ASTRA-Az Coc English

8/6/2019 ASTRA-Az Coc English

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code of

conduct

patIent safety and benefIt research and development ethIcs provIdIng InformatIon

about our products InteractIons wIth healthcare professIonals and organIsatIons

preventIng brIbery and corruptIon employment prIncIplessafety, healthand the envIronment

publIc polIcy and polItIcal actIvItIes communIty support, product donatIons and

patIent group support protectIng personal InformatIon avoIdIng conflIcts of Interest

protectIng company property and resources communIcatIons, dIsclosures and records

InsIder tradIng and confIdentIal InformatIoncompetItIon and antI-trust lawstrade controls


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astraZeneca requIres all members of the astraZeneca groupand theIr dIrectors, offIcers and employees to observe hIghstandards of IntegrIty and honesty, and to act wIth care,dIlIgence and faIrness In all our busIness actIvItIes. all ourInteractIons wIth stakeholders and wIder socIety should beconducted In an ethIcal and proper manner.

to that end, all of us must comply wIth thIs code and allsupportIng polIcIes, the laws and regulatIons of allcountrIes In whIch we operate, and wIth all applIcablenatIonal and InternatIonal codes.

IntroductIon 1

who Is the code for and what does It mean In practIce? 2

how to ask a questIon or raIse a concern 3

patIent safety and benefIt 4

research and development ethIcs 5

provIdIng InformatIon about our products 6

InteractIons wIth healthcare professIonals and organIsatIons 7

preventIng brIbery and corruptIon 8employment prIncIples 9

safety, health and the envIronment 10

publIc polIcy and polItIcal actIvItIes 11

communIty support, product donatIons and patIent group support 12

protectIng personal InformatIon 13

avoIdIng conflIcts of Interest 14

protectIng company property and resources 15

communIcatIons, dIsclosures and records 16

InsIder tradIng and confIdentIal InformatIon 17

competItIon and antI-trust laws 18trade controls 19

telephone numbers for askIng a questIon or raIsIng a concern 20

defInItIons 21

contents


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IntroductIon

Our business is ocused on making the most

meaningul dierence to patient health

through great medicines.

What we do is important, but how we do it is

just as important. As we drive our business

orward, we must not lose sight o ourundamental commitment to doing business

the right way. I expect people at all levels

always to do the right thing, not just the easy

thing and to be motivated, empowered and

supported in doing so.

Only by living up to our core values, wherever

AstraZeneca has a presence or an impact,

can we maintain the trust o our stakeholders

and wider society that is so vital to ourreputation and licence to do business.

The AstraZeneca Code o Conduct is our

guide to understanding how our high-level

values are to be translated into consistent

actions worldwide. It provides guidance about

what is expected o each o us, as we work to

achieve our business goals. I expect you to

study it closely and to live by its principles inyour day-to-day business activities.

We are all responsible or making sure that

nothing, including the need to meet targets,

direct orders rom a more senior employee,

or pressure rom colleagues, ever

compromises our commitment to honesty

and integrity.

Compliance with this Code and all

supporting policies is mandatory. Together,

they provide the ramework or the application

o consistent standards o responsible

behaviour that will ensure that AstraZeneca

continues to be an organisation that is

valued and respected by society, and or

which we are all proud to work.

davId r brennan

chIef executIve offIcer

I want astraZeneca not only to be valued as a source ofgreat medIcInes, but also to be trusted for the way In whIchwe do busIness worldwIde.

> IntegrIty and hIgh ethIcal standards

> respect for the IndIvIdual and dIversIty> openness, honesty, trust and support for each other> leadershIp by example at all levels

astraZeneca core values

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who Is the code for and what does It meanIn practIce?

Our business activities touch many

peoples lives, including patients, physicians,

shareholders, employees, regulators,

partners, those who pay or healthcare and

the communities around us. Maintaining the

trust and condence o these groups means

ensuring that our high level values aretranslated into consistent and appropriate

behaviour worldwide.

Everyone is required to be aware o, and

conduct their activities in accordance with this

Code, all supporting policies and applicable

codes, and the laws and regulations o the

countries in which we work and do business.

We must operate to the highest o the

standards required by these variousauthorities, and always have due regard to

national legislative requirements, as a

minimum, and to circumstances where the

laws o more than one country may apply.

