EUROMED GROUP CODE OF CONDUCT FOR BUSINESS PARTNERS

1. INTRODUCTION

This EUROMED Group Code of Conduct for Business Partners aims to ensure that EUROMED Group and its business partners always act in compliance with current legislation, and that they undertake to conduct their business in accordance with a set of ethical principles, to maintain long-lasting and stable business relationships.

This Code of Conduct shall be applied in accordance with the laws and regulations applicable at any given time, as well as in accordance with the other regulations that EUROMED Group may decide to apply to its activities.

2. ETHICAL PRINCIPLES

2.1. SOCIAL RESPONSIBILITY: HUMAN RIGHTS, EMPLOYEE WELLBEING AND EMPLOYMENT RIGHTS

2.1.1. COMPLY WITH ALL APPLICABLE LAWS, RULES AND REGULATIONS

The business partner undertakes to comply with all applicable laws, rules and regulations governing its professional activity.

The business partner undertakes to avoid any conduct that may be detrimental or potentially detrimental to EUROMED Group and that may compromise its interests, reputation or image.

EUROMED Group shall monitor, by any means it deems appropriate, the business partner’s knowledge of this Code of Conduct, always ensuring that it has in its possession an updated version of the Code of Conduct.

2.1.2. TREAT ITS EMPLOYEES WITH DIGNITY AND RESPECT

The business partner is committed to respect the human rights of its employees and to treat them with dignity and respect, as reflected in major international declarations such as the Universal Declaration of Human Rights and the International Labour Organisation (ILO) Declaration.

2.1.3. AVOIDING CHILD LABOUR

EUROMED Group does not tolerate child labour. The business partner may not employ children under the legal school leaving age and may not under any circumstances employ children under the age of 14 (or in accordance with national law if the minimum age is higher).

2.1.4. AVOIDING FORCED LABOUR AND ANY OTHER FORM OF MODERN SLAVERY

EUROMED Group does not tolerate any form of involuntary work or work exacted under threat of penalty or other sanctions, including compulsory overtime and work obligations. We therefore also expect our business partner to take measures to avoid forced labour, any form of modern slavery or other forms of domination or oppression in the workplace.

2.1.5. PROHIBIT ANY DISCRIMINATORY OR HARASSING BEHAVIOUR

The business partner shall prohibit any conduct that may amount to discrimination of any kind or that may be considered an abuse or offence. Likewise, it will not tolerate any aggressive behaviour or behaviour that could lead to moral or sexual harassment.

2.1.6. HEALTH AND SAFETY IN THE WORKPLACE

We expect our business partner to provide a safe and healthy working environment for their employees and to comply with all applicable occupational health and safety legislation. In addition, appropriate measures must be implemented to prevent work-related accidents and health hazards.

2.1.7. FAIR WAGES AND FAIR WORKING HOURS

Employees must be paid in accordance with applicable national and local laws, including minimum wage requirements, overtime pay and mandatory fringe benefits (e.g. social security contributions). Working hours must be in line with applicable law.

2.1.8. FREEDOM OF ASSOCIATION

Within the scope of applicable law, we expect our business partner to respect the rights of employees to freely associate, form and join trade unions, appoint employee representatives, form a works council and actively participate in collective bargaining. Employee representatives are not discriminated against or subject to reprisal for forming, joining or being a member of a trade union, and they are afforded the opportunity to exercise their representative functions in the workplace.

2.1.9. RESPECTING LAND RIGHTS

When acquiring, developing, building on or otherwise using land, we expect our business partner to observe the prohibition on unlawful eviction and dispossession of land, forests and bodies of water, particularly where their use secures a person’s livelihood.

2.1.10. DEPLOYING SECURITY PERSONNEL

If a business partner deploys private or public security personnel to safeguard business projects, it must adequately instruct and monitor such personnel to ensure that they do not resort to torture, cruelty, unreasonable violence, inhuman or degrading treatment, endanger life or limb.

