Code of Conduct – MIM PHARMA

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Message from CEO

Our Code of Conduct defines how we do business at MIM PHARMA and is embedded in our values and Open Leadership principles. Together with our strategy, it unites us across our locations and cultures. The importance of a shared Code of Conduct increases as our scope of operations and influence widens as the world around us grows more and more complex.

To commit to the well-being of mankind, especially the patients To act ethically and treat all with honesty, integrity, and respect

is “part of our DNA”. We act in a global environment and are all entrusted to make decisions that impact our reputation and relationships with each other, our customers, our business partners, and the public. Our Code of Conduct is the guide for our actions and behavior both within the company and externally. We comply with the laws and are guided by our ethical principles as we conduct business at MIM PHARMA.

Living by high ethical standards gives us the license to operate and helps to safeguard our industry interests and reputation. It is obvious that one booklet–however carefully worded it is–cannot answer all questions or address every situation. Therefore, we should stay alert and act without delay whenever we are concerned that our Code, policies, or regulations are being violated. I personally believe working with high ethics and in line with our values is the only way to gain truly sustainable business success in meeting our business goals and being a good corporate citizen.

Peter Ressalehi

CEO, MIM PHARMA

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About this Code of Conduct

MIM PHARMA operates globally, and our researchers are citizens of a number of different countries. Consequently, our operations are subject to various national and international laws and regulations. Therefore, we embrace the spirit of integrity and uphold the highest standards of ethical business conduct. We believe that there is a clear connection between the high ethical business practices set by our Code of Conduct and successful financial results. MIM PHARMA’s Code of Conduct builds on various international agreements and initiatives and defines the principles of how we treat others, do business, and engage with the wider world. This Code also sets rules that we as a company follow and articulates the kinds of behavior we expect from our employees, stakeholders, and everyone who represents us. MIM PHARMA employees, members of our Board of Directors, and anyone representing MIM PHARMA are expected to conduct themselves in line with this Code of Conduct. Additionally, MIM PHARMA expects companies affiliated with us to respect these principles.

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OUR STORY & VISION:

We strive to transfer the legacy of deep-rooted natural medicine to the modern pharmaceutical R&D and manu- facturing techniques for introducing NOVEL medical solutions. In order to pro- vide excellent solutions, we dedicate time and resources developing treatment and cures to help humanity get rid of common and widespread ailments such as Covid-19 and migraine headaches.

OUR MISSION:

To be an R&D-oriented pharmaceutical company by applying the most up-to-date technology, techniques, and quality To introduce novel medical solutions to the world To remove or mitigate pain and ailments using natural solutions.

OUR VALUES:

To create a scientific, energetic, and entrepreneurial organization that contributes to the improvement of improving human health To emphasize on innovation and continuous improvement both in the processes and medical solutions To commit to the well-being of mankind, especially the patients To act ethically and treat all with honesty and respect

OUR RESPOSIBILITY:

We have a strong sense of responsibility. We take responsibility for both our own work and our collective impact on society and humanity. We create sustainable medical solutions that are part of the collective effort. We never compromise on safety.

OUR INTEGRITY:

We believe in transparency. We run our business in an ethical manner that exposes every challenge, every success, and every milestone. We have no hidden agen- das and follow our Code of Conduct in our everyday business and work practices.

OUR RESPECT:

We greatly value each other and all our stakeholders, such as our co-workers and partners. Our success derives from main- taining a diverse and inclusive company culture where everyone feels empowered to thrive and reach their full potential no matter color, culture, or religion.

Legal compliance

There are a number of national and international laws and regulations governing the activities of MIM PHARMA and its employees, and many of the standards established in this Code of Conduct are based on legal requirements. All our employees and co-workers are expected to know and to act in accordance with the relevant laws and regulations applicable to their country and position.

MIM PHARMA employees must always comply with laws and regulations relating to, for instance, health and safety, employment, environment, competition and antitrust, anti-bribery, and the securities and the pharma industry. Non-compliance with laws and regulations can have severe consequences, both legally and in terms of MIM PHARMA’s reputation.

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How We Treat Others

We respect and support internationally recognised human rights and comply with fair employment practices and labour standards. We are committed to complying with all laws on freedom of association, collective bargaining, working time, wages and salaries, as well as laws prohibiting forced, compulsory, and child labour. We expect our suppliers and partners to do the same. We acknowledge that our operations directly and indirectly impact the realisation of the human rights of our own personnel, those working in our supply chain, and members of local communities. Therefore, we take measures to act in accordance with the UN Guiding Principles on Business and Human Right

Each of us is Accountable:

While laws, policies, and procedures may vary by country or region, the ethical principles of MIM PHARMA do not. All MIM PHARMA employees must comply with this Code of Conduct and the policies, procedures and laws that apply to our particular geographies and jobs. We must also ensure that third parties performing work on the Company’s behalf (such as researchers, consultants, contract workers, agencies etc.) understand and adhere to this Code of Conduct and any applicable policies, procedures and laws.

