Code of Conduct
General lmmedica expects that our employees behave according to our core values by acting responsibly towards colleagues, business associates and society at large; and to take inta consideration that when acting outside lmmedica, they are legitimately regarded as lmmedica employees and representatives of the company.

Scope and responsibility
The lmmedica Code of Conduct applies to all lmmedica employees, temporary personnel, consultant, agents or anyone working on behalf of lmmedica. 

This Code of Conduct recognises that compliance with law and relevant regulation when conducting
business on behalf of lmmedica is a fundamental duty and an essential part of the responsibility of
each employee.

lssues regarding social and sustainable entrepreneurship play an important role in corporate
competitiveness, profitability as well as for shareholder value.

In order to respect human rights, promote fair employment, safe working conditions, environmental
responsibility and high ethical business standards, the Code of Conduct is to be applicable globally in
all aspects of lmmedica’s organization.

Product and safety quality
Patient safety is the highest priority for lmmedica. In our development, manufacture, storage and distribution activities, we will comply with all applicable laws and regulations, including reporting of safety information designed to ensure the safety and quality of pharmaceutical products. We will also adhere to our internaI policies and standard operating procedures designed to protect patient safety and to ensure quality of our products.

Relationship with health care professionals
lmmedica is committed to complying with all applicable laws, regulations, and industry codes, including codes established by regional and local industry associations, in interacting with healthcare professionals.

We will not provide, offer, or promise any money, goods, hospitality, gift or any other item of value to induce or reward favourable treatment of our products.

When we obtain consulting services, advisory board services, or any other services from healthcare professionals, we will have a legitimate business need and we will not pay more than an appropriate market value for the services rendered.


Advertisement and promotion
lmmedica is committed to comply with all applicable laws, regulations and industry codes governing promotional activities and advertising and will conduct these activities in an appropriate and ethical manner.

We will follow applicable company procedures designed to ensure that our promotional information and advertisements comply with regulatory requirements and are accurate, balanced, fair, supported by scientific evidence and are not false or misleading.

We will not promote our products fora specific use in a country until the requisite approval for marketing for that use has been given in that country.

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Anti-corruption and anti-bribery
lmmedica employees will comply with all applicable laws and regulations prohibiting bribery of government officials as well as all applicable laws and regulations prohibiting bribery of foreign government officials. lmmedica should work against corruption in all its forms, including extortion and bribery.

We will not provide, offer or promise any bribe (including money, goods, hospitality, gifts or any other item of value), directly or indirectly, to government officials or foreign government officials. In addition, we will not provide any payment or benefits to private sector employees to influence them to obtain or retain a business advantage.

We will also ensure that those who act on our behalf, such as our agents, will not engage in corrupt practices.

lmmedica employees who work with purchasing will contribute to and work for honesty, reliability and professionalism in our contacts with suppliers and subcontractors.

Purchasers and others participating in the purchasing process and others in contact with suppliers will not inform third parties about competitive prices and other conditions.

All kinds of purchasing activities will comply with all applicable laws, statutes and related regulations in all the markets where we are active. Purchasers and others in the purchasing chain will never participate in contexts where same form of illegal cooperation exists, where competition is limited, such as joint pricing decisions, including production quotas, etc. lmmedica employees will cooperate with all relevant authorities in such matters.

Furthermore, we will comply with all applicable laws and regulations in exporting and importing products, machinery and technology. Employees responsible for exportation and/ar importation of goods or technologies will familiarise themselves with these laws and regulations.

Competition and anti-trust
We will comply with all applicable competition and anti-trust laws in all countries where we do
business. In particular, we will adhere ta the following:

  1. We will not exchange information with competitors an pricing, outputs, capacity, customer selection, or exchange any other competitive information, and will not enter inta any agreements on those matters (such as price fixing, market allocation, and bid rigging).
  2. We will not participate in trade association meetings or other meetings with competitors where we anticipate that such exchange af information ar agreements will be requested.
  3. We will not impose unlawful resale price restrictions on wholesalers, distributors, licensees, sales agencies or any other party.

Protection of assets and intellectual property
We will protect lmmedica’s money, property and other assets and will use them solely for the purpose of carrying out our duties to lmmedica and will not misappropriate ar embezzle these for ourselves or for any third party.

During and after employment, we will keep confidential and protect all confidential information, including trade secrets and business or technical information about lmmedica and its products, and we will not improperly disclose such information to any third party, nor will we use such information for any purpose other than performance of our duties to lmmedica.

All intellectual property owned, developed or obtained by lmmedica are vital assets af lmmedica. Therefore, we will carefully safeguard lmmedica’s intellectual property and fully cooperate in the establishment, protection, maintenance and defence af lmmedica’s intellectual property rights.

lmmedica respects confidential information and intellectual property af third parties. Therefore, we will not obtain ar infringe an such information by illegal or unethical methods either directly ar through the use of an agent, nor improperly disclose such information to any third party, nor misappropriate such information. In addition, we will not seek confidential information from other lmmedica’s employees regarding their former employers.

lnside information and trading

lmmedica may make a limited number af investments in public companies. To the extent that information is held by the lmmedica that could be deemed as inside ar sensitive, a “stop list” will be maintained that the employees or other representatives will be required adhere to (this is dealt with further below).