Managers are responsible or providing

appropriate support to enable their teams to

understand the requirements o this Code and

the relevant supporting policies and how theyshould be applied in practice. Managers are

also responsible or providing assurance

on these matters to the Board o Directors

o AstraZeneca.

The ollowing sections o this Code outline

AstraZenecas core commitments what

they mean and how they should be actively

implemented at all levels within the Company.

You must also be prepared to exercise good

judgement and common sense in decidingthe right actions to take, because this Code

and our supporting policies cannot cover

every situation that may arise. You should ask

questions i you are unclear about any aspect

o this Code, or i you are not sure how to

respond to an issue that the Code does

not address.

You must also promptly report any known,

suspected or observed violations o laws,regulations, this Code or supporting policies

o which you become aware.

any faIlure to comply wIth thIs code

or Its supportIng polIcIes wIll be fully

InvestIgated and approprIate actIon

taken. thIs may Include re-traInIng,

dIscIplIne, or other correctIve actIon,

up to and IncludIng termInatIon ofemployment, dependIng on the

cIrcumstances.

AstraZeneca is committed to working only withcontractors, such as suppliers, joint venture orco-promotion partners, and research or licensing

partners, who embrace standards o ethicalbehaviour that are consistent with our own.

thIs code applIes to all full- and part-tIme astraZenecagroup dIrectors, offIcers, employees and other temporarystaff worldwIde.

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anyone who raIses a concern about a possIble complIancebreach In good faIth wIll be supported by management, and wIllnot be subject to retalIatIon. any act or threat of retalIatIonwIll In Itself be consIdered a serIous vIolatIon of thIs code.

how to ask a questIon or raIse a concern

You may at some time come across a situation that appears to violate an AstraZeneca policy.

Everyone has a duty to report any suspected violation promptly.

In general, you should rst seek to address your concerns with your manager. I you believe

this is not appropriate, you may also contact your Human Resources, Legal Department or

Compliance representative. I you preer to contact someone outside your area, you may use

any o the ollowing contacts:

aZethIcs lIneSee page 20 or the telephone number to call in your country

(MedImmune and Aptium Oncology employees should also reer to page 20 or inormation

on reporting within their organisations)

websIteAZethics.com

emaIl [email protected]

postal addressGlobal Compliance Ocer, AstraZeneca PLC, 15 Stanhope Gate,

London W1K 1LN, United Kingdom

I the concern relates to accounting, internal accounting controls or auditing matters, you may

contact the AZethics line, the Global Compliance Ocer or the VP, Group Internal Audit.

You can provide inormation anonymously i you preer, and i your local laws so permit. In all

instances, every eort will be made to ensure that inormation relating to a reported violation

is kept condential and communicated on a need-to-know basis only.

Group Internal Audit, which reports to the Board o Directors, works closely with the Global

Compliance Ocer to ensure that condentiality and impartiality are maintained in the

overall process.

The above procedures can also be ollowed i you have a question, or are seeking clarication

about any aspect o this Code and its supporting policies.

The AZethics line and AZethics.com are managed by a third party on AstraZenecas behal.

When you ask a question or raise a concern, you will be asked to provide details and whether

you wish to disclose your contact inormation. AstraZeneca UK Limited may record thisinormation in a database (hosted on its behal by EthicsPoint in the US) and may contact

you or urther inormation. You have a right o subject access to the personal inormation

AstraZeneca processes about you.

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patIent safety and benefIt

astraZeneca Is commItted to mInImIsIng the rIsksand maxImIsIng the benefIts of each of ourmedIcInes throughout theIr lIfe-cycle.

Saety and ecacy are core considerations

throughout discovery, development and

beyond.

We work with regulators to develop

prescribing inormation or our medicines that

provides healthcare proessionals and otherswith the benet/risk inormation they need to

make prescribing decisions.

Ater launch, we continue to monitor all our

medicines or side eects, including those

that may not have been identied during the

research and development process. We notiy

the appropriate authorities about side eects

o which we become aware and co-operate

with them in taking any necessary action.

Every stage o the research, development,

manuacture, storage and distribution o

our products (and any active pharmaceutical

ingredients) must be conducted in

accordance with all applicable internal and

external standards.

The Company also works to combat thegrowing problem o countereit drugs, which

can adversely aect the health and wellbeing

o millions o people worldwide.

quIck reference

Comply with all applicable proceduresdesigned to promote product saety, ecacyand quality, such as Good Laboratory, GoodClinical and Good Manuacturing Practice.

