Code of Conduct

General

Immedica expects that our collaboration partners behave according to our core values by acting responsibly towards colleagues, business associates and society at large; and take into consideration that your behavior, through our collaboration, can reflect on Immedica. 

This Code of Conduct recognizes that compliance with law and relevant regulation when conducting business with Immedica is a fundamental duty and an essential part of the responsibility of you and each of your employees. 

This code is attached to a main agreement and should be regarded as an integral part of such agreement. 

You / Your means Immedica’s collaboration partner under the applicable collaboration agreement.

Immedica means the Immedica group from Immedica TopCo AB including its subsidiaries which includes without limiting Immedica Pharma AB and all country affiliates.

Product and safety quality

Patient safety is the highest priority for Immedica. In Your development, manufacture, storage and distribution activities, You will comply with all applicable laws and regulations, including reporting of safety information designed to ensure the safety and quality of pharmaceutical products. You will also adhere to Your internal policies and standard operating procedures designed to protect patient safety and to ensure quality of Immedica´s products.

Relationship with health care professionals

Immedica 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.
You will not provide, offer, or promise any money, goods, hospitality, gift or any other item of value to induce or reward favourable treatment of Immedica’s products.
If You obtain consulting services, advisory board services, or any other services from healthcare professionals, You will have a legitimate business need and You will not pay more than an appropriate market value for the services rendered.

Advertisement and promotion

You and Your employees will 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.
You will follow applicable company procedures designed to ensure that Your promotional information and advertisements comply with regulatory requirements and are accurate, balanced, fair, supported by scientific evidence and are not false or misleading.
If You have been authorized to promote Immedica’s product(s), You will not promote Immedica’s product(s) for a specific use in a country until the requisite approval for marketing for that use has been given in that country.

Anti-corruption and anti-bribery

You and Your 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. You should work against corruption in all its forms, including extortion and bribery. 
You 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, You will not provide any payment or benefits to private sector employees to influence them to obtain or retain a business advantage.
You will not accept or solicit any illegal or inappropriate benefits (including money, goods, hospitality, gifts, or any other item of value) from suppliers, customers or others with whom You do business.
You will also ensure that those who act on Your behalf, such as agents, will not engage in corrupt practices.
 

Procurement and Trade Compliance

You will contribute to and work for honesty, reliability and professionalism in Your contacts with suppliers and subcontractors. You will select suppliers and customers based on fair and objective standards and without favour or preference based on any personal relationship. You only work with qualified third parties who have a commitment to ethics and integrity consistent with Immedica’s.    
Your 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 You are active. Purchasers and others in the purchasing chain will never participate in contexts where some form of illegal cooperation exists, where competition is limited, such as joint pricing decisions, including production quotas, etc. Your employees will cooperate with all relevant authorities in such matters.
You will comply with all applicable export control laws and trade compliance regulations in the countries where You operate.  When exporting products or procuring services, You must ensure that all activities are conducted in accordance with these laws and regulations. This includes obtaining necessary licenses, adhering to restrictions on certain countries and entities and ensuring that all transactions are screened against applicable sanctions lists. Your employees will familiarise themselves with the export control requirements relevant to their roles and responsibilities. 

Competition and anti-trust

You will comply with all applicable competition and anti-trust laws in all countries where You do business. In particular, You will adhere to the following:
1.    You will not exchange information with competitors on pricing, outputs, capacity, customer selection, or exchange any other competitive information, and will not enter into any agreements on those matters (such as price fixing, market allocation, and bid rigging).
2.    You will not participate in trade association meetings or other meetings with competitors where You anticipate that such exchange of information or agreements will be requested.
3.    You 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 Immedica's money, property and other assets and will use them solely for the purpose of carrying out Our duties to Immedica and will not misappropriate or embezzle these for ourselves or for any third party.
You will keep confidential and protect all confidential information, including trade secrets and business or technical information about Immedica and its products, and You will not improperly disclose such information to any third party, nor will You use such information for any purpose other than performance of Your duties to Immedica.
All intellectual property owned, developed or obtained by Immedica are vital assets of Immedica. Therefore, You will carefully safeguard Immedica's intellectual property and fully cooperate in the establishment, protection, maintenance and defence of Immedica's intellectual property rights.
Immedica respects confidential information and intellectual property of third parties. Therefore, You will not obtain or infringe on such information by illegal or unethical methods either directly or through the use of an agent, nor improperly disclose such information to any third party, nor misappropriate such information. 

Inside information and trading

It is the responsibility of each individual to know the rules for trading and any trading is the responsibility of such individual. To the extent that information is disclosed to you by or on behalf of Immedica which the general public does not have access to, and if such information would likely have a significant effect on the price of the company’s share or other financial instrument, then such person is not entitled to trade in the share or financial instrument of such company.
Finally, Your associated personnel and other representatives are prohibited from having a related person engage in any of the matters set out above on their behalf or on the related person’s behalf.
 

