Code of Conduct

The Scope of this Code of Conduct is to:

• Apply globally to all Camurus group companies in relation to the sale, supply, procurement, distribution etc. of all Camurus products and services.
• Set out the business conduct and ethics for Camurus.
• Assist the organization in the daily work and business activities to promote the long-term positive development of the Company.

This Code applies to all directors, officers, employees, permanent and temporary, contractors, consultants and agents working on behalf of Camurus (below referred to as “employees”).

Camurus (“we” or the “Company”) strives to be recognized for the value we bring to patients, healthcare stakeholders, society, customers, and partners. We strive to always be trusted and respected for the way we conduct our businesses; in research, development and when marketing our products.

Our professional activities and daily decisions shall be performed in line with Camurus values: — Passion, Innovation, Quality, Collaboration and Ownership, and be supported by the company objectives, reflecting our respect for each other’s skills, viewpoints, and decisions. We are energetic, proactive, and innovative and always respectful of each other, our business partners, and customers.

This Code, including all matters contained herein, does not constitute any individual third-party rights and may be subject to revisions from time to time. Camurus reserves the right to amend or replace this Code, including its content, without prior notice at any time.

4.1 Risk awareness

Corporate social and sustainable entrepreneurship is central to all business endeavors and plays an increasingly important role in corporate competitiveness, profitability, and sustainable shareholder value. Breaches of applicable laws and regulations may have severe consequences for Camurus, for example fines, penalties and sanctions, imprisonment, and reputational damage. If there is a conflict between the provisions set forth in applicable laws or regulations, versus this Code, the strictest provisions will always apply.

4.2 Research and development

Camurus is engaged in developing new and innovative medicines with the ultimate goal of contributing to improvement of the lives of patients and society as a whole. Clinical research and the conduct of clinical trials in humans to evaluate the safety and efficacy of products for the treatment and prevention of disease are critical components of medicinal product development. Camurus will always apply high ethical standards in the conduct of its research and development activities, complying with applicable laws and regulations, including the Declaration of Helsinki governing research and development performance (1), and international standards of good practices, such GLP (2) and GCP (3).

Camurus is fully committed to protecting the patients and volunteers who take part in our clinical trials; ensuring we uphold the highest ethical, scientific, and clinical standards in all of our research initiatives; and providing study results in a timely, objective, accurate and complete manner and recognizes there are important public health benefits in making study results available to patients, health care providers, and the general public. All data from clinical research is recorded, handled, and stored in a way that enables accurate reporting, interpretation, and verification. Individuals participating in clinical trials should not be exposed to any unnecessary risks.

When Camurus have to use animals for research purposes Camurus is, according to the company Animal Welfare Policy (4), committed to treating them respectfully, minimizing discomfort and pain. Alternatives to animal research will be used whenever possible.

4.3 Product information, advertisement and promotion

Camurus is committed to providing only truthful, balanced, non-misleading and accurate information about our products, that is supported by scientific evidence. Patients and HCPs have a right to independently decide the best course of care, based on truthful, fair, substantiated and scientifically rigorous claims.

Camurus is committed to complying 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 only promote products for uses that have been approved in a manner consistent with the country-specific approved labeling.

4.4 Product safety and quality

Patient safety is the highest priority for Camurus. In our research, development, manufacture, storage, distribution, and post-marketing 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 also will always adhere to our internal policies and standard operating procedures (SOPs) designed to protect patient safety and to ensure quality of our products.

Products in clinical trials and/or on the market will be monitored for adverse events, new and unexpected safety signals and the regulatory agencies will be informed about these in accordance with applicable rules and regulations. Every employee is responsible for reporting any safety or performance issues relating to investigational medicinal products in clinical trials and our marketed products.

4.5 Conflict of interest

A conflict of interest can occur when an employee's private interest interferes with the interests of the Camurus. We should always avoid that any private interests influence our ability to act in the interests of Camurus, or makes it difficult to perform our work objectively and effectively.

All Camurus’ employees must disclose, to their Line Manager, any situations that reasonably would be expected to give rise to a conflict of interest, even small or perceived.

Refer to Camurus Anti-Corruption Policy (5), for further provisions and examples.

4.6 Interactions with healthcare stakeholders

Camurus recognize that our interactions with HCPs, healthcare organizations and other healthcare stakeholders are particularly sensitive to conflicts of interest. We therefore take careful consideration into such interactions, to ensure that no illegal, unjust or unethical activities may take place, such as false or misleading information or comments about our products or the products of our competitors.  Camurus is committed to applying the highest standards of integrity and honesty, and to follow applicable laws and regulations and codes, in all such interactions. There must be legitimate needs for engaging the services of HCPs or organizations and any payment for such services. Furthermore, payments may only be provided if there is a written agreement governing the applicable services and must not exceed fair market rate for such service.

