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The purpose of this Vendor Code of Conduct is to define Camurus’ expectations on vendors regarding ethical business conduct, labor and human rights, environmental responsibility, compliance with applicable laws, and reporting obligations, and reflects Camurus’ own commitments.

Camurus’ ambition is to contribute to sustainable development and integrate Environmental, Social and Governance (ESG) considerations into its business execution across its value chain. Camurus supports the United Nations Sustainable Development Goals (SDGs) and is committed to protecting the environment, including by promoting resource efficiency, reducing environmental impacts, preventing pollution, and supporting responsible use of natural resources throughout its operations and supply chains. Camurus is also committed to preventing, mitigating, and remedying adverse human rights impacts in accordance with the United Nations Guiding Principles on Business and Human Rights (UNGPs), and to addressing and minimizing other sustainability-related risks in its supply chains.

In line with its commitments, Camurus strives to ensure that all goods and services procured are produced under sustainable, environmentally responsible, and ethical conditions. Camurus expects its vendors to comply with this Vendor Code of Conduct, including applicable environmental laws and standards, and to make every effort to uphold its principles within their own organizations and throughout their supply chains.

This Code of Conduct applies throughout Camurus’ supply chain and to all kind of suppliers, collectively referred to herein as “Vendors.” It forms part of Camurus’ contractual arrangements with Vendors, either as an incorporated contractual provision or as a separately executed agreement.

In addition, according to Camurus’ sole discretion, Camurus may impose these requirements on any other contractual partner with whom the company is doing business, as reflected in the relevant contract with such a partner.

Laws and Regulations

Vendors shall comply with all applicable international, regional, and national laws and regulations, including conventions concerning human rights, labor rights, environmental protection, anti-corruption, and competition law. It is the responsibility of the vendors to verify legal compliance and compliance with this Vendor Code of Conduct. If there is a conflict between what is in the Vendor Code of Conduct and an applicable law or regulation, the strictest provision will apply.

List of international conventions to comply with (minimum requirement):

• The United Nations Universal Declaration of Human Rights (1948)
• The Eight Fundamental Conventions of the International Labor Organization, no. 29, 87, 98, 100, 105, 111, 138 and 182
• The United Nations Convention on the Rights of the Child, Article 32
• The United Nations Convention against Corruption
• The International Covenant on Civil and Political Rights
• The International Covenant on Economic, Social and Cultural Rights
• The labor protection and labor environment legislation in force in the country of production
• The labor law, including legislation on minimum wages, and the social welfare protectionregulations in force in the country of production
• The environmental protection legislation that is in force in the country of production

Ethics

Anti-corruption and business ethics  

Vendors shall comply with all applicable laws and regulations relating to competition, financial reporting, and taxation. Camurus maintains a zero-tolerance approach to corruption in any form, including bribery, extortion, kickbacks, and the offering or acceptance of improper private or professional benefits involving customers, third parties, contractors, vendors, employees, or government officials.

Vendors are prohibited from making so-called “facilitation payments” in connection with any Camurus-related supply, business, or other activity.

Vendors shall establish and maintain appropriate measures to prevent corruption, such as implementing anti-corruption policies and providing relevant training to employees.

Vendors must recognize that no Camurus employee may, directly or indirectly, offer or accept any improper advantage in exchange for personal benefit of any kind. Likewise, Camurus will not accept any benefit intended to facilitate a vendor’s business relationship with Camurus. Camurus does not accept that our vendors offer or provide any gifts or money to our employees, including personal gifts, cash, gift vouchers, credit, services, tickets for entertainment, payments, loans, personal discounts or other personal benefits.

Vendors shall also take appropriate measures to prevent their business operations from being used for money laundering, financing of terrorism, concealment or obstruction of justice, embezzlement, trading in influence, illicit enrichment or abuse of functions.

Vendors shall not enter into agreements intended to distort competition or abuse a dominant market position.

Vendors shall refrain from tax arrangements where there is uncertainty regarding compliance with applicable laws and regulations. Vendors shall also refrain from tax planning practices that exploit deficiencies in tax rules to artificially shift profits to jurisdictions with low or no taxation.