Each of us has help:

To support MIM PHARMA’s commitment to delivering results with the Code of Conduct at its foundation, we encourage to start with your manager, but if you aren’t comfortable doing so or this option isn’t available, reporting channels are an option with more information:
• Global Ethics & Compliance Website
• Ethics & Compliance Policy
• Speak Up Portal
• Speak Up Policy

Each of us has a voice:

It might happen that you become aware of an action or behavior which is, or could be perceived to be, not in line with our commitment, such as wrongdoing, misbehavior, doubtful practices, or deviation from this Code of Conduct. In such situations you are encouraged to “speak up” to one of these resources or use the “Speak Up” portal to report your concern.

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How We Do Business

MIM PHARMA complies with all applicable national and international laws, regulations, and conventions in the countries where we do business. The company also follows practices related to good corporate governance. Some of the key legislation related to our businesses concern anticorruption, money laundering, economic sanctions, tax evasion, market abuse and insider regulations, securities, and pharmaceutical industries. We periodically evaluate the applicability of sanctions and trade restrictions on our own operations.

MIM PHARMA values transparency in all dealings, competes fairly, and avoids using intermediaries without a legitimate business reason. We only conduct business with suppliers and partners that follow relevant laws and comply with MIM PHARMA’s requirements.

Our Ethical Principles

1. Patient Safety and Pharmacovigilance

Ensuring a positive benefit-risk balance of our medical solution is of critical importance to us.

We develop our medical solutions to ensure the level of quality and safety expected by our future customers and regulators worldwide.

Our Commitment

We foster a culture that is committed to patient safety and compliance with pharmacovigilance regulations worldwide, and we report any adverse event and pharmacovigilance-relevant information to my local Patient Safety & Pharmacovigilance Department.

More Information

Patient Safety & Pharmacovigilance Policy
Applicable local standards

2. Quality

We consider quality, including all its integral compliance aspects, as indispensable in researching, developing and providing safe and efficacious products for our patients.

Our Commitment

We foster a culture that is passionately committed to quality and compliance as success factors for our Company and we report any product complaints to my local Department that handles them.

More Information

Quality Policy
Policy on Supply Chain Integrity
Applicable local standards

3. Research and Development

In all our Research & Development activities, we strive to ensure the rights, safety and well-being of all participants and accuracy of our information. We are committed to the principles of Good Clinical Practice.

Our Commitment

We take appropriate actions to ensure the appropriate and responsible use of human biospecimens as well as the welfare of our laboratory animals, and we practice responsible animal care and use.

More Information

Human Biospecimens and Associated Data Policy
Declaration of Helsinki
Applicable local standards

4. Interactions with Customers and Stakeholders

We will provide accurate, fair and balanced information about our medical solutions, and do not engage in activities that inappropriately benefit or influence our future customers or stakeholders. We strictly follow applicable transparency and disclosure standards required by law, regulations and codes of practice.

Our Commitment

We ethically engage with customers and stakeholders and abide by the laws, codes and practices governing those relationships.

More Information

Interactions with Customers and Stakeholders Policy
IFPMA Code of Practice
Applicable local standards

5. Social Media and Public Relations

We at MIM PHARMA continuously work hard to grow a reputation of integrity and trust. Media representatives and other stakeholders outside our Company depend on and expect us to provide consistent, accurate and responsible communications, which we are committed delivering.

Our Commitment

We refer requests from journalists and other stakeholders outside the Company directly to the local MIM PHARMA representative responsible for external communications, and we are aware of and abide by any Social Media Guidelines.

More Information

Social Media Guidelines
Applicable local standards

6. Prevention of Bribery and Corruption

We do not promise, offer, pay, ask for or accept anything of value or benefit that may improperly influence decisions or actions with respect to our business operations.

Our Commitment

We avoid any and all activities that create actual or perceived inappropriate influence, either directly or indirectly, through third parties.

More Information

Anti-Bribery/Anti-Corruption Policy
Applicable local standards

7. Purchasing and Supplier Relations

Recognizing that our suppliers and partners play an important role in our success, we engage only with partners that are appropriately selected and contracted, and who share our commitment to quality, service, sustainability, diversity and ethical business practices.

Our Commitment

We conduct due diligence to ensure that we engage only reputable and qualified partners, and make sure appropriate contracts are in place.

More Information

Supplier Code of Conduct
Purchasing Policy
Applicable local standards

8. Antitrust and Fair Competition

We compete with ambition in the marketplace and do so honestly, fairly and in accordance with all applicable antitrust and unfair competition laws.

Our Commitment

We avoid any activity that creates an actual or perceived impression of conspiring with a competitor or otherwise inappropriately restraining fair competition.

More Information

Antitrust Policy
Applicable local standards

9. Export Control & Trade

We adhere to applicable export control and trade laws and other efforts intended to promote peace, stability and human rights, including regulations from the United Nations.

