CODE OF ETHICS PHARMA GROUP, a.s.

Effective from: 15.10.2023

Applies to employees of the company:

PHARMA GROUP, a.s., SNP 150, 908 73 Veľké Leváre, ID No.: 31 320 911

1. Introduction

The Code of Ethics of PHARMA GROUP, a.s. stems from the Code of Ethics of the Slovak Association of Suppliers of Medical Devices SK+MED (hereinafter referred to as SK+MED). PHARMA GROUP, a.s. is a member of SK+MED and is obliged to comply with the principles of the SK+MED Code of Ethics. The current version of the SK+MED Code of Ethics is available online: http://skmed.sk/?page_id=106.

The member companies of the SK+MED Association are entitled to adopt and implement their own code of ethics, which shall not contradict the Code of Ethics of the Association in its provisions and rules.

The Code of Ethics of PHARMA GROUP, a.s. is binding for all employees of the company. It regulates our mutual relations, relations with business partners and customers and relations with the professional and lay public (third parties). It represents our commitment to behave on a day- to-day basis in accordance with applicable laws, regulations, ethical principles and our own conscience towards responsible business with medical supplies and medical technologies.

Our goal is to establish and uphold ethical rules and principles that will lead to building the reputation of our company.

2. Compliance with laws and regulations

We comply with all applicable laws, regulations and industry standards regarding the development, manufacture and distribution of medical technologies. This includes compliance with medical device regulations, data protection laws and quality management standards such as ISO 9001-2015.

3. Employee relations

We, the employees of PHARMA GROUP, a.s., treat each other with due respect. We do not tolerate demeaning, intimidating, hostile or aggressive behaviour. We respect each other, regardless of age, gender, nationality, race, religious beliefs, social status, disability, political views or opinions on social events and sexual orientation. We are committed to preserving the dignity and privacy of the individual. Each of us has a role to play in creating a positive work environment.

4. Relations with third parties

A "third party" is defined as any customer, medical or non-medical professional, business partner, supplier (of goods or services), official (government or local), lay or professional public, and/or political party representative with whom we come into contact in the course of our work as employees of the Company.

Our goal is to build long-term and fair relationships with third parties that are based on

mutual respect and esteem. We are aware of the responsibility we have towards them. We are obliged to behave with integrity and honesty.

We never engage in illegal or unethical activities related to competition and public procurement such as:

- agreements with competitors on prices and customers

- the provision of direct or indirect payments (through third parties) aimed at obtaining an unfair competitive advantage.

We strive to gain competitive advantage through superior performance, but never through unethical or illegal business practices.

We do not provide third parties with any corrupt or illegal payments (direct or indirect), gifts, grants, entertainment or improper entertainment that is intended to close a deal, gain a competitive advantage or otherwise benefit the company. We provide or reimburse hospitality, travel and lodging only to the extent reasonable and only in connection with a legitimate opportunity to educate, promote or discuss the Company's products.

We may not offer, promise, endorse or pay any incentive payment, bribe or anything of value (directly or indirectly) to an individual for the purpose of obtaining or providing favorable treatment in a business transaction. We do not offer, solicit or accept unauthorized payments under any circumstances, even if it will ultimately result in the loss of business.

Our interactions with third parties must not be used to influence decisions through undue or improper advantage and should not be conditional on a sales decision or recommendation of the Company's products. We do not take unfair advantage of anyone through manipulation, concealment, misuse of privileged information, misrepresentation of material facts, or any other intentional unfair business practices.

5. Relations with health professionals

We are committed to ethical communication with healthcare professionals (HCPs). We regularly consult with healthcare professionals on topics related to our products, including training and education on their safe and effective use. Interactions with HCPs are strictly regulated, and the Company does not tolerate interactions with HCPs made for the purpose of improperly and inappropriately influencing the purchase of the Company's products. We present our products accurately, disclose relevant information, and avoid misrepresentations or false claims. We sell our products only for the use for which they have been approved.

We select and engage healthcare professionals for consulting services based solely on their qualifications, experience, skills and expertise. Any engagement with a GP must be properly documented, approved, legitimate and provided in return for remuneration. Remuneration must be paid for actual service rendered and based on the principle of fair market remuneration.

The provision of grants and training to healthcare professionals is governed by the rules of the SK+MED Association's Code of Ethics and the company's internal regulations.

We provide accommodation, travel and hospitality expenses to the PIs to a reasonable extent and exclusively in accordance with the rules of the Code of Ethics of the SK+MED Association and the internal regulations of the company.

We do not provide hospitality and do not reimburse any expenses, such as travel or accommodation, for persons accompanying healthcare professionals at business meetings, educational events, congresses or similar events.

6. Keeping accounting records

Our books and records must accurately, fairly and honestly reflect all business transactions we conduct. We will never reimburse expenses that do not have an adequate description or supporting documentation or appear unreasonable. The purpose of each payment must be clear, reasonable and transparent. We do not make non-transparent payments whose purpose for being made would be unreasonable, false or artificial.

7. Access to property assets

We take a responsible approach to all tangible and intangible assets entrusted to the company. Each of us spends costs efficiently and without unnecessary waste. The use of our Company's property assets for private or other business activities is prohibited. The Company only permits the use of the Company's entrusted property assets for private purposes if:

- if they do not adversely affect work performance,

- unless their use imposes significant costs on the company,

- if their use complies with applicable law and internal rules,

- if their use is pre-approved,

- if their use does not damage the company's reputation.

All official expenses must be reasonable, appropriate in time and place and modest in terms of value and frequency.

We are obliged to maintain confidentiality towards any third parties, we protect all confidential information and information of a commercial nature that we obtain in the course of our employment. Our commitment continues after our employment with the Company has ended.

8. Conflict of interest

We actively identify and manage conflicts of interest to ensure that personal interests do not compromise the best interests of the Company or our stakeholders. Financial, personal or professional interests that could influence decisions must be disclosed and properly managed.

9. Privacy and security

We are committed to protecting patient and customer data. We comply with data protection laws, implement robust data security measures and ensure responsible use of sensitive information in accordance with applicable laws and our company's internal regulations.

10. Reporting and accountability

We are required to report any suspected ethical violations, breaches of the Code of Conduct or potential legal issues. Reports can be made through established channels, and all reports will be treated confidentially and investigated thoroughly.

11. Enforcement and consequences

We, the employees of PHARMA GROUP, a.s., are aware that failure to comply with this Code of Conduct may lead to disciplinary action up to and including termination of employment or contractual relationship. Depending on the nature of the violation, our actions may also have legal consequences.

12. Conclusion

If I am not sure whether my actions comply with the Code, I ask myself the following question:

"Will I be satisfied If my actions become public knowledge?"

If the answer to the question is "no", my actions are not in compliance with this Code, I will advise with my supervisor and ask for guidance.