CODE

OF ETHICS

Guerbet works every day to improve patient
diagnosis and prognosis.
To fulfill this mission, we must be ethicallyunimpeachable in everything we do. Ethicalconduct supports our company strategy and ensures
our longevity and credibility.
Doing business in accordance with the principles
of integrity, honesty, fairness, and transparency isa major undertaking for each and every one of us.
This Code of Ethics is a reference document thatprovides guidance for our actions and decisions.
Each of us can refer to the principles set forth in
this code to adopt the best attitude according to
the situation. If you have any questions, feel free tospeak with your manager or with Human Resources.
The Guerbet Ethics Alert Line can also be used by
all Group employees, partners, and third parties toalert senior management to practices that violate
the Code of Ethics.
Ethics is a duty for each and every one of us.
We must all remain committed to upholding thiscode on a daily basis.
David Hale
Chief Executive Officer

2

Guerbet group Code of Ethics

Marie-Claire Janailhac-Fritsch
Chairperson of the Board of Directors

Guerbet group Code of Ethics

3

David Hale
Chief Executive Officer

Jean-François Blanc
SVP Interventional Imaging

EXECUTIVE
 COMMITTEE PLEDGE

4

Philippe Bourrinet
SVP Development, Medical& Regulatory Affairs

Valérie Brissart
SVP Diagnostic Imaging

Sarah Dayre
SVP Technical Operations

Mathieu Elie
Chief Commercial Officer
Asia Pacific

Jérôme Estampes
Chief Financial Officer and SVPBusiness Development & Licensing

Gitte Hesselholt
Chief Commercial Officer
Americas & EMEA

François Nicolas
SVP R&D, R&I and Chief
Digital Officer

Pétra Zalabak
SVP Human Resources & Corporate
Social Responsibility

Guerbet group Code of Ethics

We the members of the Guerbet
Executive Committee pledge topromote honest, balanced, andsustainable development that
respects the law, individuals,
and the environment in which
we operate. In addition, we
promise to support the dissemination and enforcement of our
new Code of Ethics.

Guerbet group Code of Ethics

5WHO IS THISCODE OF ETHICS FOR?
• Everyone. All Guerbet employees.
All Guerbet departments.
All of the Group’s businesses. Allover the world. It is also applicable totemporary staff and external partners
working on our behalf.
• As such, each of us must readand refer to it and comply with its
principles and rules, which govern
our day-to-day behavior.

HOW AND WHY SHOULD
 WE USE THIS CODE OF ETHICS?
• The process is simple.
This code covers all areasthat form the foundation forthe company’s reputation.
It guides our actions,informs our choices, andreinforces our ethicalprinciples in the course ofour day-to-day work.
• Its rules apply mostnotably to situations thatare likely to raise ethics
or integrity issues. Eachone of us must be able
to consult it in order todecide how to proceed indelicate situations.

6

Guerbet group Code of Ethics• However, this code cannot respond to ordeal with all situations exhaustively. That
is why we use policies and procedures,training courses, and other internal resources(managers, compliance managers, etc.) totranspose it into practice, to provide youwith additional assistance.
• This code is unique to us, as in addition to
being a reference for our internal dealings,
it reflects the complexity of our business,echoing its human and strategic challenges.
It allows us to position ourselves with our
stakeholders and move forward with confidence. This Code of Ethics does not belong
to any other company. It conveys ourvalues, represents our beliefs, and reflects
who we are.

Guerbet group Code of Ethics

7

TABLE OF CONTENTSRESPECTING THE COMPANYRESPECTING OUR EMPLOYEES
Health and safety – 12
Promoting diversity and combating discrimination – 13
Combating harassment – 14

Protecting the group’s assets – 32
External communication – 33
Protecting personal data – 34
Protecting confidential information – 35
Preventing insider trading – 36

Social dialogue – 15

PRESERVING THE ENVIRONMENTRESPECTING PATIENTSAND HEALTHCARE PROFESSIONALS

Controlling and reducing our environmental impacts – 40
Combating climate change – 41

Product quality and safety – 18
Product information – 19Interactions with healthcare professionals – 20
Interactions with patient associations – 21

HOW TO REPORT AND EXPRESS YOUR CONCERNSACTING WITH INTEGRITYIN BUSINESS AFFAIRS
Commercial and fair competition law – 24
Combating corruption – 25
Conflicts of interest – 26
Responsible purchasing – 27
Lobbying – 28

8

Guerbet group Code of Ethics

We encourage you to express yourconcerns directly to your manager
or your HR, Legal or ComplianceManager, depending on the situation.
The Guerbet Ethics Alert Line has also
been specially developed for thispurpose and can be reached at thisaddress:
https://report.whistleb.com/en/
GuerbetEthicsAlertLine

It is open to everyone, anywherein the world, including company
employees and external
contractors. Reports may be madeanonymously.
For more information, theGroup has developed aprocedure describing howreports are collected, processed,
and managed securely andconfidentially.