2.2. ENVIRONMENTAL RESPONSIBILITY: CLIMATE PROTECTION

2.2.1. MINIMISING THE ENVIRONMENTAL IMPACT OF THEIR ACTIVITIES

We expect our business partner to make efforts to reduce emissions, wastewater, waste, and avoid excessive water consumption. Particularly, it should be ensured that the environmental impacts do not impede access to clean drinking water and sanitary facilities or endanger human health.

The business partner must make every effort to ensure that the handling, storage, transportation, reuse, recycling and disposal of all types of waste and wastewater are carried out safely and in accordance with applicable regulations.

2.2.2. COMPLIANCE WITH SPECIFIC ENVIRONMENTAL CONVENTIONS

Where relevant to their business activities, our business partner must treat persistent organic pollutants (POPs) and mercury-containing substances in accordance with the Stockholm Convention and the Minamata Convention. This includes handling waste, emissions or wastewater containing these substances, as well as complying with the Basel Convention in cross-border waste movement.

2.3. INTEGRITY AND ETHICAL CONDUCT

2.3.1. AVOIDING CONFLICTS OF INTEREST

The business partner shall avoid all situations that may lead its employees into having a conflict of interest between their personal interests (or those of their family) and those of their organisation, and shall always make decisions objectively.

2.3.2. PREVENT CORRUPTION AND BRIBERY

The business partner shall not permit any act or behaviour related to trading in influence or corruption, in accordance with applicable law. It shall also ensure that its employees do not offer, promise or give benefits to EUROMED Group employees or third parties on behalf of EUROMED Group.

The business partner undertakes to complete the Anti-Money Laundering Charter that EUROMED Group will provide.

2.3.3. RESPECT FREE COMPETITION

The business partner undertakes to compete fairly and avoid unfair competition and anti-trust behaviour. It must ensure that fundamental principles of anti-trust law are respected in contracts or agreements.

The business partner shall not disclose to competitors EUROMED Group’s strategic decisions or commercial, pricing or promotional policies.

2.3.4. PROTECT PRIVACY AND CONFIDENTIAL INFORMATION

The business partner shall comply with personal data protection rules and shall not use personal data for purposes beyond its functions.

The business partner must protect EUROMED Group’s information and documents and may use them only where strictly necessary. Disclosure to third parties is prohibited unless required by law or authorised by EUROMED Group.

The duty of confidentiality survives the termination of the business relationship.

2.3.5. COMPLIANCE WITH FOREIGN TRADE LEGISLATION

The business partner must have safeguards to ensure that transactions do not violate embargoes, trade rules, import/export controls or anti-terrorism financing provisions.

3. ETHICAL CHANNEL

An Ethics Channel has been set up where any person with a current or past employment or professional relationship with EUROMED Group can report infringements contrary to the law or internal regulations.

E-mail: de*******@*****ed.es

Postal mail:
A/A Compliance Officer (confidential)
C/ Rec de Dalt, 21-23, Pol. Ind. “Can Magarola”
08100 – Mollet del Vallès (Spain)

Web: https://dermapharm.integrityline.com/frontpage

Communications (anonymous if desired) can be made in writing or by voice message.

They may also be submitted via the external information channel of the Independent Authority for Whistleblower Protection or the corresponding regional authorities.

The Ethical Channel guarantees anonymity, absence of reprisals and confidentiality.

4. INFRINGEMENTS AND VERIFICATIONS

Infringements of this Code negatively affect EUROMED Group and all third parties with whom it has business relationships.

The business partner is responsible for compliance with this Code. EUROMED Group reserves the right to verify compliance through its employees or independent third parties. Cooperation is expected during verification.

5. SCOPE

This Code applies to all business partners of EUROMED Group.

6. RESPONSIBILITIES

The Sustainability Department of EUROMED Group is responsible for reviewing the Code of Conduct. The business partner is responsible for complying with the principles outlined in the Code.

7. SANCTIONS FOR VIOLATIONS OF THIS CODE OF CONDUCT

EUROMED Group considers violations of this Code as contractual breaches and may take legal action, conduct audits, apply due diligence checks, provide training or suspend/terminate business relations. The business partner will have an opportunity to take corrective action if violations are detected.

8. REVIEW

This policy has been approved by EUROMED Group’s board. It will be reviewed annually or as needed.

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