1. Purpose
This Code of Conduct Policy is established to guide the conduct of all employees, contractors, customers, and suppliers associated with Axmed AG, a company focused on ensuring that affordable and high-quality medicines are accessible globally. Our commitment to ethical business practices, legal compliance, and social responsibility is paramount in achieving our vision.
2. Scope and Applicability
This Policy reflects Axmed’s commitment to maintaining the highest standards of ethics and compliance. Adherence to these guidelines is essential for our collective success and for the realization of our vision, it underscores our dedication to ethical behavior, requiring all stakeholders to maintain the highest standards of compliance and integrity in alignment with our mission. We expect every member of our community, including employees, contractors, customers, and suppliers, to uphold these standards in all their professional endeavors associated with our company.
3. Diversity, Equity, and Inclusion (DEI)
Axmed is committed to fostering a diverse, equitable, and inclusive environment where all employees, customers, and suppliers are respected, valued, and empowered. We strive to ensure equal opportunities for everyone, irrespective of their race, gender, age, sexual orientation, religion, disability, or any other characteristic. Our policies and practices aim to promote understanding, respect, and mutual appreciation for diversity within our global community.
4. The four principles of our Code of Conduct
Our conduct principles include: a. b. c. d. Compliance with all applicable laws of the countries where we do business and adherence to Axmed’s policies and procedures. Modeling honesty and fairness, setting an example for all stakeholders. Promoting a culture of integrity, respect, and ethical standards. Holding each other accountable and promptly addressing potential violations.
5. Compliance policies
We act with care and respect.
a. Employee Well-being and Mental Health
We recognize the vital importance of mental health and overall well-being for our employees. We are committed to creating a supportive work environment that promotes work-life balance, stress management, and access to mental health resources. Our policies are designed to support the physical and psychological health of all employees, offering programs and initiatives such as flexible working hours and confidential counseling services. By prioritizing the well-being of our team, we foster a culture of care, resilience, and productivity, demonstrating our unwavering commitment to the health and happiness of our employees.
b. Environment
Our commitment to environmental responsibility includes actively managing and reducing our ecological impact. We aim to exceed legal standards, prevent pollution, and minimize the environmental footprint of our activities. We expect our partners and supplies to share this commitment.
c. Human Rights
We are committed to respecting and endorsing internationally recognized labor and human rights standards, in line with the International Bill of Human Rights, United Nations Guiding Principles on Business and Human Rights, and the labor rights defined by the International Labor Organization including the ILO Declaration on Fundamental Principles and Rights at Work. We expect our partners and supplies to share this commitment
d. Data Protection and Privacy
Axmed prioritizes the security and privacy of all personal and sensitive data. We strive to comply with all applicable data protection laws to ensure the confidentiality, integrity, and availability of the data we handle, and we adhere to the highest standards of data protection. Our policies ensure the confidentiality, integrity, and availability of all data we handle, emphasizing the importance of privacy rights and data security in all our business activities.
5.1 We conduct business fairly and ethically.
Integrity and Professionalism
a. Employees:
Must conduct business with integrity, respect, and professional ethics. Personal and professional behavior should align with the company’s values and ethical standards.
b. Customers and Suppliers:
Are expected to adhere to similar standards of integrity and professionalism in all interactions with or related to the company.
c. Conflict of Interest
Any situation that might lead to a conflict of interest must be reported and managed according to the company’s conflict of interest policy. A conflict of interest occurs when an individual’s personal interests interfere with their ability to make impartial decisions in the best interest of the company. This can include situations where personal, financial, or familial relationships might influence a person’s judgment or action within their role. It is not necessary for such a compromise to have occurred before the situation can be identified as an actual or potential conflict of interest. The perception of a conflict of interest in a situation can be enough for an employee’s professional reputation and decision-making ability to be compromised or question. Employees are required to disclose any potential or actual conflicts of interest in writing to their line manager or a designated compliance officer as soon as they become aware of them. The company will then review the situation and determine the necessary steps to manage or mitigate the conflict, ensuring decisions are made in the company’s best interest. To avoid any potential or perceived conflict of interest, an employee must seek permission from their manager and the legal/compliance team in order to commence or continue any outside employment.
d. Trade Compliance
The global nature of our business at Axmed means we need to comply with many exports control and customs requirements. These requirements affect the movement of products across country borders, the use of software and technology, the exchange of know-how, and our ability to do business with different parties. Axmed is committed to compliance with all applicable international trade regulations, including customs controls, import and export controls and sanctions. Violations of these regulations can result in civil and criminal liabilities and loss of export privileges. Axmed regularly screens third parties, customers and employees against government lists of sanctioned parties.
e. Gifts and Hospitality
Axmed upholds strict guidelines on the acceptance and offering of gifts and hospitality to ensure they do not compromise, or appear to compromise, our professional judgment or integrity. Gifts and hospitality must be modest, appropriate, and transparent, avoiding any potential conflicts of interest or perceptions of undue influence in our business decisions. In any case, gifts of cash or cash equivalents are not allowed.
The giving or accepting of gifts or entertainment during contract negotiation or in connection with Axmed’s business is not permitted. Where regulations are in place that prohibit or constrain the provision of gifts or entertainment to healthcare professionals and government officials, Axmed requires strict compliance with the most stringent requirements.
