Global business ethics and compliance

The global business ethics and compliance program is dedicated to ensuring that our business is conducted with integrity and is compliant with applicable laws. This program is led by the global business ethics and compliance officer, with guidance from the global business

ethics and compliance committee. They are supported by regional compliance officers and additional committees. The program consists of the following key elements:

Corporate policies and procedures

The Apotex code of conduct and business ethics provides guidance to employees regarding the ethical, legal and compliance principles of the company. The code of conduct and business ethics is supplemented by various compliance policies, procedures and processes for individual business functions.

Training

Training sessions and educational materials about expectations for compliant and ethical behaviour of employees.

Anonymous and retribution-free reporting

Communication channels and tools for employees, customers and vendors to report concerns or misconduct, anonymously and without reprisals for employees (e.g., the Global Business Ethics and Compliance Helpline, www.ApoSpeaks.com).

Monitoring and auditing

Systems and procedures to assess adherence to the Code of Conduct and other compliance related matters, and to identify opportunities for enhancing ethical behaviours.

Investigation and enforcement

Taking appropriate action to validate and address issues, when concerns or allegations about misconduct or non-compliance arise.

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Last updated: September 2024