma expects its Business Partners to respect and support internationally recognised
human rights for all stakeholders, such as the OECD Guidelines for multinational
enterprises, the ILO Declaration on Fundamental Principles and Rights at Work and theUnited Nations Universal Declaration of Human Rights. In particular, we expect ourBusiness Partners to comply with the following principles:
Fair Treatment: Business Partners will provide their employees with a workplace free of
inhumane treatment, sexual harassment, sexual abuse, corporal punishment or torture,
mental or physical coercion or verbal abuse of employees, or the threat of any suchtreatment.
Working Hours, Wages and Benefits: Business Partners´ working hours will not exceed themaximum set by applicable national law. Compensation paid to employees will comply withapplicable national wage laws and the employees will be paid in a timely manner andreceive adequate training in order to perform the tasks assigned to them.
Freedom of Association: Business Partners will respect the rights of their employees toassociate freely, join labour unions, seek representation, join works councils and engage
in collective bargaining.
Child Labour Avoidance: Business Partners must avoid any sort of child labour in theirbusiness operations (any person under the age of 15 or 14 according to applicable locallaws).

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Freely Chosen Employment: Business Partners shall not use any forced, bonded orindentured labour or involuntary prison labour.
Non-Discrimination: Business Partners will provide that no employee will be unfairly
disadvantaged or favoured because of ethnic or racial status, colour, nationality, descent,religion, caste, gender, age, physical characteristics or appearance, sexual orientation,
union membership, political affiliation, HIV/AIDS or parental status.
3 Avoiding conflicts of interest
DFE Pharma ask from its Business Partners to avoid even the appearance of a possible
conflict of interest and to be totally transparent with DFE Pharma if a conflict with more
personal interests would arise.
4 Anti-corruption, gifts and payments
DFE Pharma expects its Business Partners to stand for honest business practices and not
to commit or allow any form of bribery. Business Partners shall not provide or promise
anything of value to any person with the aim of improperly receiving preferential treatment
or request or accept a bribe or request or allow others to do so.
Business Partners shall only use gifts and entertainment to develop or strengthen business
relations, to show appreciation or to create goodwill in a well-timed, moderate andinfrequent manner, and not in excess of locally acceptable business practices. In no event
shall gifts or entertainment be offered or accepted to put the recipient under pressure toreturn a favour or to influence a business decision.
5 Fair competition and export control
DFE Pharma expects its Business Partners to conduct their activities in a fair andcompetitive manner in full compliance with applicable competition laws and regulations. In
particular, Business Partners will not make agreements or arrangements that influence
prices, conditions, strategies or customer relations, especially regarding participations intender procedures.
Furthermore, Business Partners will comply with all applicable laws and regulations regarding
the import and export of goods, international trade control laws and regulations, economic or
financial sanctions or trade embargos, services and information into foreign countries as well
as applicable laws and regulations on combating international terrorism.
6 Fair communication
DFE Pharma expects its Business Partners to communicate in an open, respectful, andprudent manner.
7 Sustainability
DFE Pharma expects its Business Partners to run their business in an environmentallysound and sustainable manner by minimising the impact of its processes and products onthe environment and at the same time maximising its efforts to secure health.
In particular, Business Partners will have adequate business processes in place to ensure
the safe handling, movement, storage, recycling, reuse, or management of waste, air2emissions and wastewater discharges. Business Partners are expected to use naturalresources (e.g. water, sources of energy, raw materials) in an economical way.
8 Protection of business secrets and intellectual property
DFE Pharma expects its Business Partners to properly handle all confidential informationof DFE Pharma and others and protect it against unauthorised disclosure.
Furthermore, Business Partners shall respect all intellectual and industrial property rightsof DFE Pharma, and use any such intellectual and industrial property rights only inaccordance with the terms agreed from-time-to-time with DFE Pharma.
9 Data protection
DFE Pharma expects its Business Partners to respect the privacy rights of employees,
customers, suppliers and other enterprises. Business Partners shall only collect, process,transmit and use personal data insofar as reasonably required for communicated businesspurposes, and in compliance with applicable laws and regulations on data protection.
10 Integrity of (financial) reportingDFE Pharma expects its Business Partners to have a duty to ensure that their financial andnon-financial documents, records and reports are accurate, complete, consistent and upto-date.
11 Prevention of fraud
DFE Pharma does not accept any behaviour intended to deceive or mislead others. BusinessPartners shall contribute to preventing fraud within their own enterprise.
12 Speak Up
If a Business Partner suspects that DFE Pharma, any of its employees or any third party
that DFE Pharma is doing business with, does not act in line with DFE Pharma’s Compassfor Good Business Conduct, with these Business Practices or with applicable laws orregulations, DFE Pharma encourage its Business Partners to speak up.
Business Partners may do this by contacting the Speak Up Webservice, available throughthe following Website: https://www.frieslandcampina.com/contact/speak-up/
13 Compliance management
DFE Pharma expects its Business Partners to ensure that the principles set out in this Codeof Conduct for Business Partners are complied with, and that adequate measures are
implemented to monitor such compliance and to take corrective action in the event of noncompliance.
In the event of a material violation of this Code of Conduct for Business Partners, andwithout prejudice to any further rights DFE Pharma may have under applicable laws andregulations or an agreement with the Business Partner, DFE Pharma reserves the right toterminate the business relationship with the Business Partner.

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