lmmedica associated personnel or managers are therefore prohibited from carrying on the following:

(a) market abuse or insider dealing;

(b) dealing in financial instruments as a result of the misuse or improper disclosure of confidential information;

(c) dealing in financial instruments that have been added to the Stop List unless consent is first obtained (see summary under ‘Stop List’ below); and In addition to these matters, the lmmedica associated personnel are also prohibited from:

(a) advise/procure and/ar disclose information to a third party which that lmmedica associated personnel knows or ought reasonably to know would or would likely to lead the third party to:

(i) enter inta Prohibited Transactions or engage in conduct that would otherwise constitute a misuse of information relating to pending transactions; or

(ii) advise or procure another person to enter into a Prohibited Transaction. Finally, lmmedica associated personnel are prohibited from having a related person engage in any of the matters set out above on their behalf oron the related person’s behalf.


Personal information
It is lmmedics’s policy to respect the privacy of “personal information”. Personal information is information that can be used to identify a specific individual by name, date of birth or other description contained in that information. It can include information about employees, patients, clinical study subjects, doctors, employees of customers and others.

We will comply with all applicable laws and regulations regarding protection of personal information in countries where we do business. These laws and regulations vary from country to country. At a minimum, however, we will adhere to the following:

  1. We will collect personal information only for legitimate business purposes and by lawful means, and will not disclose or use personal information for purposes other than a legitimate business purpose or as required by law.
  2. We are fully compliant with the new GDPR regulations.
  3. We will protect personal information by reasonable security safeguards against accidental loss or destruction or unauthorised access, use, modification or disclosure.

Company records

  1. Company records: we will comply with all applicable laws and regulations and company policies relevant to corporate accounting. We will record all transactions on the company books accurately and properly in accordance with generally accepted accounting principles, and will not make any false or artificial entries. We will maintain internaI control systems to ensure that all transactions are accurately and properly recorded.


  1. Relationship with suppliers and customers: We will select suppliers and customers based on fair and objective standards and without favour or preference based on any personal relationship.

  2. Hospitality and gifts: We will not acceptor solicit any illegal or inappropriate benefits (including money, goods, hospitality, gifts, or any other item of value) from suppliers, customers or others with whom we do business.

  3. Personnel issues: We will handle personnel issues impartially and fairly, and will not give any advantage to an employee based on a personal relationship in handling personnel issues such as recruitment, evaluation, transfer, or promotion.

  4. lmmedica does not tolerate child labour in any form. No person younger than the statutory minimum age for employment according to the UN Convention on the Rights for the Child shall be employed.

  5. lmmedica does not tolerate forced, compulsory or involuntary labour in any form. This includes any work or service that is extracted from someone under the menace of any penalty, and for which that person has not offered him or her voluntarily and against their own will or choice.

  6. lmmedica respect diversity, tolerate no discrimination, harassment or abuse. lmmedica will not engage in physical, sexual, psychological, and verbal or any other forms of harassment or abuse, or any other behaviour that could create a hostile work environment. All employees shall be treated according to his or her abilities, qualifications, experience, behaviour, work performance and demonstrated potential in relation to the needs of the job in any employment decision, including, but not limited to, recruitment, promotion, compensation, benefits, training and termination. lmmedica takes appropriate measures to prevent such discrimination and harassment.

  7. All employees are free to exercise their legal right to form, join or refrain from joining organisations of their own choice and which represent their interests as employees. lmmedica shall also respect the employees’ legal right to collectively bargain, a voluntary processor activity through which employees discuss and negotiate their relations, as applicable under local laws.

  8. Employee Health & Safety: lmmedica is committed to providing a healthy and safe work environment for its employees. We will comply with all applicable laws, regulations and company policies regarding occupational health and safety. Consequently, lmmedica will take appropriate action to prevent workplace accidents or illness.

Human rights and environment
lmmedica supports and respects the protection of internationally proclaimed human rights andmakes sure that we are not complicit in human rights abuses.

lnternational sourcing and distribution means that lmmedica needs to be aware of potential human rights issues both upstream and downstream in the business.

lmmedica will support a precautionary approach to environmental challenges and undertake initiatives to promote greater environmental responsibility and encourage the development and diffusion of environmentally friendly technologies where possible.

lmmedica is committed to minimising any adverse environmental impact of its products and operations. We will comply with all applicable laws, regulations and company policies concerning environmental protection and accident prevention in all our business activities and conduct them in away that will conserve natura I resources.

Corporate Social Responsibility and sustainability
lmmedica will continuously work with CSR and sustainability items. As a part of the lmpilo AB group, We are committed to follow the policies and directives found in the UN PRI framework.

Management of suspected breach of the code
We have an obligation to raise and report our cancerns about anything we think may be a violation or a potential violation of the Code of Conduct or the local code (if applicable).

We strive to have an atmosphere where every line manager and supporting function shall be ready anytime to openly address and advice on a compliance concern or question raised by an employee. lf you have cancerns or questions about possible ethical misconduct, or suspect a possible violation of the Code of Conduct should contact any of the following:

Your manager as soon as possible, or if not available, or Our Compliance Officer.

Regular review of the Code of Conduct
The Code of Conduct will be regularly reviewed (once annually, or when specific developments so demands),  to ensure that it is current and up to date.