Report any incidents o non-compliance.

Report any possible adverse eects relatingto our medicines through the establishedprocedures.

Report any countereit or suspectedcountereit drugs through the establishedprocedures.

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Our undamental responsibility is to delivereective medicines that are as sae as they canbe or those who take them. All medicines have

possible side eects. The benets o a medicinethereore have to be weighed against its risks.

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In our search for new medIcInes for Important areas ofhealthcare, astraZeneca Is commItted to InnovatIve, hIgh-qualIty scIence, conducted to hIgh ethIcal standards Inall areas of research and development worldwIde.

research and development ethIcs

Compliance with relevant laws and

regulations governing research and

development is a minimum baseline and

underpins AstraZenecas own standards.

These include ensuring that those taking

part in clinical research anywhere in the worldare not exposed to unnecessary risks, that

they understand the nature and purpose o

the research, that proper procedures or

gaining inormed consent are ollowed

and that appropriate condentiality rules

are applied.

All inormation rom clinical research must

be recorded, handled and stored in a way

that complies with applicable data protectionlaws, and enables accurate and transparent

reporting, interpretation and verication.

All research proposals must be ethically

and scientically reviewed in line with current

laws and regulations, and all relevant internal

review and approval procedures must

be ollowed.

All research involving animals must be

careully considered and justied, and the

principles o the 3Rs (replacement, reduction

and renement o animal studies) applied.

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Comply with international standardso good practice, such as the Declarationo Helsinki, Good Clinical Practice andGood Laboratory Practice.

Ensure that appropriate inormed consentprocedures are ollowed when conductingclinical research or obtaining human tissueor use in scientic studies.

Ensure that the provisions o this Coderelating to the protection o personal data(see page 13) are applied when collectingor accessing any health inormation.

Use laboratory animals only when alternatives

are not available.

Ensure that the welare o the animals we useis a top priority and that our standards areapplied consistently worldwide.

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Our commitment to high ethical standards oresearch and development applies not only toour R&D unctions (globally and in our marketing

companies), but also to supporting unctionssuch as purchasing, business development

and legal.

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Product inormation includes any inormation,material or activity, promotional or non-promotional, designed to inorm healthcare

proessionals and organisations, patients,investors, the media and others about the

characteristics and use o our products.

provIdIng InformatIon about our products

astraZeneca Is commItted to hIgh ethIcal standards whenprovIdIng InformatIon about our medIcInes and other products.

AstraZeneca uses a wide variety o

communications channels, ranging rom

contact through sales representatives to

the internet. Whatever the method used, we

must communicate inormation accurately,

eectively and in a proper manner.

The inormation we provide to support the

sae use o our products, whether through

publications and promotional materials or

in response to enquiries received, must

be supported by scientic evidence and

approved through the Companys established

review and approval procedures. We must

only promote licensed products and only or

their approved uses.

Our sales and marketing practices worldwide

must meet or exceed the minimum standards

set by applicable laws, regulations and codes.

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Only provide inormation about our productsi you are authorised to do so. This includescommunications about our products on theinternet or in other electronic media.

Promote our products in an ethical, air andbalanced way.

Use only promotional materials and otherproduct inormation that have been approvedthrough our internal review procedures.

Publish inormation about our products in linewith Company standards and procedures.

Comply with the IFPMA Code o

Pharmaceutical Marketing Practices, locallaws, regulations and applicable codes omarketing practice and our own, oten morestrict, local codes.

Do not engage in direct to consumer/direct topatient communications unless permitted bylocal laws.

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quIck reference

Comply with the IFPMA Code oPharmaceutical Marketing Practices, locallaws, regulations and applicable codes omarketing practice and our own, oten more

strict, local codes.

Only make payments to healthcareproessionals and organisations when thereis a written contract in place.

Do not oer payments, gi ts, hospitality,entertainment or anything else o value i itcould constitute a bribe to a healthcareproessional or organisation.

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InteractIons wIth healthcare professIonalsand organIsatIons*

In all our InteractIons wIth healthcare professIonalsand organIsatIons, we must observe hIgh standards ofIntegrIty and honesty.

All our interactions with healthcare

proessionals and organisations must be

intended to ensure the eective use o our

medicines and to enhance patient care. This

can include advancing medical research,

enhancing medical knowledge or practice

management, or gathering necessaryeedback about our medicines.

