I. OUR FOUR CORE PRINCIPLES

1. Patients

Patients benefit and safety is at the heart of everything we do.

2. Associates

We treat our associates fairly and respectfully.

3. Shareholders

We are committed to outstanding and sustainable performance with integrity.

4. Society

We aspire to be a good corporate citizen. Misconduct can always be reported to the human resources representative or the compliance officer with full protection against retaliatory actions.

II. BUSINESS ETHICS

All Swiss Rockets clinical studies, no matter where they are conducted, are managed in compliance with international guidelines.

Swiss Rockets commitment to attain the highest possible level of health by all peoples must be accompanied by the dedication of its personnel to uphold and promote the highest standards of ethics and conduct.

We are committed to the following ethical principles:

1. Integrity

We demonstrate the highest standards of integrity and commit to act in good faith in all matters. We are driven by the qualities of honesty, truthfulness, impartiality, and incorruptibility.

2. Accountability

We act in accordance with the WHO regulatory and policy frameworks. We are responsible for our actions and decisions, and we are accountable to the Organization for them. We respect and safeguard confidentiality; ensure the proper, effective; and demonstrate the expected standards of conduct with all persons we encounter, both internal and external to the Organization. We always act within the scope of our authority. We exercise adequate control and supervision over matters for which we are responsible.

3. Independence and impartiality

We conduct ourselves with the interests of Swiss Rockets only in view and under the sole authority of the company country director. We exercise the utmost discretion in our actions, refrain from participating in any activity that is, or may be perceived to be, in conflict with the interests of Swiss Rockets, or that might damage the reputation of the company.

4. Respect for dignity, worth, equality, diversity, and privacy of all

We are committed to fostering an inclusive culture marked by dignity and respect for each other as well as recognition of individual contributions and privacy of all. We behave ethically and avoid any form of discrimination related to gender, gender expression or gender identity, race, religion, political belief/conviction, nationality, citizenship, ethnic or social origin, age, marital status, sexual orientation, disability, language, or other aspects of personal status.

5. Professional conduct

We refrain from any form of exploitative or abusive behavior and from all forms of harassment and misconduct. We are always guided by the ambition to not harm the people we work with. We strive to ensure a safe, respectful, healthy, and empowering work environment. We are committed to the following core values:

5.1. Trusted to serve public health:

a) We put people’s health interests first.

b) Our actions and recommendations are independent.

c) Our decisions are fair, transparent, and timely.

5.2. Professionals committed to excellence in health:

a) We uphold the highest standards of professionalism across all roles.

b) We are guided by the best available science, evidence, and technical expertise.

c) We continuously develop ourselves and innovate to respond to a changing world.

5.3. Persons of integrity:

a) We practice the advice we give to the world.

b) We engage with everyone honestly and in good faith.

c) We hold ourselves and others accountable for words and actions.

5.4. Collaborative colleagues and partners:

a) We engage with colleagues and partners to strengthen impact at country level.

b) We recognize and use the power of diversity and equality to achieve more together.

c) We communicate openly with everyone and learn from one another.

III. CONFLICT OF INTEREST

1. Identify conflicts of interest

Employees are expected to recognize when they potentially have, or could be perceived as having, a conflict of interest. A conflict of interest arises when employees place their personal interests before the interests of Swiss Rockets and where such personal interests improperly influence or could be seen as improperly influencing their business judgments, decisions, or actions. Making judgments, taking decisions, or pursuing actions when facing a conflict of interest may make it difficult to perform work for s Swiss Rockets objectively and may have legal, reputational and regulatory consequences. If Associates are in doubt about whether there is a conflict of interest, they should consult their line manager, Head of Human Resources, Compliance Officer or Head Legal Counsel for guidance.

2. Avoid conflicts of interest

Swiss Rockets respects employees’ rights and choices and does not wish to interfere with their personal lives. However, as part of their employment with Swiss Rockets, employees have a contractual obligation of loyalty to Swiss Rockets. Accordingly, employees should avoid conflicts of interest with their work at Swiss Rockets wherever possible.

3. Disclose conflicts of interest

Having a conflict of interest is not necessarily wrong. However, it can become a problem or even a legal matter if an employee tries to influence or could be perceived as influencing the outcome of business dealings for direct or indirect personal benefit.

