Palla Pharma Code of conduct

Introduction

The Board of Directors and management of Palla Pharma Norway AS (the “Company”) are committed to maintaining good standards of corporate governance, ethics and conduct in all the company’s activities, including the company’s interaction with shareholders, employees, business partners, customers, suppliers, society, and the environment in which the company operates.

The company acknowledges its responsibility as a developer of pharmaceutical products and that it must conduct its business in accordance with relevant Norwegian and international regulatory requirements and laws.

All employees of the Company play an important role in establishing, maintaining, and enhancing the Company’s reputation by ensuring compliance with the high standards of ethics and conduct to which the Company is committed. The Company requires that its employees, all directors, and all tenures demonstrate the highest levels of professionalism in all aspects of their work to facilitate the Company’s compliance with the Code of Conduct.

Generally

Our vision of the perfect interaction requires us to take responsibility for the areas at our disposal. This applies to employees, customers, suppliers, and society at large.

Palla Pharma shall appear skilled and professional and have high ethical standards in all processes. This affects both business operations and employee actions. Our employees shall act honestly and objectively and refrain from actions that may undermine confidence in Palla Pharma.

The guidelines cannot cover all matters, and individuals must at all times assess their own behaviour in relation to the guidelines and what constitutes ethical conduct. In case of doubt, one should refrain from the action or consult with the immediate superior.

Employees

All employees shall be given the opportunity to familiarise themselves with regulations that are relevant to the individual’s work. It is the employee’s responsibility to comply with applicable regulations and internal guidelines.

Everyone has a duty of confidentiality regarding matters they become aware of through the work performance for Palla Pharma. This applies to matters related to employees, partners (e.g.: customers / suppliers) and operations in general.

We offer equal opportunities regardless of race, gender, nationality, skin colour, religion, ethnicity, or other characteristics.

We do not accept discrimination, sexual harassment, or bullying. Anyone who feels bullied or discriminated against must be taken seriously.

Employees who have genuine suspicions of censurable conditions must have a safe environment where they can speak up without fear of reprisals or harassment.

Business ethics

Palla Pharma strives to operate in a responsible manner that provides the most value for our customers and inspires development and interaction.

Directors and employees of the Company must not receive personal financial rewards or financial motivations in return for making business decisions.

Directors or employees must not accept gifts or other benefits where this could affect, or be considered to affect, the exercise of objective business judgment in decision-making processes.We are vigilant for censurable conditions, also outside our area of responsibility.

We seek to report if we uncover or suspect criminal matters, or circumstances that may adversely affect our partners (e.g.: customers/suppliers).

Palla Pharma does not tolerate corruption and strives to ensure that this does not occur in our business operations.

Environment

The company aims to provide a safe environment to work in, and for customers and suppliers to visit.

Everyone is expected to comply with and comply with applicable occupational, health, safety and risk management policies of the Company and applicable legislation at all times. All work confidently in accordance with applicable internal procedures/policies and regulatory expectations to strive to protect the health, safety and well-being of themselves, other employees, customers, and suppliers.

The Company strives to reduce the environmental impact of its business activities and will seek to do so through continuous improvement of environmental performance, protection, and safety.

The Company is committed to providing effective support and training for its employees to assist them in their responsibilities to ensure a safe workplace and to reduce the environmental impact of their activities.

Responsibility

Managers at all levels have a particular responsibility to ensure that their own and employees’ behaviour is in accordance with the ethical guidelines in force at any given time.

Disciplinary and/or judicial action will be taken where an individual or group of individuals fails to comply with relevant laws, regulations or engage in conduct that is either unethical, dishonest or represents other violations of the Code.

Sanctions for breaches of the guidelines shall be assessed on the basis of the severity of each case.