EUROMED GROUP CODE OF ETHICS

1.- INTRODUCTION

EUROMED Group (composed of EUROMED S.A.U. and its subsidiaries), is part of the DERMAPHARM Group.

The purpose of this Code of Ethics is to ensure that the EUROMED Group and its employees always act in a responsible manner, i.e. within the law and respecting the values upheld by both the DERMAPHARM Group and the EUROMED Group.

The Code of Ethics is based on ethical principles that must be complied with by employees, which must be reflected in their actions and decision-making.

The Organisation shall ensure that its employees are aware of the contents of the Code of Ethics and of the risks involved in actions contrary to the legislation in force and the obligations contained in this document.

The Code of Ethics is applied in accordance with the policies contained in the DERMAPHARM Group’s Compliance Manual and with the DERMAPHARM Group’s Principles of Conduct, and with the laws and regulations applicable at any given time, as well as in accordance with the other regulations with which, of its own volition, the EUROMED Group decides to govern its corporate activity.

Employees may request information on the content of the Code of Ethics from the head of the Human Resources Department or the Compliance Officer. This request will be treated confidentially.

2.- ETHICAL PRINCIPLES

The ethical principles that should govern the actions of the Organisation’s employees are as follows:

  • Compliance with the Law, the DERMAPHARM Group Compliance Manual and the DERMAPHARM Group Principles of Conduct, and the EUROMED Group Code of Ethics.
  • Respect for human rights and civil liberties.
  • Commitment to the principle of equal opportunities and to combating harassment.
  • Measures to reconcile work, personal and family life.
  • Loyalty to the interests of the Organisation. To avoid conflicts of interest.
  • Proper use and protection of the organisation’s resources.
  • Respect for privacy: Confidential and secure processing of personal data.
  • Protection of confidential information and knowledge.
  • To guarantee that the Product is of the highest quality.
  • Respectful and transparent relations with public administrations and third parties.
  • Respect for competition.

All these ethical principles are set out in a series of protocols, which form part of the EUROMED Group’s Crime Prevention Model (CPM) or Legal Compliance System:

  • Code of Ethics
  • Regulations for users of information systems
  • Protocol on workers’ rights and duties
  • Crime Prevention Manual
  • Protocol on the Use of Information and Communication Technology Resources
  • Protocol for the prevention of fraudulent and unfair behaviour
  • Protocol on the prevention of money laundering and terrorist financing
  • Environmental risk management policy
  • Prevention of offences against public health
  • Anti-corruption protocol
  • Protocol on the flow of persons and goods
  • Protocol for the prevention of offences against the public treasury and social security
  • Protocol on selection and recruitment
  • Protocol on equality and prohibition of discriminatory treatment
  • Protocol for preventing and dealing with sexual harassment, gender-based harassment and bullying

The content of the ethical principles discussed below is set out in detail.

COMPLIANCE WITH THE LAW, THE DERMAPHARM GROUP COMPLIANCE MANUAL AND THE DERMAPHARM GROUP PRINCIPLES OF CONDUCT AND THE EUROMED GROUP CODE OF ETHICS

Employees make a firm commitment to familiarise themselves with and comply with all national and international laws that apply to their professional activities, as well as the applicable collective agreement and other concordant rules in accordance with the system of sources in Article 3 of the Workers’ Statute. It is the responsibility of employees to comply with the rules that regulate their professional activity and to behave in a manner that respects local regulations and this Code of Ethics, as established in article 5 of the Workers’ Statute in accordance with the rules of good faith and diligence that must govern all employment relationships.

Employees must also take into account and fulfil contractual obligations agreed with third parties.

Employees undertake to avoid any conduct that may be harmful or potentially harmful to the DERMAPHARM Group and/or the EUROMED Group and that may compromise its interests, reputation or image.

The Organisation shall ensure, in implementing the power to direct the work activity regulated in Article 20 of the Workers’ Statute, that this task of updating knowledge is effective and shall control, by the means it deems appropriate, the knowledge of this Code of Ethics on the part of the workers, ensuring that at all times employees have in their possession an updated version of this Code.

RESPECT FOR HUMAN RIGHTS AND CIVIL LIBERTIES

EUROMED Group employees undertake to respect and ensure respect for the human rights and public freedoms set out in the Universal Declaration of Human Rights proclaimed by the United Nations, in the Convention for the Protection of Human Rights and Fundamental Freedoms and in the New York Covenants of 1966 (International Covenant on Civil and Political Rights and International Covenant).

COMMITMENT TO THE PRINCIPLE OF EQUAL OPPORTUNITIES AND TO COMBATTING HARASSMENT

Employees shall treat each other with respect and encourage teamwork to make the best use of each other’s qualities and know-how in the most beneficial way for the organisation.

Workers shall reject any conduct that may amount to discrimination of any kind or that could be considered an abuse or offence. Likewise, employees and the Organisation will not tolerate any aggressive behaviour or conduct that could lead to moral or sexual harassment.

The Organisation has a Protocol for preventing and dealing with sexual harassment, gender-based harassment and bullying and the Equality Plan, whose objective is to achieve effective equality between women and men, avoid any discriminatory conduct within the Organisation and promote an effective attitude against harassment.