Guerbet group Code of Ethics

9

RESPECTINGOUR EMPLOYEES
Respecting our employees is oneof our central concerns, as evidenced
in our "CARE" value.
The Group believes that the men and women
who work at the company are the driving force
behind its success. Their well-being and safety
are a guarantee of lasting performance. Within
this people-friendly framework, Guerbet relies
on a strong health and safety culture, promotes
diversity, does not tolerate any discriminationor harassment towards others, and bases
its sustainable development on listening
and social dialogue.

10

Guerbet group Code of Ethics

TABLE OF CONTENTS

Guerbet group Code of Ethics

11

HEALTHAND SAFETY

PROMOTING DIVERSITYAND COMBATINGDISCRIMINATIONAt Guerbet, the health and safety of our employees and external contractors is our
top priority. "Zero accidents" is our goal now more than ever. With this in mind, theGroup is pursuing a policy of continuous improvement. It complies with the applicablelaws and regulations in this area, wherever it conducts its business.
How do we do our part as employees?
• We understand the risks and apply and enforce the Group’s rules and best practices for occupational
health and safety.
• We escalate suggestions for improving health and safety to our manager and/or our local EHS
Manager.
• Without putting ourselves at risk, we move to stop any hazardous situations that have been detectedby delaying them or correcting them ourselves.
• We work proactively to ensure our collective safety by taking care of ourselves, our colleagues,
and our work environment.
• We report to our manager any health and safety deviations, risks, and events (incidents, near misses,
accidents) that we may notice.
• We participate in the implementation of occupational health and safety initiatives.

FOR MORE
INFORMATION
If youhave anyquestions about
health and safety,
you should consult
your manager oryour local EHS
Manager.

12

Guerbet group Code of Ethics

There was a hole in the ground in the parking lot, andI tripped. Luckily I didn’t hurt myself. Do I have to report
this near miss?
Yes. The Guerbet procedure specifies that all incidents, near misses,
and accidents, including any first aid, must be reported to yourmanager or via the existing tracking system. This is crucial for
eliminating or reducing the risk, and thereby preventing any accident
from occurring or reoccurring. Sharing your experiences helps
to improve safety for all Group employees.
I notice that a colleague or a contractor uses a cutter
without wearing gloves. I am not their manager and I am
not part of the EHS team. Should I intervene to stop thissituation?

Guerbet believes that employee diversity is an asset as well as an opportunity todevelop the Group’s sustainable performance, innovation, and creativity. Guerbet
promotes inclusion, applies zero tolerance in the fight against discrimination in all its
forms, and incorporates these topics into its managerial training.
How do we do our part as employees?
• We promote diversity, regardless of gender, age, marital status, sexual orientation, disability, nationalor ethnic origin, or religious or political beliefs, in recruitment and career development.
• We report any act of discrimination that we may experience or witness using the resources andmechanisms made available to us by the company.
• We strive to ensure that what we say to others never seems inappropriate or is misinterpreted.
• We are aware that there are severe professional and criminal penalties for any form of discriminationthat has the purpose or effect of violating dignity or creating an intimidating, hostile, degrading,humiliating, or offensive environment.

I am in a meeting with male colleagues to present
the five-year sales forecast. Someone mentions
that the skirt that I’m wearing alleviates the bad
news, and I receive a few teasing comments.
What can I do?
You should feel free to react immediately to theseunacceptable comments. In addition, it is important for the
meeting organizer to intervene to correct this behavior andremind the participants of our "CARE" value. Finally, you
can refer the matter to your manager or HR Manager.

FOR MORE
INFORMATION
If you have any
questions about
discrimination, you cancontact the Legal Department
or the Human Resources
Department.

Yes. This is a situation that can lead to a serious accident. In thiscase, we all have a duty to act by immediately putting a stop to thesituation and initiating a discussion on how to work safely.

TABLE OF CONTENTS

Guerbet group Code of Ethics

13

COMBATINGHARASSMENT
SOCIAL DIALOGUE
Guerbet is committed to maintaining a safe and peaceful work environment, freeof any acts, comments, or behaviors likely to constitute a form of harassment.
Accordingly, the Group condemns all types of harassment toward others, whether
psychological or sexual, and applies a zero-tolerance policy in this area.
How do we do our part as employees?
• We can reach out to the Group’s liaison staff, who are recruited by Human Resources.
These volunteers are here to listen to any employee who does not feel comfortable in theirprofessional environment, especially in the event of harassment.
• We take part in harassment awareness training courses developed for managers by the Human
Resources Department. These courses meet the most rigorous standards in this area.
• We encourage all employees to speak out in the event of harassment and not to continue suffering.
• As managers, we are particularly attentive to maintaining respect between employees and ensuring
there is no aggression, disparagement, or discrimination toward others.
• We are aware that there are severe penalties for any proven act of psychological or sexual
harassment.

FOR MORE
INFORMATION
Contact your HR
Manager or meet withyour liaison.