Research ethics

Vendors shall ensure that all research conducted on behalf of, or in collaboration with, Camurus complies with all applicable local and international laws, regulations, standards, and ethical requirements.

Animal Welfare

The principles and requirements below apply to Camurus-initiated studies performed at third party facilities (e.g., contract research organizations, universities, and other companies).

The Vendor is subjected to a vendor qualification by Camurus before carrying out any studies, ensuring these requirements.

Vendors are required to comply with all applicable local and national laws and regulations relating to animal welfare. In addition, they are required to comply with the following key principles, which embody the principles in Camurus’ Animal Welfare Policy:

• The welfare of animals is of primary concern
• The 3Rs (Replace, Reduce, Refine) are applied
• Studies are carried out by well-trained, competent, and experienced personnel
• Only animals specifically bred for research purposes are purchased and used
• Animals are treated respectfully and cared for in accordance with the needs of the given species and individual, as defined by current veterinary care and practice guidelines for animals used in experiments
• Animals shall experience a minimum amount of discomfort, distress or pain and appropriate methods for sedation, analgesia or anesthesia are utilized whenever possible.
• Rehoming and retirement of animals as appropriate for the health and well-being of the animal shall be supported if possible

Protection of information 

Vendors shall not expose to any unauthorized person or company any confidential information, sensitive information, or proprietary information, and not use such information for any other purpose other than the purpose for which it was provided, unless written consent from Camurus.

Vendors shall adequately protect personal data, which in many cases include compliance with GDPR (General Data Protection Regulation, EU 2016/679).

In the situation that the vendor, and/or a subcontractor to the vendor, will process personal data on Camurus behalf, an additional contractual arrangement in the form of a DPA (Data Processing Agreement) must be executed between Camurus and the vendor, unless such provisions are otherwise covered in the relevant contractual arrangement with the Vendor (e.g. in a Master Services Agreement). 

No Debarment

Vendors shall be able to represent and warrant that they currently do not and shall not in the future employ, contract with, or retain any person or entity directly or indirectly to perform any Services for Camurus if such a person or entity (a) is under investigation by any health authority for debarment, has ever been debarred, or is presently debarred by the FDA pursuant to 21 U.S.C. § 335a or its successor provisions, or (b) has a disqualification hearing pending or has been disqualified by the FDA pursuant to 21 CFR § 312.70 or its successor provisions; and that the Vendor has not engaged in any conduct or activity which could lead to disqualification or debarment actions by the FDA pursuant to 21 U.S.C. § 335a or its successor provisions, and that if, during the term of any agreement with Camurus, the Vendor or any person or entity employed or retained by it to perform Services for Camurus, comes under investigation of any health authority for a debarment action or disqualification, is debarred or disqualified, or engages in any conduct or activity that could lead to any of the above-mentioned disqualification or debarment actions, the Vendor shall immediately notify Camurus of it.

Human rights and labor rights

Respect of human rights and due diligence

All internationally recognized human rights, as expressed in the Universal Declaration of Human

Rights, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, and the ILO Declaration on Fundamental Principles and Rights at Work must be respected. Vendors are expected and strongly encouraged to conduct human rights due diligence, as set out in the United Nations Guiding Principles on Business and Human Rights UNGPs.

No child labor

Vendors must not engage in or permit any form of child labor. The employment of workers under the age of 18 is permitted only for non-hazardous work performed during daytime hours and only where such workers meet both the legal minimum working age in the relevant country and the minimum age for completion of compulsory education.

A worker under the age of 18 may nevertheless be legally employed if the applicable minimum age requirements for the specific type of work are met:

• For general employment, the minimum age is 15
• In countries where the school-leaving age is below 15, the minimum age for non-hazardous work may temporarily be reduced to 14

The vendor or its subcontractor shall develop, participate in, and support policies and programs that facilitate the transition of any child identified as engaged in child labor into education, ensuring that the child can attend and remain in education until they are no longer considered a child.

No forced and compulsory labor

Vendors must ensure that forced and compulsory labor, bonded labor, debt bondage, human trafficking, involuntary prison labor, or any other form of modern slavery or slavery-like practice is not used in any phase of their business operations, including within their own supply chain. Vendors must also ensure that all workers are free to leave their employment after providing reasonable notice.