Personal data and privacy

It is Immedica's policy to respect the privacy of "personal data". Personal data is information that can be used to identify a specific individual by name, date of birth or other description contained in that information as well as information that in combination with other information can be used to indirectly identify a specific individual. It can include information about employees, patients, clinical study subjects, doctors, employees of customers and others.
You will comply with all applicable laws and regulations regarding protection of personal data in countries where You do business. These laws and regulations vary from country to country. At a minimum, however, You will adhere to the following principles:
1.    You will collect personal data 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.    You will protect personal data by reasonable security safeguards against accidental loss or destruction or unauthorised access, use, modification or disclosure.
3.    You will inform individuals of collection and processing of their personal data, allowing them to make informed decisions and exercise their privacy rights. 
4.    Individuals whose personal data is processed by You have the right to access their data, request corrections, and, where applicable, request deletion or restriction of their data. You will respond to such requests in accordance with applicable laws.
5.    You will retain personal data only as long as necessary for the fulfilment of the purposes for which it was collected or as required by law.
6.    In the event of a personal data breach, You will promptly assess the risk to individuals' rights and freedoms and, if necessary, notify the relevant supervisory authority, affected individuals and if applicable notify Immedica.

Workplace

1.    Personnel issues: You 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.
2.    You will respect diversity and tolerate no discrimination, harassment or abuse. In Your working place, You will not accept or 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. Your employees shall be treated according to her/his/their 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. You will take appropriate measures to prevent such discrimination and harassment.
3.    You will seek to create an inclusive work environment where all employees feel respected, safe, heard, supported and valued, allowing them to contribute to their fullest potential, leading to higher engagement and innovation. An inclusive and diverse workforce enables us to understand and address the unique needs of patients, healthcare professionals, and partners on a global scale. You will offer opportunities for Your employees to develop, grow and continuously improve individual skills to strengthen the competencies of You company as a whole.
4.    All Your 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. You shall also respect the employees' legal right to collectively bargain, a voluntary process or activity through which employees discuss and negotiate their relations, as applicable under local laws.
5.    Employee Health & Safety: You will provide a healthy and safe work environment for Your employees. You will comply with all applicable laws, regulations and company policies regarding occupational health and safety. Consequently, You will take appropriate action to prevent workplace accidents or illness.

Human rights and environment

Immedica supports and respects the protection of internationally proclaimed human rights and makes sure that we are not complicit in human rights abuses.
International sourcing and distribution means that we need to be aware of potential human rights issues both upstream and downstream in the business and You agree to inform Immedica about any such issues.
Immedica 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 of the Child shall be employed by You.
Immedica does not tolerate forced, compulsory or involuntary labour in any form. You will not have any work or services performed that is extracted from someone under the menace of any penalty, and for which that person has not offered her/him/them voluntarily or is against their own will or choice.
Immedica is committed to take actions to minimize the carbon footprint and other pollution, protect land, water, and natural resources and biodiversity impacted by its operations as well as to impact Immedica’s third party vendors to minimize theirs. We aim to have a good understanding of Immedica’s environmental risks and challenges, and the environmental impacts caused by Immedica’s operations, including those of Immedica’s partners. 
You must take responsibility for environmental issues over which You have control, at all levels of the organization. Each employee is responsible for preventing and to reduce environmental impact where possible and to suggest ways to do. 
You will manage and follow up the environmental impact and performance across operations. You will perform appropriate due diligence when selecting partners, suppliers, and contractors as well as in evaluating potential business acquisitions, to reduce the indirect negative footprint and to minimize the risk of contracting operations with low sustainability ambitions. Through continuous improvements, You will reduce the impact of Your operations on the environment. 

Sustainability

Global sustainability is grounded in the principles of justice and equality among individuals, as well as the preservation of our environment and all its species. At Immedica, we recognise our responsibility for our own activities and for our place in the broader value chain. Accordingly, we have established a framework for Environmental, Social and Governance (ESG) matters. We are committed to advancing the UN Sustainable Development Goals, guided by two core pillars: making a lasting difference in patients’ lives and fostering a sustainable organisation and operations.
Immedica expects its third-party partners to share these standards. We will work with our third parties throughout the life cycle of the partnership, including diligence, contracting, collaboration, regular monitoring, auditing, and evaluation, to enhance our global sustainability impact. By joining forces with Immedica under these principles, our partners play a key role in promoting justice, equality and environmental stewardship for the benefit of everyone.

Management of suspected breach of the code

If you have concerns or questions about possible ethical misconduct, or suspect a possible violation of the Code of Conduct you should rectify the violation as soon as possible and inform the Immedica Compliance Officer as soon as possible on [email protected] 
We foster an open and honest culture in Immedica and SpeakUp is an important tool to ensure that also sensitive issues can be reported, and that the reporting route shall not be a barrier. SpeakUp is a system to report actual or suspected misconduct which offers anonymity for the reporter. It is available 24 hours a day and hosted by an independent third party. It is available on the Immedica homepage (immedica.com).