We must only engage the services o

healthcare proessionals and organisations

when they are legitimately needed, and we

must not pay more than an appropriate

market rate or the services rendered.

We must not enter into business relationships

or oer or provide gits, hospitality or anythingelse o value, to induce or reward avourable

decisions about our products and services.

We must always provide inormation about

our products to healthcare proessionals and

organisations in accordance with the relevant

provisions o this Code and supporting policies.

Interactions with healthcare proessionalsand organisations include all meetings,communications, research and service

arrangements, including product promotion,speaking engagements, advisory board

meetings, consulting agreements, conerences,congresses and symposia.

*For a denition o healthcare proessionals and organisations, see page 21.

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quIck reference

Never make or authorise payments or gits inorder to obtain or retain business or to securean improper advantage. Never ask or permitthird parties to do so on your behal.

It is acceptable to engage the services ohealthcare proessionals and organisations,and provide modest and customary mealsand gits, as long as they comply with anylocal laws and applicable codes and oursupporting policies (including page 7o this Code).

Make sure all gits, activities and conductare o a nature that would not be open to

misinterpretation i publicly disclosed.

Pay particular attention to relationshipswith third parties; visits to our acilities;sponsoring people to attend events ormeetings; consulting arrangements;post-marketing studies; gits and hospitality,and acilitating payments.

Report any suspicion o potentiallycorrupt behaviour.

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preventIng brIbery and corruptIon

astraZeneca dIrectors, offIcers and employees,and others who act on astraZenecas behalf,must not offer, pay or accept brIbes.

We must not oer or give money or anything

else o value either as an inducement to

make, or as a reward or making, any decision

avourable to the interests o AstraZeneca.

This includes providing such benets to

government ocials (including those romnational and local governments and those

serving in public international organisations)

and other healthcare proessionals and

organisations, patients, suppliers, charities

and patient groups, whether companies

or individuals.

AstraZeneca also does not permit agents,

contractors, advisors or other third parties

working on our behal to engage in this typeo conduct.

As well as not oering bribes, we must

also not accept them. See Avoiding Conficts

o Interest on page 14 or more inormation.

Oering or making payments to government ocials to obtain avourabletreatment, to secure business, or to obtain an improper advantage is a crimein every country in which we do business, whether such payments are in

cash or in kind. It is also a crime in many countries to make these types opayments to government ocials o another country, and also a crime in

most jurisdictions to pay commercial bribes to persons who are notgovernment ocials.

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quIck reference

Encourage diversity and creative potential,recruit and promote on the basis o meritand support the continuous developmento peoples skills and abilities.

Behave towards others with integrity, honesty,courtesy, consideration, respect and dignity.

Contribute to maintaining a workingenvironment in which any orm o harassmentis unacceptable.

Report any inappropriate conduct directedtowards you or others.

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employment prIncIples

astraZeneca Is commItted to promotIng and maIntaInIng aculture of respect and equal opportunIty, In whIch IndIvIdualsuccess depends solely on personal abIlIty and contrIbutIon.

AstraZeneca values highly the diversity o

skills and abilities that a global workorce

brings to our business. We are committed

to supporting diversity in our workorce and

in our leadership and to developing all the

talent within our organisation.

All decisions about recruitment, hiring,

compensation, development and promotion

must be made solely on the basis o a

persons ability, experience, behaviour,

work perormance and demonstrated

potential in relation to the needs o the job.

The harassment o any AstraZeneca

employee or anyone with whom we do

business, is unacceptable.

Any person who believes that they or others

have been subject to unlawul discrimination

or harassment should report the incident and

circumstances to their manager, a Human

Resources manager or other senior manager,

who will arrange or the incident to be

investigated appropriately and impartially.

AstraZeneca supports the principles set out in the UN Declaration o HumanRights, and our policies detail our high standards o employment practice.

These include respecting diversity and, as a minimum, complying with

national legal requirements regarding wages and working hours. We alsosupport the International Labour Organisations standards regarding child

labour and minimum age.

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quIck reference

Take personal responsibility or saety andhealth and or understanding how your workmay aect the environment.

Understand the hazards associated with yourwork, manage the risks responsibly and onlyundertake work or which necessary saetyand health training has been provided.

Seek to continually improve and reduce theenvironmental impact o your activities (egavoid unnecessary business trips).

Actively participate in energy-saving andwaste reduction programmes.