14

Guerbet group Code of Ethics

After a meeting, one of my colleagues offers mea drink with them. I refuse, but they heavily insist,claiming that it’s just about discussing a project that
we have to present at the end of the month. This
is at least the second time that they have been thispersistent. What can I do?

The Group has always encouraged dialogue with employee representative bodies,
which it considers to be full-fledged partners.
For Guerbet, social dialogue is conducted on the basis of mutual trust. It can bea lever for performance and a driver of transformation. It is based on transparency,
communication, respect, and a shared commitment to achieving results. Similarly,
union rights are recognized and respected in all countries where Guerbet operates.
How do we do our part as employees?
• We can freely join the union of our choice.
• We can participate in the election of employee
representatives.
• To answer any questions or address any
individual or collective issues, we can directly
contact employee representatives, employee
representative bodies, or trade unions,depending on the country.

This type of behavior is unacceptable at Guerbet. You arestrongly encouraged to share this with your manager and with
Human Resources.

TABLE OF CONTENTSFOR MORE
INFORMATION
Contact the Human
Resources Department
or employee representative
bodies in your country.

Guerbet group Code of Ethics

15

RESPECTING PATIENTSAND HEALTHCAREPROFESSIONALS
It is essential for Guerbet
employees to meet the
expectations of patientsand healthcare professionals
by ensuring the availability ofsafe, effective, and high-quality
products and services, as well as
by disseminating useful, reliable,
and substantiated information.
In addition, Guerbet manages
its interactions with healthcare
professionals in strict compliancewith local regulations. The Group
interacts with patient associations
and patients in a respectful andtransparent manner.

16

Guerbet group Code of Ethics

TABLE OF CONTENTS

Guerbet group Code of Ethics

17

PRODUCT QUALITY
AND SAFETY

PRODUCT
INFORMATION

Guerbet has always made patient safety a top priority as clearly described in the
Guerbet Quality Vision and Quality Policy.
Indeed, thanks to its quality policy, its quality management system, its drug safety/
medical device monitoring processes, and its continuous improvement program,the Group designs and manufactures contrast media and medical devices that havedemonstrated a favorable benefit/risk balance. Additionally, quality is assured
through rigorous testing, in accordance with current legislation, standards, and bestpractice guidelines.
How do we do our part as employees?
• We all feel invested in the quality policy, which applies to all our activities, and we are committed
to systematically implementing quality, safety, and product tracking standards.
• We feel responsible for the quality and performance of the product or service and for patient safetyat every stage of our operations.
• We re-evaluate our products’ benefit/risk balance very frequently by continuously monitoring
the global scientific literature, conference presentations, and adverse events reported to Guerbet.
• We deal with customers’ questions and complaints as quickly as possible.
• We regularly refer to the quality policy, the quality manual, and best practice policies
and procedures.
• Continuous improvement is facilitated through the introduction of quality improvements that matchthe current level of familiarity with our products, methods and work processes.

FOR MORE
INFORMATION

There’s a problem with my production
line. The line might be working, but
I have doubts and I’m afraid that thequality of the products will be affected.
What should I do?

If you have questions about thequality and safety of our products,
please refer to the Guerbet Quality
Manual on guerbet.com.

If you encounter a problem on a production
line that may impact product quality, you
should immediately notify your supervisor or the
local quality manager. If the quality problem
is verified, always make sure that this information
is immediately reported and documented.

Guerbet pursues a policy of responsible promotion and respects the patient-physician
relationship. As such, the Group is careful to disseminate objective, non-misleading
information that supports the rational use of its products. All promotional materials
are duly checked and approved to ensure regulatory compliance.
How do we do our part as employees?
• We comply with all regulatory requirements governing the promotion of drugs and medical devices• Since our contrast media are prescription drugs, promotion is exclusively reserved for healthcare
professionals, and we do not advertise them to the general public.
• We verify promotional information before use, from a scientific, technical, regulatory, legal andethical point of view, depending on the product.
• We promote our prescription products only for indications duly approved by the competent healthauthorities.
• We ensure that all promotional information about our products is based on relevant data andevidence.

I would like to promote a Guerbet productat an international conference that is not registeredin every country in the world. Is that allowed?
Yes, that is allowed only if it is authorized by theregulations of the country in which the conference takes
place and complies with the conditions that accompany
this authorization. You should therefore contact the local
Compliance Manager for more information.
As a Guerbet employee, can I retweet a statementfrom a healthcare professional praising one of ourpharmaceutical products?
No. Such an action can be construed as public promotion.
Contrast media are subject to medical prescription, andtherefore public promotion is prohibited by law. As such,
you should not relay this message.

FOR MORE
INFORMATION
Refer to the Group’s
policies on promotional
practices. Depending on thesituation, you can also contact
your manager, your ComplianceManager, or the Legal
Department.

You can also contact the Quality
Department.

