Readopted by the Board of Directors, 27 June 2018

Corporate Ethics

1. Introduction

Corporate ethics are about how we behave towards each other and the outside world, including avoiding violation of any law. All employees of Biotec Pharmacon ASA and its subsidiary companies (the Group or the Company) are responsible for following the rules and guidelines that build on Biotec Pharmacon’s basic values and form attitudes we can be proud of.

Biotec Pharmacon’s guidelines for corporate ethics apply to members of the Board of Directors, managers and all employees of Biotec Pharmacon as well as others acting on behalf of Biotec Pharmacon. It is the manager’s responsibility to make sure every employee is aware of, and complies with these guidelines. It is the employee’s duty to read and follow the guidelines. Those who infringe Biotec Pharmacon’s Code of Conduct must be prepared to face the consequences that are in line with the infringement’s type and scope. Violation of the Company’s Code of Conduct may result in disciplinary action, up to and including termination of employment.

This policy applies to all units of Biotec Pharmacon and to all employees regardless of function, position, employment status, grade or standing. References in this policy to “Biotec Pharmacon” or “the Company” or “Group” are meant to include references to all entities of the Biotec Pharmacon Group.

2. General guidelines

Working environment
Biotec Pharmacon is committed to providing a work environment that is positive and professional. Therefore, you shall behave with respect and integrity towards anyone you come into contact with through your work. You shall help create an environment free from any discrimination, be it due to religion, skin color, gender, sexual orientation, age, nationality, race or disability and free from bullying, harassment or similar behavior. Any behavior that can be perceived as degrading or threatening will not be tolerated.

Loyalty, impartiality and conflict of interests
Biotec Pharmacon respects the individual employee’s right to a private life and private interests, but demands openness and loyalty to the Group and the Group’s interests. You shall not take actions nor have interests that make it difficult to perform your work objectively or effectively. Service to Biotec Pharmacon should never be subordinated for personal gain and advantage. Conflicts of interest should, wherever possible, be avoided. You shall never take part in or attempt to influence a decision or settlement if there is a conflict of interest, which could give grounds to question one’s impartiality.

Conflicts of interest could involve, but are not limited to, dealing with customers, suppliers, contractors, present or prospective employees, competitors, or outside business activities. Anything that would present a conflict for you would likely also present a conflict if it is related to a member of your family.

Should a conflict of interest arise you shall on your own initiative evaluate and notify your immediate superior of your partiality or the conflict of interest.

Every employee in the Group has a duty of confidentiality by law and written agreement. You shall keep confidential all corporate and other matters that could provide third parties unauthorized access to confidential information. You should exercise caution when discussing internal affairs so as to avoid being overheard by unauthorized persons. The duty of confidentiality also applies after the conclusion of your employment or contractual relationship with Biotec Pharmacon for as long as the information is considered to be of a sensitive nature or in any other way confidential.

Intellectual property
Intellectual property such as know-how, technology, design, methodology, concepts, ideas and drawings are important for Biotec Pharmacon to succeed in the market. If you are involved with the Group’s intellectual property you are required to protect and administer it in the interest of the Group. You shall also respect the intellectual property rights of others and seek to avoid violations of such rights. Unless otherwise specified by law or orders from public authorities, you shall not make corporate secrets or other important information available to unauthorized persons before obtaining a signed confidentiality agreement from each of those persons. Any intellectual property rights related to Biotec Pharmacon’s business activities developed by or in co-operation with Biotec Pharmacon employees is the property of the company.

Property and assets
Biotec Pharmacon’s property and assets, e.g. equipment and rented buildings, shall be managed and safeguarded in an appropriate manner. You shall observe the Group’s security requirements concerning access to and use of the group’s facilities, IT equipment and access to electronic documents. The Group’s equipment and property may only be used for personal purposes if agreed in connection with the employment or as a result of Biotec Pharmacon’s rules and guidelines.

Nature and physical environment
Biotec Pharmacon shall encourage environmental protection, by minimizing environmental damage and by developing, promoting and utilizing environmentally friendly technology. You shall bear in mind the environmental effects that work-related activities have and you shall choose environmentally friendly solutions as far as this is possible.

Information that may affect the stock price
As a publicly listed company, Biotec Pharmacon is subject to strict rules concerning the handling of non-public information that may affect the market price of Biotec Pharmacon shares and other financial instruments issued by Biotec Pharmacon.

If you have such information about Biotec Pharmacon, it is your responsibility to prevent access to it by unauthorized persons and/or disclosure before it has been received by the stock exchange and made available through the stock exchange’s information system, or before the information ceases to be sensitive.

If you have or receive information that may affect the stock price, you shall not trade in the financial instrument/share before the information has been made public or ceases to be sensitive. You must not provide such information to anyone, directly or indirectly, except those who have a real need for the information in order to perform their duties on behalf of Biotec Pharmacon.

If you are in doubt as to whether you have share price sensitive information or how you should act, ask for advice from the Group management as soon as possible.

Information, communication and contact with the media
All information from Biotec Pharmacon shall be reliable and correct and be maintained under high professional and ethical standards. All individuals who, through their work, deal with information are responsible for meeting these standards. Communication with the media, the public and the financial markets shall be done only by authorized personnel and in accordance with established guidelines and routines and satisfy the regulations and practice applicable to publicly listed companies.

Expertise and authority
All decisions shall be made at the appropriate level in accordance with the applicable regulations concerning authority. You may only obligate the company vis-à-vis others if you hold such special authority, and you must at all times keep within the limits of your authority.