Promptly report accidents, incidents o non-compliance, or any other matter posing athreat to saety, health or the environment.

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safety, health and the envIronment

astraZeneca Is commItted to carryIng out our busIness In anenvIronmentally responsIble manner, and to promotIng a safeand healthy workplace for all our people worldwIde.

We manage our environmental impact and

seek to continuously improve the sustainability

o our activities by, among other things,

economising on our use o non-renewable

energy and raw materials; minimising the

amount o waste we generate, and minimising

any adverse environmental eects associatedwith our products.

The Company also works to identiy, mitigate

and monitor existing and emerging risks to

the environment associated with our business

activities, as well as to the health and saety

o our employees and others who visit or work

on our premises, and to the communities in

which we operate.

We go beyond legal minimums to proactively

reduce the potential or exposure to chemical,

biological, physical and other hazards in the

workplace; reduce the risk o other accidents

in our research and manuacturing acilities;

promote sae driving, and help our sta to

manage their health and wellbeing.

We also aim to promptly and eectivelyrespond to, investigate and share learning

rom incidents that resulted in, or had the

potential to result in, serious illness or injury

Saety and health include the prevention oillness and injury and the promotion o wellbeingin the workplace. Saety and health laws and

regulations exist to saeguard the workingconditions o employees, and o visitors to

business premises.

or environmental harm, and to take any

appropriate corrective action promptly.

Everyone is expected to integrate saety, health

and environmental considerations into their

day-to-day work activities. Line managers alsohave a duty to provide their teams with a sae

and secure business environment, including

building awareness o potential security risks

and how they should be managed.

We are committed to minimising any adverseenvironmental eects rom our activitiesand products, while working to reduce our

consumption o natural resources andotherwise operating in an environmentally

sustainable manner.

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quIck reference

Do not engage in any public policy or politicalactivity on behal o AstraZeneca unless youare authorised to do so.

Do not use Company resources or acilitiesto carry out, support or urther any personalpolitical activities.

Do not act, or appear to act, as a representativeo AstraZeneca when engaging in personalpolitical activities.

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publIc polIcy and polItIcal actIvItIes

any publIc polIcy or polItIcal actIvIty undertakenon behalf of astraZeneca must be lawful, ethIcal andapproved under establIshed company procedures.

publIc polIcy actIvItIes

Employees and others who, on AstraZenecas

behal, engage in dialogue with governments

and other public bodies to inorm or infuence

public policy must ensure that all

communications are based on acts and

evidence and are not misleading or open tomisinterpretation. People engaged in these

activities must always make it clear that they

represent AstraZeneca.

All interactions with government ocials and

other third parties must also be in accordance

with page 8 o this Code (Preventing Bribery

and Corruption).

polItIcal contrIbutIonsWe must not use, or consent to the use o,

any o our corporate unds, resources or

acilities to support a governmental entity,

political organisation, party or candidate,

except where permitted by law and where

acceptable as part o local custom and

practice with respect to government/industry

engagement. This includes support or policy

advocacy organisations, such as certainpatient groups.

No political contribution should be made

which, by its scale or aliation, might be seen

as excessive or inappropriate.

All political contributions made by the Company

must comply with policies approved by

the Corporate Head Oce, London,

United Kingdom and be reported through

the Finance unction as part o the annual

consolidation o results.

Our standards refect AstraZenecas commitment to acting lawully andwith integrity in this highly regulated area. They are not intended todiscourage you rom making any personal donations with personal unds

in situations in which your role as an AstraZeneca employee is not implicatedor compromised.

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quIck reference

Provide support to your community inaccordance with relevant guidelines.

Use the proper approval and management

procedures or the donation o medicines.

Ensure that any relationship with a patientgroup is transparent and based on trustand a shared objective to improve patienthealthcare.

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communIty support, product donatIons andpatIent group supportour focus Is on actIvItIes that brIng benefIt In ways that areconsIstent wIth our busIness of ImprovIng health and qualItyof lIfe, and promotIng the value of scIence.

AstraZeneca is committed to making a

positive contribution to our local communities

through charitable contributions, sponsorships

and other initiatives.

AstraZeneca also responds to humanitarian

appeals with nancial and/or productdonations, where there is a demonstrated

public health need. We conorm to the WHO

Guidelines or drug donations and only donate

our medicines through reputable, non-

governmental organisations or well dened

government programmes, where we are

condent that the medicines will reach

their intended recipients and will be

used appropriately.

