Clinigen : Supplier Code of Conduct 2023

Clinigen is committed to responsible business practices and conducting business with the highest ethical standards.

We also expect that suppliers, vendors, contractors, consultants and other third parties acting on our behalf (collectively, "Suppliers") conduct business to the same standards and in compliance with all applicable laws and regulations. This code sets out the standards that we expect our Suppliers to uphold.

for your commitment to upholding the standards set out in this code.

Business Integrity

Suppliers shall comply with all applicable anti-trust and competition laws, rules and regulations. Suppliers will not enter into agreements with competitors or engage in other acts that may unfairly impact competition, including, but not limited to, price fixing or market allocations.

Suppliers shall comply with all applicable anti-bribery laws and anti-corruption laws and shall never engage in bribery and corruption. Suppliers who deal with governments or government officials need to be extremely careful not to give rise to suspicions that they might engage in bribery or corruption.

Suppliers will not offer, promise, give (including facilitation payments), demand or accept bribes or other improper advantage, including excessive gifts and entertainment, in order to obtain, retain or give business. Supplier shall recognise that anti-bribery and anti-corruption laws may be applied internationally.

Suppliers shall comply with all applicable statutes governing the prevention of money laundering and not to take part in any money laundering or other fraudulent activity.

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All business dealings must be carried out in a transparent manner and recorded accurately. Clinigen does not tolerate any actual or potential involvement by its suppliers in money laundering, terrorist financing, and/or market abuse.

Employment Standards

Ethics & Compliance

Supplies must comply with all applicable data protection and privacy laws when collecting, processing, storing or otherwise handling the personal data of any individuals, including their own employees and the employees of their customers, suppliers, and business partners.

Suppliers should avoid any situation or relationship that may involve an inappropriate conflict or the appearance of a conflict with the interests of Clinigen. Suppliers shall declare all and any conflict of interest in any business dealing to Clinigen.

Suppliers shall respect the Clinigen communicated policies regarding gifts and entertainment and conflicts of interest when dealing with Company employees and representatives.

Suppliers shall operate an appropriate management system to support ongoing compliance with all applicable laws and regulations. This includes maintaining adequate documentation to demonstrate compliance and putting in place a system for employees and business partners to anonymously report concerns.

Business entertaining and hospitality involving individuals representing Clinigen must be kept reasonable and proportionate and be done entirely for the purpose of maintaining good business relations and not to influence unfairly any future business decisions.

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Trade Compliance