18

Guerbet group Code of Ethics

TABLE OF CONTENTS

Guerbet group Code of Ethics

19

INTERACTIONSWITH HEALTHCAREPROFESSIONALS

Guerbet favors scientific interactions with healthcare professionals to support
research or medical training, in compliance with local regulations.
To avoid any risk of conflict of interest that could harm public health, the Grouppublishes its interactions with healthcare professionals in accordance with applicableregulations. To protect patient health, Guerbet respects the independence of
healthcare professionals and requires its employees to behave ethically in theirbusiness practices.
How do we do our part as employees?
• We ensure that our interactions with healthcare professionals are lawful and appropriate to preserve
their independence.
• If we are involved in sales, marketing, promotion, research or product development, we ask the local
Compliance Manager for information on the applicable requirements and codes of conduct in the
country of practice of the healthcare professional with whom we are interacting.
• Any research, consulting, assessments, training, or conference presentations performed on behalfof Guerbet must be formalized by a contract. We undertake to ensure that the associated payments
and allowances comply with the limits described in our internal rules and are disclosed publicly
in accordance with applicable regulations.
• Donations to support research or training for healthcare professionals are subject to an internal
compliance review• We verify that providers who are likely to interact with healthcare professionals on our behalf comply
with the applicable regulations in this area.

INTERACTIONS WITH
PATIENT ASSOCIATIONSPatients are at the heart of what we do. The Group interacts with patient associations
and patients themselves in a transparent and non-promotional manner. We work withthem ethically and legally, from the early stages of development through to market
launch and beyond. By exchanging views and listening to patients’ experiences andthe challenges they face, we can shape the future of medical research and disease
management, from diagnosis to treatment, to better address unmet patient needs.
Only through open and transparent dialogue between patients and the industry
can we ensure that the patient’s perspective becomes an integral part of the way
diagnostics, drugs, and medical devices are researched, developed and delivered
to patients. The rules for collaboration between Guerbet, patient organizations,and patients are defined in a dedicated corporate policy to ensure transparent andethical relationships.
How do we do our part as employees?
• We have partnerships with patient associations that allow us to further our knowledge of patient
pathologies, improve the information provided to patients on products and services, and optimize thecare they receive.
• We provide factual information that is reliable and based on scientific evidence.
• We guarantee safety and protect the rights of patients who participate in clinical trials.

I am a Guerbet employee, can I have contact
with a patient association?

FOR MORE
INFORMATION
Refer to the Group’s
policies oninteractions with healthcare
professionals. If you haveany questions or concerns,
you can also contact yourlocal Compliance Manager.

20

Guerbet group Code of Ethics

I would like to contact a radiology expert/
hospital practitioner to give a presentation at aninternational conference. He would like his travel
and hotel expenses to be covered by Guerbet.
Can I agree to this?
Travel costs may be covered if they are related to a legitimate
service and limited to a reasonable amount. This coveragemust always be approved by your supervisor and the local
Compliance Manager to ensure that you are complying with
Guerbet policy and the applicable regulations in the country
where the healthcare professional practices.

Yes, but you must disclose your position at Guerbet and meetwith them in a specific, non-promotional setting.
I’m meeting with a patient association. Can I talkabout Guerbet products and services?
Yes, you can mention them, but you must be careful not
to promote them commercially so as not to induce sales
or make the members of the association uncomfortable.

TABLE OF CONTENTSFOR MORE
INFORMATION
For further
information, pleaserefer to the Group’s Patient
Relations Policy and contact
the Group’s head of patientassociations.

Guerbet group Code of Ethics

21

ACTING
WITH INTEGRITYIN BUSINESS AFFAIRS

22

Guerbet group Code of Ethics

Guerbet aims to be a trusted
partner for all its stakeholders.
The Group conducts its business withethics and integrity, two essential
principles for establishing andmaintaining credibility. For this reason,
Guerbet does not tolerate any practicethat could cast suspicion on the honestyof its employees or its activities, suchas unfair trading practices, corruption,
conflicts of interest, irresponsible
purchasing, or lobbying that does notcomply with applicable rules.

TABLE OF CONTENTS

Guerbet group Code of Ethics

23

COMMERCIAL
AND FAIRCOMPETITION LAW

Guerbet respects the rules of open, fair and honest competition wherever theGroup operates. As such, it prohibits any price fixing, protects its customers andpartners against unfair commercial practices, and is committed to gathering relevant
competitive intelligence.
How do we do our part as employees?
• We follow sales processes and the rules for proper bidding in all the countries where we operate.
• We refrain from any exchange of sensitive commercial, financial, or other information withcompetitors or any prohibited commercial practices (cartels, price fixing, collusion on production/
sales volumes or costs, market sharing; etc.).
• During conferences or professional association meetings, we observe the same rules as those
applicable to our competitors, and we prohibit any detailed discussions contrary to competition
law. When in doubt, we abstain from or leave the meeting immediately and maintain a record of
our refusal or opposition. In addition, we inform our supervisor and the Legal Department as soon
as possible.
• We refrain from seeking out any information on our competitors through corporate espionage, theft,
bribery, or any other illicit methods.