4. Address conflicts of interest

Disclosing a conflict of interest alone is not sufficient. Every conflict must be addressed together with the line Manager in order to eliminate or reduce the associated risks. Most conflicts of interest can be addressed in a simple and mutually acceptable manner through pro-active, open dialogue between employees and their manager. Swiss Rockets expects the line manager to:

• Assess the conflict of interest situation disclosed by the employee, and fairly evaluate options to address the conflict.
• Consult the Head of Human Resources and/or Compliance Officer and/or Head Legal Counsel in addressing the conflict depending on the category of conflict of interest as described below
• Make a pragmatic and informed decision to address the conflict of interest so that risks to Swiss Rockets are minimized and the personal interests of the employees are protected as far as possible.
• Communicate the decision and its reasoning to the employee and follow up to ensure the employee understands and complies with it.

5. Types of Conflicts of Interest

The following section lists some common types of conflicts of interest. They are divided into the following main categories:

• External engagements including outside employment
• Personal financial interests
• Family and personal relationships
• Gifts, meal, travel, entertainment and other favors

6. External engagements (incl. outside employment)

6.1. Outside engagements and other payments for services External engagements (including employment outside of Swiss Rockets) may create, or appear to create a conflict of interest. This is because of the possibility that some aspects of the outside position may cause employees to act in a way that is inconsistent with their duty to Swiss Rockets. This concern applies not only to traditional employment relationships, but also to the receipt of fees for consulting, honoraria and other payments for services. Employees should not have any kind of paid or unpaid engagements with a Swiss Rockets supplier, customer or competitor, unless it clearly does not influence and cannot be perceived as influencing their business judgment or it is expressly requested by Swiss Rockets and is documented accordingly. Additionally, Associates must avoid taking up external engagements – whether or not involving a business partner, competitor or customer – which could:

• Entail the use of working time or company resources unless it is requested or supported by Swiss Rockets
• Require the use or disclosure of Company confidential information.
• Adversely affect or appear to affect the objectivity of the employee in performing their duties at Swiss Rockets.
• Conflict with Swiss Rockets’ mission or values or otherwise negatively impact the reputation of Swiss Rockets. A conflict of interest could also arise when an employee acts as an official/advisor/consultant to a government agency, particularly in a role involving regulatory or supervisory power over (or other ability to affect) Swiss Rockets. Employees must inform their line manager for approval prior to accepting any such position.

6.2. Giving paid speeches and other presentations

Giving paid speeches and other presentations may raise conflict of interest concerns. Specifically, they could:

• Create a perception that Associates are using their position for personal gain, which could harm both their reputation and that of Swiss Rockets.
• Lead to a perception that the employee’s participation in the event could influence their business decisions with respect to the event sponsor. Before accepting an offer to give a paid speech or other presentation

6.3. Gifts, meals, travel, entertainment and other favors

• Receiving gifts, meals, hospitality, travel and entertainment can serve important business purposes. However, employees must be careful to avoid any conduct that would constitute a conflict of interest. Employees must not directly or indirectly solicit or accept from any actual or potential Swiss Rockets supplier, customer or competitor:
• Cash or cash equivalents (e.g., stocks, gift certificates, discounts not based on a collective agreement, etc.);
• Gifts, unless it is reasonable to believe that accepting the gift does not influence and cannot be perceived as influencing the business judgement of the employee. Where refusing a gift might reasonably be interpreted as giving offence or causing embarrassment, a gift may be accepted on behalf of Swiss Rockets but must be disclosed and the employee’s manager must determine appropriate disposition.
• Meals, hospitality, travel, or entertainment, unless it serves only Swiss Rockets business interests, is accompanied by a representative of the business providing it and does not influence (and cannot be perceived as influencing) the business judgment of the employee.

7. Implementation

7.1. Training

Associates must familiarize themselves with this Guideline and participate in periodically held training sessions. Managers should additionally be trained on their specific responsibility to evaluate and effectively address conflicts of interest.

7.2. Reporting Potential Misconduct/Non-Retaliation

Any employee with knowledge of suspected misconduct must report his or her suspicion promptly. Employees who report potential misconduct in good faith or who provide information or otherwise assist in any inquiry or investigation of potential misconduct will be protected against retaliation.