5.3 We protect our brand and assets.
a. Confidentiality
Confidential information must be safeguarded. Sharing sensitive data externally is prohibited unless approved by authorized personnel i.e., Executive Leadership Team (ELT). Confidentiality refers to the obligation of individuals within an organization to protect sensitive information from unauthorized access, disclosure, or dissemination. This includes, but is not limited to, proprietary data, financial information, customer details, strategic plans, inventions and trade secrets, any confidential information received by third parties under an obligation of confidence and employee records. Employees are expected to safeguard this information during and after their tenure at the company, only sharing it with authorized parties as required for business operations. Breaches of confidentiality can result in disciplinary action, including termination and legal consequences.
b. Intellectual Property Rights
The respect and protection of intellectual property rights are fundamental principles at Axmed. Employees, customers, and suppliers are expected to honor these rights, ensuring that all intellectual property, whether belonging to the company or external entities, is not misused, infringed upon, or disclosed without authorization. Our commitment to innovation is matched by our dedication to ethical and legal use of intellectual property.
We require that our employees assign and transfer to Axmed, at any time without further consideration, any intellectual property developed by them in the course of their employment by Axmed or developed from Axmed’s intellectual property. The only exception is where applicable local laws require that consideration be payable. In this case said consideration will be the minimum payable under the applicable local laws.
c. Fraud and Theft
Any kind of theft, fraud, embezzlement, or other misuse of Axmed’s assets is prohibited. Honesty and transparency are fundamental to our business. Axmed funds and other assets are used properly, in a responsible manner and for their intended and legitimate purposes. Axmed’s assets are to be secured and protected, including inventory, tools, vehicles, spare parts, data, and intellectual property. All Axmed’s financial transactions are based on real events. They are recorded accurately, in a timely manner and follow Axmed’s accounting standards and other applicable local rules. Financial and non-financial reporting and records do not contain any false, misleading, or artificial entries or information.
All facilities must be well maintained and secured against theft, misuse and fraud; each Axmed associate, and business partner is responsible for ensuring the protection of our assets and information, including electronic equipment.
d. Cybersecurity
Axmed is committed to cybersecurity. It is your responsibility to act appropriately when using, developing, or maintaining valuable information, tools, and digital assets. It is our policy to ensure that information needed to conduct Axmed business efficiently is adequately protected. Systems and products are developed according to established security principles, including security testing prior to release and monitoring for cybersecurity threats and vulnerabilities.
e. Social Media Use
Employees of Axmed are advised to use social media responsibly and ethically, reflecting the company’s values and professionalism. Our policy highlights appropriate conduct on social media, including respecting confidentiality, avoiding defamation, and not sharing sensitive company information.
This ensures that our reputation and the privacy of our employees, customers, and suppliers are protected in the digital sphere. Additional information can be found in the
Internal and External communications policy. As Axmed is active in heavily regulated markets, any use of social media that relates to Axmed by associates or business partners of Axmed must comply with the regulatory framework applicable to that specific content from time to time.
6. Speaking up
6.1 Reporting mechanism
Axmed has implemented a Speak Up policy to foster a positive and transparent relationship with our associates, contractors and other third parties. To facilitate speaking up in an environment without fear of reprisal, retaliation or detriment, we maintain our Speak Up Policy and promote proper use of procedures for our employees, contractors and other third parties to report (anonymously where permitted) situations which may raise concerns under this Code of Conduct or relevant Axmed’s policies, standards and values. Our Speak Up Policy lists various reporting processes that could be used to raise concerns. Please refer to our publicly available resources to access further information.
6.2 Addressing Concerns
Axmed is committed to resolving conflicts in a fair, transparent, and efficient manner. We encourage open communication and dialogue to address disagreements or disputes among employees or between employees and management. Our conflict resolution process is designed to ensure that all parties are heard, and resolutions are reached with respect to everyone involved, fostering a positive and productive work environment. This will follow the escalation process captured in the internal and external communication guideline.
7. Compliance with Local Laws and Regulations
7.1 Legal Compliance
All company operations, irrespective of geographic location, must comply with local, national, and international laws and regulations. Employees, customers, and suppliers are expected to understand and adhere to these legal requirements, and to observe the principles set out in this Code of Conduct Axmed conducts and monitors participation in mandatory training programs to help our employees understand the Code, its relevance and individual obligations. We expect our business stakeholders, contractors and third parties a similar level of diligence.
7.2 Non-Compliance
a. Reporting and Investigation
• Reports of non-compliance will be thoroughly investigated. Confidentiality will be maintained to the extent possible.
b. Consequences
• Violations of this Policy may result in disciplinary action, including employment or business relationship termination.
• Legal actions may be pursued in cases of illegal activities or violations of the law.
8. Review and Amendments
This Policy shall be reviewed and updated periodically or annually to reflect changes in the organization’s structure, operations, or regulatory requirements.
9. Outside Employment Policy
Outside Employment
Axmed values the full commitment of its team members and seeks to maintain high standards of integrity and performance. To that end, Axmates are not permitted to engage in any form of paid or unpaid work for another company, individual, or entity that conflicts or competes with Axmed’s business, interferes with their performance, uses or could be perceived as using Axmed’s confidential information or intellectual property, or creates a conflict of interest or appearance thereof. This applies to all Axmates unless otherwise agreed upon in writing. External work includes, but is not limited to, employment by a second company, operating a side business, or undertaking freelance or consulting work.
In case of doubt, we ask all Axmates to share with their respective managers to make an informed decision. In exceptional circumstances, where the scope, nature and timeline of the role does not clash with Axmed duties, individuals could obtain prior written approval from PWS and their department head. Approval is granted at the sole discretion of Axmed and may be withdrawn at any time.
Breaches of this policy may result in disciplinary action, including termination of employment or contract, and may constitute a material breach for contractors including termination of the relationship with Axmed. This policy is globally applicable but will defer to local labor laws and contract terms where they are more restrictive or provide additional rights. Team members should consult PWS for guidance relevant to their jurisdiction.