Our Commitment

We ensure that every transfer of items (goods, software, technology and related services) is reviewed carefully against existing export control and trade regulations and that all resulting obligations are fulfilled.

More Information

Export Control and Trade Policy
Applicable local standards

10. Insider Trading

We are committed to the fair functioning of the world’s financial markets and prohibit employees/partners from sharing inside information relating to MIM PHARMA’s stocklisted business partners, from trading on the basis of inside information or sharing “tips” that could unfairly influence investment decisions.

Our Commitment

We are cautious when we have access to material information relating to MIM PHARMA’s stock-listed business partners. We do not disclose such inside information to anyone outside the defined project team and we do not trade or tip on inside information.

More Information

Insider Trading Policy
Applicable local standards

Workplace Principle

11. Fair Treatment, Anti-Discrimination, and Inclusion

We treat each other with fairness and dignity at all times, and stand firmly against any form of discrimination or harassment. We respect and value the diverse individual characteristics, the different perspectives and distinctive backgrounds of our people. We uphold human rights and international labor standards around the globe.

Our Commitment

We respect our colleagues’ differences, and neither practice nor tolerate any form of discrimination, harassment, workplace aggression or gender inequality.

More Information

UN Global Compact
Applicable local standards

12. Conflicts of Interest

We conduct business in a manner that ensures that decisions and business judgment are made with objectivity and free of undue personal interests.

Our Commitment

We act at all times in the best interest of the company and avoid or disclose situations that present an actual or perceived conflict between personal interests and the interests of MIM PHARMA

More Information

Anti-Bribery/Anti-Corruption Policy
Applicable local standards

13. Data Protection

We respect the privacy rights of our employees, patients, physicians and other data subjects. We handle personal data only to the extent that we have a specific, definable business need for the information and then in compliance with all applicable laws and regulations.

Our Commitment

We protect others’ privacy by only using their personal data in a lawful, fair and transparent manner.

More Information

Applicable local standards

14. Responsible Handling of Information

Information is one of our most valuable assets, and we protect and manage it with care. We maintain confidentiality, and obtain, enforce and defend our intellectual property rights.

Our Commitment

We will not disclose MIM PHARMA or partner confidential information and are cautious and take appropriate safeguards when handling company information in public places. We use manage, protect and retain company records appropriately.

More Information

Information Protection Policy
Applicable local standards

15. Respect for Environment, Health, Safety and Sustainability

In all our activities we protect our employees, facilities and the environment from harmful influences, conserve natural resources and biodiversity, and promote environmental awareness. We select partners who share this commitment as well as the United Nations Sustainable Development Goals.

Our Commitment

We are committed to good environment, health and safety practices at all times. If we experience or come across a safety or environmental hazard in our workplace, we report it to the responsible function.

More Information

Environment, Health, Safety & Sustainability Policy
Applicable local standards

16. Political Activities

We respect and support individuals’ rights to participate in political activities using their own resources and done on their own time.

Our Commitment

We will not engage in activities that support political parties or candidates on behalf of MIM PHARMA. We also do not make political contributions on behalf of MIM PHARMA. When engaging in personal political activities, We avoid creating the impression that we are acting or speaking on behalf of the company.

17. Human Rights

We are committed to respecting and contributing to the realization of all human rights. We continuously advance our understanding of human rights and assess the impact of our business activities, including impact that we may cause and any to which we may contribute. We take remedial measures as required, including by using leverage in our business relationships.

Our Commitment

If we become aware of any potential impact to human rights caused by or connected to our business activities, We take remedial measures within our control and raise our concern to the appropriate department or to the “Speak Up” line.

More Information

Human Rights Policy
Applicable local standards

18. Speak Up

We take all reports of potential non-compliance seriously and conduct objective, thorough and timely investigations when necessary. Retaliation against employees who in good faith speak up and voice concerns is strictly prohibited. Speaking up helps MIM PHARMA take action and resolve issues appropriately.

Our Commitment

We report potential non-compliance with law, this Code of Conduct, policies or procedures to one of MIM PHARMA’s available reporting channels. If a concern is brought to our attention, We listen and act by being receptive to the information, respecting confidentiality, emphasizing non-retaliation, and referring the matter to the proper channel for further handling. We have the duty to cooperate in an internal investigation.

More Information

Speak Up Policy
Applicable local standards

When in doubt, ask yourself:

No document can cover every situation that we may encounter or every policy that may apply to us and our work. And it is not a substitute for good judgment.

There are times when we may be unsure what to do, or there are some issues that may not be immediately apparent or clear. In these situations, refer to the Ethics and Compliance resources and before making a decision or taking an action, ask yourself the following questions:

When in doubt, ask yourself:

Is it legal?
Does it comply with this Code of Conduct and company policies?
Would we feel comfortable if it was made public?
Does it feel right?

If you truthfully answer “yes” to of all these questions, you do not need to be in doubt.

If you have to answer “no” to any of these questions or if you are not sure, please consult with your manager.