Employees have a duty to report any behaviour that could constitute harassment to the Organisation, through the Internal Reporting System (“Ethics Channel”).

MEASURES TO RECONCILE WORK, PERSONAL AND FAMILY LIFE

The well-being of employees is an essential factor for the success of the organisation. Therefore, after assessing the needs of all employees, the Organisation has taken a number of measures to ensure satisfaction with their work and personal situation. These measures and those that may be approved in future, in accordance with perceived needs, are set out in the EUROMED Group Corporate Manual.

LOYALTY TO THE INTERESTS OF THE ORGANISATION. AVOIDING CONFLICTS OF INTEREST

In the exercise of their activities, employees shall ensure that the interests of the Organisation are respected and that they act loyally.

Employees shall avoid all situations that may lead to a conflict of interest between their personal interests (or those of any member of their family) and those of the Organisation.

In the event of a conflict situation, the employee shall inform the Audit, Ethics and Control Committee, the Compliance Officer or their manager, undertaking to reach a solution satisfactory to both parties.

PROPER USE AND PROTECTION OF THE ORGANISATION’S RESOURCES

Employees undertake to make professional use of the assets that the Organisation places at their disposal for the development of their activity.

The EUROMED Group understands that, in a reasonable and moderate manner, private use of these resources may be made, provided employees understand that these resources are not personal and may be checked.

Employees shall be responsible for the protection of assets and shall safeguard them with due diligence.

RESPECT FOR PRIVACY: CONFIDENTIAL AND SECURE PROCESSING OF PERSONAL DATA

Employees shall comply with all applicable rules on the protection of personal data and shall refrain from making any use of personal data to which they may have access for purposes other than the performance of their duties.

PROTECTION OF CONFIDENTIAL INFORMATION AND KNOWLEDGE

Employees have the duty to use and protect information and/or documents belonging to the EUROMED Group in a confidential manner, in accordance with the Protocol on the use of ICT resources and the Regulations for users of information systems.

Employees shall not use confidential data of third parties unless authorised in writing (via CDA/NDA).

Employees shall not use information obtained during their employment for personal benefit.

Information shall not be provided to third parties unless required by law, authorised, or necessary for organisational rules.

No copies or external storage are allowed without written authorisation.

The duty of confidentiality survives termination and requires the return of all materials.

GUARANTEEING THE HIGHEST PRODUCT QUALITY

Products must meet customers’ expectations and comply with applicable legislation. Interaction with customers, regulators and authorities must always be proactive and transparent.

RESPECTFUL AND TRANSPARENT RELATIONS WITH PUBLIC ADMINISTRATIONS AND THIRD PARTIES

Supplier selection shall be objective and impartial, applying criteria such as quality, service, competitiveness and financial soundness.

The Organisation shall ensure that business partners comply with anti–money laundering and anti–terrorist financing regulations.

All dealings must be proper and transparent. Conduct related to fraud, influence peddling or corruption is strictly prohibited.

Employees may not offer, grant, solicit or accept unjustified benefits. Gifts may only be accepted if:

  • of immaterial economic value,
  • customary commercial practice,
  • not prohibited by law.

Employees may not accept hospitality that could influence decisions.

RESPECT FOR COMPETITION

The EUROMED Group undertakes to compete fairly and comply with competition and anti-trust law.

Employees shall not unfairly criticise competitors or disclose sensitive internal information.

Advertising must comply with pharmaceutical regulations.

3.- THE CRIME PREVENTION MODEL (CPM)

LEADERSHIP

The CPM requires leadership by the Management Bodies, who define responsibilities and allocate resources to ensure its implementation.

They oversee the performance of the Audit, Ethics and Control Committee, who manage CPM monitoring and periodic review.

Managers support CPM implementation within their areas and ensure employee adherence.

COMPLIANCE BODY

The Audit, Ethics and Control Committee is the Compliance Body, with autonomous control powers. Its function is to ensure legality, prevent breaches—especially criminal ones—and enforce the Code of Ethics.

The Committee is independent from the Management Bodies.

A Compliance Officer supervises daily CPM compliance, manages the Ethics Channel and advises employees.

NON-COMPLIANCE AND VIOLATIONS

Violations harm the organisation and third parties. Non-observance may lead to sanctions, including dismissal, applied proportionally and respecting labour law.

4.- ETHICAL CHANNEL

The Ethics Channel allows any person with an employment or professional relationship to report infringements.

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

Reports may be anonymous and made in writing or by voice message. A face-to-face meeting may be requested.

The Audit, Ethics and Control Committee and the Compliance Officer have access to communications.

Reports may also be submitted via official external channels. The organisation ensures anonymity, absence of reprisals and confidentiality.

CONCEPT OF INFRINGEMENT

Reportable violations under Law 2/2023 include:

  • Breaches of EU law.
  • Serious or very serious criminal or administrative offences.

Other reportable issues (not under protection of Law 2/2023):

  • Breaches of internal regulations or Codes.
  • Risks to EUROMED Group’s reputation.

False or unlawfully obtained information may lead to disciplinary action.

5.- COMMUNICATION AND ACCEPTANCE

The Code of Ethics is provided to all new employees and distributed upon updates. All employees must comply with it.

Modifications or updates will be communicated promptly.