FOR MORE
INFORMATION
If you arelooking for
further information or
advice on businesspractices, please contact
your business manager
or the Legal Department.

24

Guerbet group Code of Ethics

I am attending a conference and meet a former
colleague who works for a competitor. He invites
me to have coffee near our stand and asks me how
the business is going, and whether I managed to getbetter prices in the geographical region he wasin charge of. How should I respond?
You should suggest that he move away from our stand and tell
him that you do not wish to discuss business or prices because
it is forbidden for competitors to discuss these topics. Then, talkto your manager and, if necessary, the Legal Department.

COMBATING
CORRUPTION

Guerbet does not tolerate any form of corruption or influence peddling. The trustof our stakeholders and our long-term success depend on it. Vigilance is therefore
essential for everyone, regardless of hierarchical level or workplace, particularly in
relations with customers, suppliers, prescribers, public officials, and intermediaries.
How do we do our part as employees?
• We are prohibited from promising, granting, or paying any benefit to a "public official" who may
be an agent of government or any administrative authority, particularly if they are involved in healthpolicy, health enforcement, or act under any administrative authorization.
• We are prohibited from offering or giving any benefit to any healthcare professional with theintention of improperly influencing their decision to prescribe, recommend, purchase, or supply
our products.
• We do not seek gifts for ourselves or our family members from a natural person or legal entitywith whom we maintain commercial relations, and we do not accept such items if they are likely
to influence us or give the impression of influencing Guerbet’s decisions.
• We do not make any facilitation payments to expedite certain administrative procedures initiatedor imposed on our company.
• We ensure that any providers or distributors who may interact with other parties on our behalf follow
anti-corruption laws and adhere to Guerbet’s ethical values.

Our distributor says he can get a new contract witha large radiology center if we make a donation
to a charity. I think the president of this associationis the brother of the head of the radiology center.
What should I do?
Do not make the donation and report the matter to theCompliance Department. This appears to be an attempt
to disguise a bribe as a donation. A dishonest distributor
or agent may also charge higher than expected feesor commissions. It may use part of them to bribe the agents
responsible for issuing the contract.

TABLE OF CONTENTSFOR MORE
INFORMATION
If you need more
information, you
can consult the Group’s
anti-bribery policy
or contact your local
Compliance Manager.

Guerbet group Code of Ethics

25

CONFLICTS
OF INTERESTRESPONSIBLE
PURCHASING

The personal, social, financial, or political relationships or interests of Guerbet
employees or their family members may conflict with those of the Group. In this case,
Guerbet expects its employees to be transparent about relationships or activities
that may influence their decisions on behalf of Guerbet, and to protect the interestsof the company without deriving any personal benefit.
How do we do our part as employees?
• The decisions we make always protect the interests of the company.
• Our professional activities must not be exploited to yield any personal benefit for ourselves
or our family members and loved ones at the expense of the Group’s interests.
• In accordance with the procedures in force, we notify our supervisor in writing of any realor potential conflicts of interest, so that the company can determine an appropriate response to eachsituation.
• We do not accept gifts from third parties (suppliers, distributors, etc.).
• We decline all invitations to events, meals, and other hospitality requests that could compromise
our independence or distort our judgment regarding a third party, or be perceived as such.

FOR MORE
INFORMATION
If you have any
questions or concerns
regarding conflicts of interest,
please contact your manager,
HR Manager or local
Compliance Manager,
or refer to the Group’s conflictof interest policy.

26

Guerbet group Code of Ethics

For one of my projects, I would like to suggest
a supplier run by my brother-in-law.
What precautions should I take?
In this case, there may be a conflict of interest, so you must
inform your manager, explain and document the situation
in a transparent manner, and refrain from participating in thedecision to list the supplier. However, please keep in mind thateven the appearance of a conflict of interest must be avoided.

Guerbet pursues a responsible purchasing policy that seeks to cultivate collaborative,
balanced, and healthy relationships with its suppliers. Guerbet asks its procurement
employees to act in accordance with an Ethical Purchasing Charter. The selection
criteria for our providers rely on open and fair competitive bidding rules. In addition,
Guerbet only works with principled suppliers who respect human rights, labor laws,
the environment, and business ethics.
Guerbet has decided to promote its social and environmental values to its suppliers
and to ask them to do the same with their own economic partners.
How do we do our part as employees?
• We follow our Ethical Purchasing Charter, and we make sure that we do not accept, either directly
or indirectly, gifts, favors, benefits in kind, commissions, or money payments.
• We do not provide their competitors with any information collected from a supplier during
a negotiation or a call for tenders.
• The creations offered by a contractor are subject to copyright and cannot be used without prioragreement.
• Listed providers must reflect our values. For example, we reject any supplier who uses forced labor,child labor, or illegal labor, and who does not ensure safe and healthy working conditions for theiremployees.