Freedom of association and collective bargaining

Freedom of association and the right to collective bargaining must be respected. Worker representatives must not be discriminated against and shall have access to carry out their representative functions in the workplace. Where the right to freedom of association and collective bargaining is restricted under law, the employer shall facilitate the development of parallel means for independent and free association and bargaining.

Good working conditions

No worker should pay recruitment fees or deposits in order to secure their job, their employer-provided accommodation, or any training and equipment necessary to carry out their jobs.

All workers shall receive clear and comprehensible written contract regarding their employment terms, including wages, prior to commencing employment. They shall also be provided with detailed information concerning their wages for each relevant pay period every time they are paid. Wages and benefits shall be paid in a timely manner and directly to the employee.

Vendors shall ensure that wages and benefits paid for a standard working week shall as minimum meet national legal standards or industry benchmark standards. Vendors shall support the payment of fair and living wages to employees and shall, under no circumstances, pay wages below the applicable national or local minimum wage requirements. In any event wages should always be enough to meet basic needs and to provide some discretionary income. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

Working hours must comply with applicable national laws and collective agreements. Working hours, excluding overtime, shall be defined by contract and shall not exceed 48 hours per week. Vendors shall ensure that working hours comply with applicable national laws, relevant industry standards, and internationally recognized labor standards.

Total working hours shall not exceed 60 hours within any seven-day period, except in exceptional circumstances. Working hours may exceed 60 hours only where permitted by national law and by a collective agreement freely negotiated with a workers’ organization representing a significant portion of the workforce, provided that appropriate safeguards are in place to protect workers’ health and safety, and the employer can demonstrate that exceptional circumstances exist, such as unexpected production peaks, accidents, or emergencies.

Workers shall be entitled to at least one day off in every seven-day period or, where permitted by national law, two days off in every 14-day period.

Overtime compensation shall be paid and clearly specified in wage statements. Overtime hours must not exceed the limits established by national law or collective agreements, whichever provides greater protection to the worker. Where no such limits exist, overtime shall be limited to the extent necessary to protect the health and safety of workers.

All overtime work must be voluntary and shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be no less than 125% of the regular rate of pay.

Leave, including vacation, holidays, sick leave, and parental leave shall be compensated in accordance with national legislation.

Obligations to workers under labor or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labor-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

Healthy work environment

Vendors must provide a working environment that minimizes health and safety risks, supports accident prevention and ensures the health and safety of all personnel and all others affected by their activities.

A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment. Vendors should take appropriate measures to protect workers from over-exposure to chemical, biological, and physical hazards arising from their work, including through the provision of appropriate personal protective equipment, engineering controls, and exposure monitoring where relevant. Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers. Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers. Responsibility for health and safety shall be assigned to a senior management representative.

Emergency preparedness and response

Vendors shall have effective emergency plans and response procedures in place to address foreseeable emergency situations, including fire, chemical spills, natural disasters, and other incidents that could affect the health and safety of workers or the surrounding environment. Such plans shall include emergency evacuation procedures, employee training and drills, and reporting mechanisms, and shall be reviewed and updated periodically.

No discrimination and harassment

All workers must be treated with dignity and respect. Vendors shall provide a workplace free from harsh or inhumane treatment, corporal punishment, bullying, physical or mental harassment, coercion, or any other form of abuse.

Vendors must not discriminate in hiring, compensation, access to training, promotion, or retirement based on ethnic background, caste, gender, marital or parental status, age, national or social origin, membership of traditional marginalized groups, religion, sexual orientation, pregnancy, disability, union membership, political affiliation, serious illness or any other condition that could give rise to discrimination.

Grievance mechanisms

In cases of human rights or labor rights violations, vendors shall ensure that all workers have access to grievance mechanisms and effective remedies. Retaliation against workers who raise concerns is strictly prohibited. Vendors are required to promptly investigate and address worker concerns and provide timely responses to reported issues.

Environmental protection

Vendors shall comply with national and international environmental legislation and regulations and obtain required permits as adequate. 