IV. WHISTLEBLOWING

In awareness of the fact, that currently there is no law in Switzerland protecting whistleblowers from dismissal by their employer, Swiss Rockets commits itself to following rules:

1. Swiss Rockets will not retaliate against a whistleblower. This includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any whistleblower who believes he/she is being retaliated against must contact the Head of Human Resources immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.

2. Whistleblower protections are provided in two important areas: confidentiality and retaliation. Insofar as possible, the confidentiality of the whistleblower will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law, and to provide accused individuals their legal rights of defense.

3. Individuals protected include a. the employee, or a person acting on behalf of the employee, who reports to a public body or is about to report to a public body a matter of public concern; or b. the employee who participates in a court action, an investigation, a hearing, or an inquiry held by a public body on a matter of public concern.

4. Swiss Rockets may not discharge, threaten, or otherwise discriminate against an employee regarding the employee’s compensation, terms, conditions, location, or privileges of employment.

5. Swiss Rockets may not disqualify an employee or other person who brings a matter of public concern, or participates in a proceeding connected with a matter of public concern, before a public body or court, because of the report or participation, from eligibility to bid on contracts with Swiss Rockets; receive land under a district ordinance; or receive another right, privilege, or benefit.

6. The provisions of this policy do not:

6.1. require Swiss Rockets to compensate an employee for participation in a court action or in an investigation, hearing, or inquiry by a public body;

6.2. prohibit Swiss Rockets from compensating an employee for participation in a court action or in an investigation, hearing, or inquiry by a public body;

6.3. authorize the disclosure of information that is legally required to be kept confidential;

6.4. diminish or impair the rights of an employee under a collective bargaining agreement.

7. Limitation to protection

• A person is not entitled to the protections under this policy unless he or she reasonably believes that the information reported is, or is about to become, a matter of public concern; and reports the information in good faith.
• A person is entitled to the protections under this policy only if the matter of public concern is not the result of conduct by the individual seeking protection, unless it is the result of conduct by the person that was required by his or her employer.
• Before an employee initiates a report to a public body on a matter of public concern under this policy, the employee shall submit a written report concerning the matter to the organization’s chief executive officer. However, the employee is not required to submit a written report if he or she believes with reasonable certainty that the activity, policy, or practice is already known to the Chief Executive Officer; or that an emergency is involved.

8. Relief and penalties

A person who alleges a violation of this policy may bring a civil action and the court may grant appropriate relief.

9. Procedures

9.1 If an employee has knowledge of or a concern of illegal or dishonest/fraudulent activity, the employee is to contact his/her line manager or the Head of Human Resources. All reports or concerns of illegal and dishonest activities will be promptly submitted by the receiving line manager to the Head of Human Resources, who is responsible for investigating and coordinating any necessary corrective action. Any concerns involving the Head of Human Resources should be reported to the Chief Executive Officer.

9.2. The whistleblower is not responsible for investigating the alleged illegal or dishonest activity, or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.

9.3. Examples of illegal or dishonest activities include violations of federal, state, or local laws; billing for services not performed or for goods not delivered; and other fraudulent financial reporting. The employee must exercise sound judgment to avoid baseless allegations. An employee who intentionally files a false report of wrongdoing will be subject to disciplinary action.

V. POLICY OF INTERNATIONAL SANCTIONS

Swiss Rockets AG is always aware of the actual international Sanctions by the UN, USA or EU and acts accordingly.

If we risk to violate any sanctions in certain business areas, we will obtain exemptions from the authorities or refrain from carrying out the transaction.

VI. TREATMENT OF ANIMALS FOR RESEARCHE PURPOSES

Swiss Rockets commits itself to the standards of the Swiss Universities regarding animal research.

CRUS_Grundsätze_tierexpForschung_170113_e (swissuniversities.ch)

1. Procurement

We seek to build a resilient supply chain by adhering to best practices, developing novel approaches and working in partnership with our suppliers. Business continuity planning and risk management are the cornerstones of our approach.

2. Supply Chain Strategy Targets

Our strategic focus for Swiss Rockets’ manufacturing procurement organization is to accelerate Swiss Rockets goal to bring innovative solutions to patients quickly and efficiently through business and supplier partnerships”.

Our top priority is ensuring the sustainable supply of medicines and diagnostics to our patients.

We monitor target achievement and we are fully committed to ensure uninterrupted supply to patients.