4.7 Interactions with Government regulatory agencies

Camurus operates in a highly regulated industry. Governmental regulatory agencies routinely request information during audits, inquiries, and investigations. Camurus employees shall at all times deal honestly and professionally with such government agencies and their officials.

4.8 Procurement

Camurus’ suppliers play an important role in our research, development, and commercialization of our products. We will always choose our suppliers based on objective criteria, and with the expectation that our suppliers will act in a manner consistent with our own commitment to lawful, fair, and ethical business practices.

Camurus’ employees shall always:

1. Select vendors and suppliers based on objective criteria, such as price, merit, quality, service, reliability, reputation, and by minimizing any negative impact on sustainability matters, such as the climate, environment or human rights.
2. Make sure that vendors and suppliers comply with all applicable laws and regulations, and act in a manner consistent with our commitment to ethics and compliance as outlined in Camurus Vendor Code of Conduct (6). 
3. Report all allegations of improper business practices, bribery and corruption relating to vendors and suppliers, in accordance with the established procedures for reporting misconduct (refer to section 5 “POLICY Compliance” further below).
4. Avoid conflicts of interest, inappropriate gifts, and entertainment. Never accept any personal gifts, cash, credit, services, payments, loans, personal discounts or other favors from a vendor or supplier. Refer to Camurus Anti-Corruption Policy (5) for further details.

4.9 Anti-corruption and anti-bribery

Camurus has zero tolerance towards bribery or any other forms of corruption, that involves our employees, suppliers or any other third-party with whom we interact. No offer or promise of anything of value to influence purchasing decisions, reward or encourage the use or recommendation of our products, must ever be made.

All payments made to a public or government official or private individual must be appropriately recorded.

The Camurus Anti-Corruption Policy (5), the Vendor Code of Conduct (6), our Third-Party Risk-Management Framework, and the set of Company Guidance covering healthcare interactions, provide further procedures, measures, and controls to prevent corruption, that must be adhered to across our business.

4.10 Competition and anti-trust laws

Camurus must comply with all applicable competition and anti-trust laws. These laws prohibit agreements with competitors, suppliers, and customers to fix prices or to otherwise restrain trade.

Camurus does not engage, directly or indirectly, in activities that may be viewed as anti-competitive or unethical, or in any activity involving bid-rigging or boycott. Employees of Camurus should not engage in discussions or activities that could lead to the appearance of improper behavior, and should never discuss issues relating to pricing, sales, inventory, or marketing plans with competitors.

4.11 Prevention of money laundering and financing of terrorism 

Being complicit in money laundering, where the money laundering purpose is known but also in circumstances where measures can be assumed to be taken for such purpose, can lead to criminal liability for individuals and, in some jurisdictions, for companies. It may also lead to severe fines and reputational damage. Camurus is not to take part in and shall prevent money laundering and financing of terrorism throughout our operations.

4.12 International trade controls

In doing international business, Camurus is committed to complying with all applicable laws, regulations, licensing requirements, boycotts, embargoes, trade and economic sanctions laws and other restrictions placed on certain products, markets, territories, entities, or individuals that have been enforced by recognized national and international authorities, including, as applicable, the United Nations, Sweden, European Union, United Kingdom and United States of America. Camurus will always provide accurate and correct information about our products to customs authorities and other relevant authorities.

4.13 Political activities

Camurus observes strict neutrality with regards to political parties and candidates, and shall thus not make any contribution or payment, directly or indirectly, to political parties, committees or to individual politicians.

However, Camurus supports the right for individuals to engage in personal political activities, as long as these activities remain private, are lawful and ethical, and are conducted on personal time with personal resources. Camurus Employees shall never act, or appear to act, as a representative of Camurus when engaging in personal political activities; or use Camurus’ assets, including work time, equipment, or facilities, for personal political purposes, or solicit contributions or distribute political materials during work hours.

Camurus Anti-Corruption Policy (5) contain additional provisions on lobbying and must be adhered to when engaging with policy makers.

4.14 Data privacy

Camurus may in the conduct of its business collect and use personal information. Camurus is committed protecting individuals from unauthorized use and disclosure of their personal information and providing individuals with transparency and choices regarding how their personal information is used.

Camurus will always comply with Data Privacy laws and related regulations regarding collection, use, retention, disclosure and all other processing of personal data gathered or entrusted to Camurus, as further stipulated in our Data Protection Policy (7) and the associated guidelines, which together specifies applicable standards and obligations in respect of data privacy. Employees shall always respect the sensitivity regarding collected or entrusted personal data, and make sure such data is secure so that the integrity of such data is not at risk and that such data is not wrongfully disclosed. Particular cautiousness shall be adhered to when processing special categories of personal data, such as health-and genetic data.