Reducing environmental footprint 

Environmental risks have to be managed in an effective manner. Vendors shall have processes and systems in place to prevent and mitigate spills, releases, and other negative environmental impacts. Any release to the environment shall be properly treated prior to discharge and fully comply with all applicable environmental laws, regulations, and permit requirements. Vendors are encouraged to have an environmental management system according to ISO 14001 or EMAS in place.  

Vendors shall apply a precautionary approach and refrain from using materials or processes where there is uncertainty regarding potential adverse environmental impacts.

Responsible waste management

Vendors shall take appropriate measures to prevent and minimize the generation of hazardous¹ and other waste arising from their operations. Waste shall be handled responsibly, including through proper waste segregation and recycling practices, and vendors shall promote circular solutions that support reuse, recovery, and efficient use of resources. Waste shall be stored, handled, transported and disposed of in a manner that protects the health of workers, people in surrounding communities and the environment.

Reduced GHG emissions and energy use and sustainable resource use

Vendors shall work continuously to reduce energy consumption, greenhouse gas emissions, and the overall environmental impact of their operations. Climate measures that contribute to achieving national and international climate goals shall be promoted. Vendors are encouraged to regularly measure and report their Scope 1, 2, and 3 emissions, establish science-based climate targets, and track progress toward reducing their greenhouse gas (GHG) emissions. In addition, vendors should adopt a life-cycle perspective when assessing the environmental impact of their products and services and strive for continuous improvement in their environmental performance.

Vendors shall use energy, water, and materials efficiently and, where feasible, maximize the use of renewable energy sources. Strategies for efficient water use shall be promoted where applicable. No raw materials from species listed in CITES² or as critically endangered, endangered or vulnerable on the IUCN Red List of Threatened Species³ shall be used.

Vendors shall work actively to exclude or limit the use of hazardous chemicals and materials, and ensure proper handling, including storage, transportation, and disposal, to eliminate environmental impact. Where applicable, substitution and/or implementation of alternative processes shall be carried out to reduce health and environmental hazards and improve resource efficiency.

Environmental rights

Vendors shall respect the right of all peoples to self-determination and to freely dispose of their natural wealth and resources and shall not deprive any people of their means of subsistence.

Vendors shall not engage in or contribute to the illegal eviction or unlawful taking of land, forests, or water.

Vendors shall respect the rights of indigenous peoples to lands, territories, and natural resources that they have traditionally owned, occupied, used, or acquired, including the right to free, prior, and informed consent.

Vendors shall respect the right to a safe, clean, healthy, and sustainable environment as an integral part of the enjoyment of fundamental human rights, including the rights to life, health, food, water, and sanitation.

Vendors shall require their subcontractors to comply with the requirements set out in this Vendor Code of Conduct and they shall apply due diligence and actively monitor their suppliers’ adherence to these requirements. Vendors must also be able to provide information regarding the location and parties involved in the manufacture of goods ordered by Camurus.

Camurus and its vendors shall refrain from engaging with partners operating in countries that are subject to international trade sanctions imposed by the United Nations Security Council.

Corrective Actions

In the event of a breach of this Vendor Code of Conduct, Camurus and the vendor shall jointly develop and implement a corrective action plan within a reasonable timeframe. Any breaches must be reported to Camurus (see also the section “Raising Concerns” below).

Camurus reserves the right to audit or appoint a third party to audit on its behalf, the vendor’s compliance with the requirements set out in this Vendor Code of Conduct. Vendors are expected to cooperate fully with such audits, without compensation from Camurus, and to maintain all documentation necessary to demonstrate compliance with this Vendor Code of Conduct and applicable laws and regulations.

Raising concerns

Vendors shall report any suspected misconduct concerning the requirements set forth in this Vendor Code of Conduct, applicable laws, or regulations, and which relates to any Camurus interaction or Camurus business.

Suspected misconduct or violations related to this Vendor Code of Conduct may be reported through Camurus’ whistleblowing system available at Camurus AB Whistleblower System | Raising a concern or by email to [email protected]. Any retaliation by vendors against employees or other third parties for raising concerns or reporting violations in good faith is strictly prohibited.