I am conducting a call for tenders for our officesupplies. The first supplier I contacted offers
high‑quality products, but they’re expensive.
Two other suppliers don’t have products that are
as good, but they’re cheaper. Can I tell the firstone about the answers I received from the othersuppliers, to try to get them to lower their prices?
No. You can tell them, in a very general way, that othersuppliers offer you better prices, but without revealing
the prices or the identity of the respondents to your callfor tenders. Otherwise, you would be giving them confidential
information about their competitors, which would be unethicaland, in many countries, against the law.

TABLE OF CONTENTSFOR MORE
INFORMATION
If you have any
questions about
responsible purchasing, pleaserefer to the Ethical Purchasing
Charter, the supplier Codeof Ethics, or contact thePurchasing Department.

Guerbet group Code of Ethics

27

LOBBYING

To help our stakeholders understand the challenges facing Guerbet, we strive
to explain what we do, why we do it, and how it impacts the company. In a spirit ofaccountability and transparency, Guerbet participates in constructive dialogue withpublic authorities and their representatives in charge of drafting laws and regulations
that impact our business. Guerbet complies with the local regulations in force andis recorded on transparency registers, where applicable.
Guerbet has no political affiliations.
What is our role as employees?

FOR MORE
INFORMATION
If you would like more
information on lobbying for
Guerbet, please contact your local
management or the Group’s General
Secretariat/Public Affairs Department.

28

Guerbet group Code of Ethics• All the information we provide to publicauthorities is accurate, precise,and substantiated.
• We do not influence decision-making bodies
with misleading or erroneous information,or by offering compensation or any otherbenefit.
• We do not fund or support any political party,
politician, or other political institution on behalfof Guerbet.

A bill is being drafted in the country where I work for Guerbet;
can I go and promote the Group’s position to a member of a committee
or Congress?
Yes, but before taking any action, you must first report to your supervisor and/or yoursubsidiary management so that this plan is approved and coordinated with otherpossible initiatives. Before attending any meetings, you will have to prepare a written
memo on the information you wish to convey to this elected official.

I am a candidate in an election, can I ask for support from Guerbet?
Guerbet respects everyone’s political opinions and personal commitments. These beliefs
must solely be expressed in a personal capacity, never on behalf of Guerbet.
Other colleagues may provide you individual and personal support for politicalactivities, but this support is cannot be construed as Guerbet support. As such, underno circumstances can you claim to have the Group’s support in your efforts. Similarly,
an employee involved in a political campaign may not use company resources(work time, photocopiers, equipment, etc.) for this purpose.

TABLE OF CONTENTS

Guerbet group Code of Ethics

29

RESPECTINGTHE COMPANY

Guerbet employees are committed
to protecting the Group’s properties
that they work in. They are careful
to uphold the company’s brand image in theiractions and statements. They shall refrain fromusing the Group’s tangible or intangible assets
for personal purposes, including any private
data or confidential information they may
have in their possession. They are also careful
not to commit insider trading.

30

Guerbet group Code of Ethics

TABLE OF CONTENTS

Guerbet group Code of Ethics

31

PROTECTINGTHE GROUP’SASSETS

EXTERNAL
COMMUNICATION

Guerbet’s assets consist of tangible assets (buildings, industrial equipment, information
technology, raw materials, etc.) and intangible assets (know-how, trademarks andpatents, industrial processes, image and reputation). These assets allow us to implement
our strategy, achieve our objectives, and ensure our longevity.
How do we do our part as employees?
• We use company assets efficiently and for business purposes and take any necessary measures
to protect them from damage, loss, or theft.
• We refrain from using the company’s tangible or intangible assets for our personal benefit or the
benefit of a third party.
• We maintain our assets under optimal conditions and regularly conduct inventories of our physicalassets, including when they are with third parties.
• We refrain from removing property from Guerbet premises unless it is duly authorized or necessary
for our business.
• We secure access to our premises, our network, and our information systems.
• We comply with the Group’s IT security rules: for example, we do not share our passwords
or personal access codes, and we are particularly careful when receiving e-mails from unknown
senders or individuals pretending to be an acquaintance.
• When an employee leaves the company, each manager ensures that the assets assigned to them
are returned to the company, and that their access to the information systems is deactivatedin a timely manner.

FOR MORE
INFORMATION
If you would likemore informationor have a question aboutprotecting Guerbet assets,
please contact theGroup’s Internal Control
Department or theGroup’s Chief Information
Security Officer.

32

Guerbet group Code of Ethics

Someone I don’t know is on our premises without
an identification badge or a Guerbet representative.
I’m not sure they’re allowed to be here, what should I do?
Only duly authorized individuals are allowed on a company site.
In the case of a third party, a Guerbet representative must ensure that thisperson complies with access and security rules. Check with this person
and, if necessary, direct them to the reception desk and inform yourmanager or the Security Department.
I’ve just admitted an external consultant who wants toconnect to the company network with his network cable.
Is this allowed?
No, if he needs to access the Internet, he must use the Wifi Guest.
You must not allow anyone from inside or outside the company to connect
a computer not supplied by Guerbet to the company network and must
notify your manager and the IT Department if necessary.