4.15 Company records, disclosures and securities transactions

Company records shall always 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. We will always maintain internal control systems to ensure that all transactions are accurately and properly recorded, and never make any false or artificial entries.

Disclosures of company information shall always be made in a timely manner, and accurately disclose of company information to investors. Camurus will comply with all applicable laws and regulations and company policies regarding financial disclosures. All employees involved in public disclosures will familiarize themselves with these laws and regulations and company policies. All communications and disclosures on behalf of Camurus must be fair, true, correct, timely and not misleading and may be made only by authorized individuals. Any uncertainty about the validity of any entry, data, record or report must be immediately reported to a manager or supervisor.

Insider trading is strictly prohibited, and we will comply with all laws and regulations restricting insider trading of securities. If we become aware of “material non-public information” concerning Camurus, or any company conducting business with Camurus, we will not buy or sell securities of Camurus or the other company, either on our own account or on behalf of Camurus or any person or entity. Moreover, we will never provide material non-public information to others, until it is publicly disclosed in accordance with applicable laws, regulations, and company procedures. “Material non-public information” is any non-public information that could have a material influence on investors’ decisions to sell or buy securities. Examples may include issuance of shares, repurchase of shares, mergers and acquisitions, commercialization of new products, progress or failure of clinical trials, and material changes in financial forecasts.

Information is “non-public” if it has not been made generally available to the public by means of a press release or other means of widespread distribution. Information is “material” if a reasonable investor would consider it important in a decision to buy, hold or sell shares or other securities.

The Camurus Insider Policy and Guidelines (8) and the Camurus Communication Policy (9) further specifies applicable standards and obligations in relation to disclosures and insider trading.

4.16 Company property and intellectual property

Camurus physical assets, such as equipment, materials, supplies, money, and its intangible assets, like intellectual property, confidential information, value of our products and brand names, business relationships and employees’ time, skills, and talent, may be used solely for the benefit of Camurus and its business, and not for personal or inappropriate purposes.

Camurus’ employees shall protect Camurus’ properties and ensure their efficient use for business purposes. The use of Camurus’ funds or assets for personal gains and other improper purposes is strictly prohibited. Camurus’ equipment is intended for business purposes and not for personal use, other than incidental use that is reasonable and permitted by Camurus’ policies.

Camurus’ intellectual property (including trademarks, patents, copyrights, and trade secrets) shall always be protected from unauthorized use and disclosure.

4.17 Media and communications

Shareholders, investors, partners, customers and the public rely on Camurus to provide accurate and reliable information about our operations, performance and future outlook. As information can be spread widely and instantaneously via the Internet and other media, it is important that our communications with external audiences are consistent and aligned with the policies and needs of the company. For this purpose, it is critical that communication is coordinated and only goes via defined functions:

1. Press and media inquiries should be referred to the CEO. Camurus’ business should never be discussed on or off the record.
2. Investor inquiries should be directed to the CEO, the Head of IR, or the CFO. All meetings with investment professionals should be done after information to, and approval by the CEO. 
3. Speaking engagements always require approval from management, following appropriate internal review and approval processes.
4. Submission of abstracts and articles for publication always require written approval and following appropriate internal review and approval processes.

The Camurus Communication Policy (9) further specifies applicable standards and obligations in relation to media and communication.

4.18 Social media

Employees of Camurus undertake to use social media responsibly. This includes activities such as not to discuss material non-public information or any other confidential, proprietary, or personal information. Also, it includes no posting or commenting regarding Camurus’ products, pipeline projects and/or services on personal social media accounts, unless explicit authorization to do so has been provided.

Personal activities on social media may impact the way Camurus is viewed, and employees must therefore carry a professional and respectful tone when engaging with others on social media. 

The Camurus IT Communication Policy (10) further specifies applicable standards and obligations in respect of social media activities.

4.19 Confidential information

Employees have access to a variety of confidential information while employed at Camurus. Confidential information includes all information that is internally generated by Camurus concerning its business. It may also include information obtained from sources outside Camurus, including information about other companies or their securities. Confidential information includes all non-public information that might be of use to competitors, or, if disclosed, harmful to Camurus or its customers. Employees have a duty to safeguard all confidential information of Camurus or third parties with which Camurus conducts business, except when disclosure is authorized or legally mandated. An employee’s obligation to protect confidential information continues after he or she leaves Camurus. Unauthorized disclosure of confidential information could cause competitive harm to Camurus or its customers and could result in legal liability to the employee and Camurus.

4.20 Respecting human rights

Camurus respects the individual and is committed to complying with all applicable employment laws and regulations as well as the principles laid out in the United Nation’s Universal Declaration of Human Rights (11), the UN Guiding Principles for Business and Human Rights (12), and International Labour Organization (ILO) Conventions (13).