3. Relations with Customers, Suppliers, Competitors and Public Authorities

Customers shall be met with insight, respect and understanding. You shall always try to fulfill the needs of the customer in the best possible manner, within the guidelines for corporate ethics that apply to the business. Customer’s personal information shall be protected in accordance with the relevant laws on protection of personal data.

Suppliers shall be treated impartially and justly.

Competitors to Biotec Pharmacon’s products shall always be met in an honest and professional manner.

Public authorities shall be met in an appropriate and open manner. Public information about the Group shall only be supplied by Biotec Pharmacon’s management or by the person responsible for public communications, unless otherwise agreed.

Biotec Pharmacon desires fair and open competition in all markets, both nationally and internationally. Under no circumstances shall you cause or be part of any breach of general or special competition regulations, such as illegal cooperation on pricing, illegal market sharing or any other behavior that is in breach of relevant competition laws.

Corruption and bribery
Biotec Pharmacon is firmly opposed to all forms of corruption. You shall never offer or accept illegal or inappropriate monetary gifts or other remuneration in order to achieve business or personal advantages for yourself or others. Nor shall you use agreements with middlemen to channel payment to anyone in such a way that may be interpreted as corruption.

Gifts and business courtesies
You shall always exercise caution in relation to offering or accepting gifts and business courtesies. You shall not accept gifts or other remuneration if there is reason to believe that its purpose is to influence business decisions. If in doubt, always consult your immediate superior.

Money laundering
Biotec Pharmacon is firmly opposed to all forms of money laundering and shall take steps to prevent its financial transactions from being used by others to launder money.

4. Relations to Employee’s Private Interests and Actions

As an employee of Biotec Pharmacon you shall not be employed or work as a contractor for another company without prior written permission from your superior.

Duty, positions and ownership of external businesses
Engagements in external duties and positions are positive, but their scope or type must not affect your working relationship with Biotec Pharmacon or come into conflict with Biotec Pharmacon’s business interests. Duties and positions outside the Company that are of a scope or nature that they can affect your working relationship with Biotec Pharmacon shall be expressly agreed in writing in advance by your immediate superior. This include but is not limited to activities like board duties, consultancy for or ownership of customers’, suppliers’, and joint-venture partners’ or competitors’ businesses.

Political activity
Biotec Pharmacon does not give support to political parties, either in the form of direct financial support or paid working time. Employees who take part in political activities will be granted leave from their work in accordance with the law and any agreements.

Use of electronic equipment
Biotec Pharmacon, as an employer, has facilitated its employees with electronic equipment to perform optimally within their job descriptions. All employees must ensure that the technology and equipment made available by the Company is used in a manner consistent with the Company’s practices and policies. Computers, communication systems, telephones, fax machines and related services (such as access to the Internet and voicemail) are provided as tools to allow you to better perform required tasks and to support Biotec Pharmacon’s business goals and objectives. Employees may not use any electronic equipment provided by the Company (including voice mail and e-mail) for any communication that contains content that may be reasonably considered offensive, defamatory, harassing or disruptive to any recipient. Electronic communications by employees that may constitute verbal abuse or defamation or that may be considered harassing, vulgar, obscene or threatening is strictly prohibited and may result in disciplinary action, up to and including termination.

Use of Internet
Access to any Internet site from Biotec Pharmacon property or during the Company’s operating hours is restricted to activities necessary for associates to perform their jobs. However, incidental use of these systems for appropriate personal reasons is permitted, but should never interfere with normal business operations. The Company reserves the right, without prior notice, to block, monitor or internally disclose associate Internet use, and will do so for legitimate business purposes. Inappropriate use of the Internet, including but not limited to downloading from illegal web sites, is strictly prohibited. If communicating by social medias, you are responsible to the Company within this Code as described in previous section.

5. Reporting and Accountability

Should you become aware of an infringement of Biotec Pharmacon’s policies and procedures or ethical guidelines, these concerns must be reported immediately to your superior. This includes any human resources matters, including, but not limited to, questions of impropriety as they might relate to sexual harassment or discrimination allegations.

If reporting to a superior is not possible, you should report the infringement directly to the CEO. The concern may also be addressed to Biotec Pharmacon’s Audit Committee. Incidents may be reported confidentially if desired. Failure to report infringements is in itself a breach of this Code.

Biotec Pharmacon will not implement sanctions in any form against any employee who informs individuals in positions of responsibility or the Audit Committee about possible infringements of Biotec Pharmacon’s policies and procedures, ethical guidelines, applicable laws or other blameworthy circumstances in Biotec Pharmacon’s business. These individuals shall take all actions they consider appropriate to investigate any violations reported. If a violation has occurred, Biotec Pharmacon will take such disciplinary or preventive action, as it deems appropriate.

Any changes to or waivers of this Code may only be made by the Board of Directors.

6. Compliance

All employees are committed to familiarize themselves with and adhere to Biotec Pharmacon’s Code of Conduct and related policies. Each employee must annually confirm compliance with the Code of Conduct policy.

The Code of Conduct is reviewed once a year, and Biotec Pharmacon reserves the right to modify, amend, suspend or terminate the Code of Conduct with or without notice. Employees are committed to keep informed on the latest and applicable version of the Code of Conduct. Failure to adhere to the Code of Conduct and/or related policies may lead to disciplinary actions or dismissal.