Group employees are required to communicate responsibly and to pay close attention
to the statements they make to the outside world. As a publicly traded company, any
communication to the media can affect the interests and reputation of the company.
External communication has an impact on Guerbet’s image and must be carefully
prepared.
How do we do our part as employees?
• We do not speak on behalf of Guerbet if we are not duly authorized to do so or we do not haveprior approval from the Group Communications Department.
• If we are contacted by a journalist, we will coordinate in advance with the Group’s Communications
Department before answering any questions from the media.
• We shall refrain from making any disparaging remarks.
• We are very careful when communicating on social media: we comply with the regulations governing
our products (pharmaceuticals and medical devices), we do not publish sensitive or confidential
information, and we respect image rights.

Can I post photosof a Guerbet event on
my LinkedIn, Instagram,or personal Facebook
account?
No. You should neverpost images related
to a pharmaceutical productthat would be construed
as public promotion, just as
you would be very careful
not to publish inappropriate
images or reveal sensitive
or confidential information
about Guerbet. If in doubt,
you should consult the Group’s
Communications Department.

FOR MORE
INFORMATION
Please consult the group’s proceduresfor communicating with the media and using social
media, which are intended for all employees.
If you have any questions or if you have noticed
any negative information or comments about
Guerbet, please contact the Communications Department
immediately:
direction.communication@guerbet.com

Any online reference to an undesirable event thatis spotted by a Guerbet employee must be reported
in accordance with the local procedure.

TABLE OF CONTENTS

Guerbet group Code of Ethics

33

PROTECTINGCONFIDENTIAL
INFORMATIONPROTECTINGPERSONAL DATA

Guerbet has developed and implemented a personal data policy in accordance withthe applicable legislation and the General Data Protection Regulation (GDPR). In thisway, Guerbet protects the privacy of its employees, customers, partners, healthcare
professionals, and patients.
How do we do our part as employees?
• We are all required to comply with the Guerbet data protection policy. Accordingly, we strive to limit
the collection of personal data to what is strictly needed for our business.
• We undertake not to transfer, exchange, or divulge the personal data which we are responsible
for processing.
• Our providers also implement any security measures needed to protect the personal data provided
to them by Guerbet for a project.
• Managers ensure that their employees understand the extent of their responsibilities and receive dataprotection training, where appropriate.

FOR MORE
INFORMATION
Refer to the Guerbet dataprotection policy or contact theGroup Data Protection Officer
dataprotection.officer@guerbet.com

whose role is to ensure company
compliance with the EU General Data
Protection Regulation.

34

Guerbet group Code of Ethics

My laptop has a file with various customers
or prospects, which only I know about
or work with. Can I use or keep it?
No, personal customer data is supposed tobe administered by the customer relationshipmanagement tools set up by the company. Holding
a customer’s personal data on a medium notapproved by the IT Department (USB key, external
hard drive) would also present a security risk.

Confidential information is an integral part of Guerbet’s assets. It is often vital to theGroup’s strategy. The disclosure of confidential information, even unintentionally,
can cause significant harm to the Group, so it is essential that we all be aware of this,especially when we have access to sensitive information. The important thing is to beaware of what is confidential, and to know what precautions to take during externalinteractions to avoid accidental disclosure.
How do we do our part as employees?
• We protect internal, non-public information that is the property of the Group, or any information
entrusted to us by a third party, in accordance with current Group policy.
• This information should only be retained, printed, scanned, copied, transferred, or destroyed
according to the means described in this policy.
• We follow the procedures for protecting intellectual property, particularly when it comes to protecting
the results of research and development activities.
• We do not disclose any information about ongoing research and development activities, or any otherconfidential information, without prior internal agreement.

I am collaborating on a project that must remain
confidential until a given date. I need to confer with
one of my colleagues over email, and I forward
an attachment previously received from a third
party. I inadvertently write to this third party while
trying to send a message to my colleague about theconfidential project. I realize my mistake too late,what can I do?
Check whether you have a confidentiality agreement withthis third party. In any event, the message will need to berecalled using your email account. If it cannot be recalled,
send an email immediately to the third party to inform themthat they have mistakenly received confidential informationthat was not intended for them, and that you would like themto immediately confirm that they have destroyed and deleted
everything, including attachments, by replying to the email.
Finally, report the matter to the project manager in orderto monitor any potential action taken by this third party.

TABLE OF CONTENTSFOR MORE
INFORMATION
For more
information,please refer to theGroup’s confidentiality
policy or contact theLegal Department.