4.21 Equal opportunity and non-discrimination

Camurus is committed to being a positive workplace, free from discrimination or harassment of any kind. We value the contributions of each individual and group and treat one another with respect, regardless of position, statue, or relation. Camurus does not tolerate any form of discrimination or harassment and bases all employment-related decisions, such as recruitment, hiring, remuneration, promotion and development opportunities on the job qualifications, merit and/or performance of the individual, without regard to gender, sexual orientation, age, race, or identity expression, or other characteristics protected by applicable laws. Employees should never harass, degrade, or discriminate against others and never behave in a violent or threatening manner.

Refer to Harassment and Victimization HR Policy (14) for further provisions.

4.22 Working hours and compensation

Camurus has a responsible approach on wages, working hours, overtime and benefits. Our employees must be compensated in line with or above the legal minimum.

4.23 Freedom of association

Camurus is respectful of its employees' right to join or to refrain from joining and forming independent trade unions and the freedom of association and to bargain collectively. No employee shall be subject to discrimination in his or her peaceful exercise of these rights.

4.24 Workplace safety and health

Camurus offices and production sites shall be safe and healthy working environments, where no one is subject to unnecessary risk. We strive to prevent work related accidents, incidents, injuries, illness and unsafe conditions.

Safety and health considerations should be integrated into everything we do and Camurus has adopted policies and procedures to facilitate workplace safety. Employees are expected to identify and understand the risks associated with their work, manage risks responsibly, and only perform work for which adequate training has been provided.

Employees should promptly report all health and safety issues, including unsafe conditions, accidents, near misses and work-related injuries; and promptly report all security issues, including threatening or violent behavior to their manager.

In addition to minimizing the risks for exposure to chemical, biological and other hazards and proactively reduce the risk for accidents in the workplace, Camurus supports programs aimed at improving the health and wellbeing of its employees.

Refer to Global Work Environment HR Policy (15) for further provisions.

4.25 No child labor or forced labor

Camurus supports and respects the protection of internationally proclaimed human rights. We do not tolerate child labor or any form of modern slavery including forced, bonded or compulsory labor, physical or psychological punishment or human trafficking.

4.26 Drugs and alcohol

Camurus do not tolerate or allow alcohol abuse or the use/distribution of illegal drugs on any Camurus premises. No one may work under the influence of alcohol or any substance that prevents co-workers from performing their work duties safely and effectively.

Refer to Alcohol, Drug and Addiction HR Policy (16) for further provisions.

4.27 Environment

Camurus strives to perform its business in such a way that minimizes Camurus’ operations environmental and carbon footprint. When Camurus use or buy equipment, materials, utilities and services the company strive to choose the option that is best for the environment from a long-term perspective. Camurus is further committed to conducting business in an environmentally responsible way that supports circularity, biodiversity and carbon neutrality.

Every co-worker has a role to play in living up to this commitment in our daily work. Furthermore, our managers and leaders have a special responsibility to ensure this commitment is actively adhered to and clearly communicated.

Employees should promptly report all environmental accidents and near misses to their manager.

The Camurus Environmental Policy (17) and Sustainability Policy (18) further specifies Camurus’ approach to environmental management.

5.1 Violations

Violation of this Code is not accepted and may result in formal sanctions being administered, depending on the nature and severity of the violation and in accordance with all applicable laws and regulations. Depending on the circumstances, there might be a need for corrective and preventive steps including training and counseling or disciplinary actions including termination of employment.

It is the responsibility of all Camurus employees to immediately report any suspicion of violation of this policy. Such concerns can be reported through ordinary Line manager reporting, HR, Camurus management, or to a representative of Camurus Legal or Compliance functions. Reports can also be made through Camurus’ whistleblowing system, which facilitate anonymous reporting and follow up. The whistleblowing system is available via Camurus intranet and the corporate website. Camurus will not tolerate retaliation against anyone for reporting concerns in good faith.

6.1 INS-0137

1. Declaration of Helsinki governing research and development performance
2. GLP
3. GCP
4. GUI-0027 Animal Welfare Policy
5. GUI-0022 Anti-Corruption Policy
6. Vendor Code of Conduct
7. GUI-0018 Data Protection Policy (GDPR)
8. GUI-0014 Insider Policy and Guidlines
9. GUI-0015 Communication Policy
10. GUI-0012 IT Communication Policy
11. United Nation’s Universal Declaration of Human Rights
12. United Nation´s Guiding Principles for Business and Human Rights
13. International Labour Organization (ILO) Conventions
14. HR Policy Harassment and Victimization
15. HR Policy Global Work Environment
16. HR Policy Alcohol, Drug and Addiction
17. GUI-0025 Environmental Policy
18. GUI-0021 Camurus Sustainability Policy