Guerbet group Code of Ethics

35

PREVENTING
INSIDER TRADING

Guerbet is a publicly traded company. All financial communication is regulated andsupervised by the Autorité des Marchés Financiers, or AMF (French Financial Markets
Authority). In this context, insider trading is defined as the use or disclosure ofprivileged information (results of clinical trials, mergers and acquisitions, corporate
strategy, new markets, etc.) for personal purposes, which could affect the Group’s
share price. Such insider trading is strictly prohibited by law and subject to criminal
penalties.

How do we do our part as employees?

FOR MORE
INFORMATION
For further
information, pleaserefer to the Group’s
Insider Trading Prevention
Procedure, or contact theLegal Department.

36

Guerbet group Code of Ethics• If, in the course of our work, we become awareof privileged information, we do not use it to tradein Guerbet securities.
• Managers, employees, and people who have accessto privileged information do not use it or put themselvesin a position where they are suspected of having used
it, particularly in the lead-up to the announcementof financial results or "significant" transactions.
• We comply with the applicable laws and with the Group
procedure for preventing insider trading and selling andpurchasing securities (applicable to Guerbet employees
and corporate officers, as well as their immediate family
members).

I’m an operator on a production line, and I’m proud to be working
on a new molecule that could revolutionize one of our markets.
Can I talk about it with my friends and family?
No. You may say that you are working on a new product, but you may not give
any further information that could fall into the wrong hands and influence Guerbet’s
share price.

TABLE OF CONTENTS

Guerbet group Code of Ethics

37

PRESERVINGTHE ENVIRONMENT
Guerbet is fully aware of theenvironmental challenges facing theworld and pursues its development
in a sustainable manner. The company
is committed to reducing its environmental
footprint across all of its operations, fromraw material sourcing to the production ofcontrast media and medical devices, throughto customer delivery. The Group is committed
to controlling its processes and waste, while
innovating to reduce their impact. The Group
is mindful of the challenge of global warming.
All these initiatives are conducted in strict
compliance with applicable regulations andstandards, wherever Guerbet operates.

38

Guerbet group Code of Ethics

TABLE OF CONTENTS

Guerbet group Code of Ethics

39

CONTROLLING
AND REDUCING OURENVIRONMENTAL IMPACTS

COMBATING
CLIMATE CHANGE

Guerbet implements solutions to protect the environment by controlling its industrial
facilities and taking steps to reduce its environmental impacts throughout its
value chain (using natural resources sustainably, controlling production processes,
developing innovative processes, and controlling various types of waste).
How do we do our part as employees?
• We develop an ethical awareness toward the environment, both as individuals and as citizens.
We can all take action every day to limit carbon emissions, including within the company and duringbusiness trips.
• We adopt the right behaviors (following sorting rules, driving in an eco-friendly way) and makesuggestions for environmental protection (setting up a new sorting process, offering to buy paper).
• In the course of our work, we must be careful to limit waste (with well-tuned machinery) and energy
consumption (turning off the lights when leaving, limiting the use of air conditioning, etc.) and reduceand sort waste (limiting the use of plastic cups, etc.).
• We immediately report any degraded situations that could have an unusual impact on resources
or generate excessive waste.
• Instructions are followed to avoid any environmental accidents.

I see a water leak. Should I intervene to stop
this situation?

FOR MORE
INFORMATION
If you would likemore informationor have any questions,please refer to yourmanager or your EHS
manager.

40

Guerbet group Code of Ethics

Yes. It is your responsibility to act, either by stopping
the situation if it is feasible and safe to do so, or by reporting
it immediately.
A control system that prevents pollution is outof order. I just learned that it will take several days
before it can be repaired. I am afraid that reporting
it will force us to stop production, when we are
already very behind schedule. What should I do?

As a socially responsible company, Guerbet develops programs to account for the risksof climate change and reduce its carbon emissions.
How do we do our part as employees?
• Whenever possible, we use maritime transport rather than air transport to ship our products.
• We conduct a continuous improvement program for suppliers that have the largest carbon footprint,
or we select those that have the smallest footprint.
• We take action at our industrial sites to limit our greenhouse gas emissions.
• We use remote means of communication such as videoconferencing, and thereby limit our travel.

I need to buy some equipment, and I obviously
take into account the budget when making thesepurchases. Do I have to buy the cheapest products?
No, this is not the only criterion. In addition to price, youmust also look at their impact on the environment and climatechange (reduced energy consumption, recyclable material,
share of recycled material, etc.).

FOR MORE
INFORMATION
If you would likemore informationor have any questions,please refer to yourmanager or your local
EHS manager.

You should report this situation as soon as possible to yourmanager or your local EHS manager so that you can work
together to find a solution. If necessary, production will haveto stop.

TABLE OF CONTENTS

Guerbet group Code of Ethics

41

www.guerbet.com

Failure to comply with applicable
local law, specific regulations, andGroup procedures incorporatingthem can have serious consequences not only for Guerbet, but also foranyone involved. Violation of thelaws and regulations referred to in
the various chapters of the Code,in particular those relating to competition and anti-corruption laws,
may be subject to civil or criminal
penalties or potential legal actions.