AstraZeneca supports the work o patient

groups, through the provision o nancial

and in-kind assistance that seeks to enhance

patient welare. Our relationships with patient

groups must always comply with relevant

legal and regulatory requirements, as well

as applicable codes and our own

supporting policies.

AstraZeneca encourages employees toparticipate in local community initiatives, butany potential conficts o interest must be avoided

(see page 14).

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protectIng personal InformatIon

astraZeneca Is commItted to protectIng any personalInformatIon collected or held durIng the course ofour busIness actIvItIes, by ensurIng hIgh standardsof data protectIon worldwIde.

We must collect, use and retain only as much

personal inormation as we need or legitimate

business, human resources or scientic

purposes, or to satisy any legal requirements.

Where required by law, we must also obtain

appropriate consent to such collection and

use, and inorm individuals about thepurposes or which their personal inormation

may be used.

Once its purpose has been ullled, personal

inormation must be destroyed in accordance

with our legal obligations and Company

document retention policies.

We must only share personal inormation

with aliates and third parties i they have alegitimate need to know it, and only i we are

reasonably assured that they will suitably

saeguard the inormation once it is in their

hands, or i required by law.

We must give special consideration to any

additional applicable requirements beore

sensitive personal inormation is collected

or used, or where inormation is transerredor processed outside its country o origin,

because it may become subject to dierent

laws with dierent or competing requirements.

Data protection laws regulate the collection,storage, use and disclosure o personalinormation about individuals. This can include

inormation about employees, customers,patients, clinical study subjects and employees

o third parties.

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Comply with all data protection andassociated laws applicable to thecountries in which we gather and holdpersonal inormation.

I you are in doubt as to the proposed use opersonal inormation, you should seek urtheradvice and approval rom a data privacyspecialist beore collecting, accessing orusing such inormation.

Obtain approval rom a data privacy specialistbeore transerring personal inormationoutside its country o origin, or giving othermarkets electronic access to it.

Do not record things about people that youwould be embarrassed to say to them directly.

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avoIdIng conflIcts of Interest

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Avoid situations where your loyalty maybecome divided.

Do not enter into situations in which your

personal or amily interests may confict withthose o AstraZeneca.

Declare any potential conficts o interestand seek advice rom your line manager.

Report any business dealings betweenAstraZeneca and companies or organisationsin which you have, or a amily member or anindividual you treat as a amily member has,a management role or nancial interest

(excluding interests o 1% or less in publicly

listed companies).

Do not use your position at AstraZenecaor personal benet or to benet a amilymember, riend or associate.

Do not pay a third party more than acontractually agreed, market-based priceor ee or goods or services provided.

Do not accept gits, hospitality or otherentertainment o a nature that would be open

to misinterpretation i publicly disclosed.

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A confict o interest is created when an activity,interest (nancial or personal) or association oan employee directly or indirectly compromises

his or her independence or judgement, causingthe interests o the employee or another person

to infuence a business decision inappropriately.

we must not allow personal or famIly Interests to Influenceour professIonal judgement.

We must never accept anything o value, i

it would constitute either an inducement to

make, or a reward or making, any decision

avourable to the interests o a third party.

We must not accept gits or hospitality that

may compromise our independence orjudgement regarding a third party. This

includes hospitality or entertainment with a

value that exceeds locally established limits,

that is not customary or that is otherwise likely

to be seen as inappropriate.

Whilst we are ree to make personal

nancial investments and to maintain social

relationships with people we meet through

business activities, our business relationshipsmust not create any interests that may

confict, or have the potential to confict,

with those o AstraZeneca.

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quIck reference

Act appropriately and responsibly with regardto AstraZenecas property and resources.

Exercise due care when spending the

Companys money and making nancialcommitments on its behal.

Report promptly any potential improperaction against AstraZenecas propertyand resources, so that appropriate actioncan be taken.

Only use AstraZeneca property andresources or non-work related activitiesto the extent permitted under applicable


Involve the Legal Department in anycontractual matter that relates to a materialright, obligation or liability.

Subject to your local law, you should not haveany expectations o privacy when using theCompanys electronic systems or non-workrelated activities.

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protectIng company property and resources

astraZenecas property and resources must be used only forthe proper advancement of our busIness and not for personalgaIn, nor for any fraudulent purpose.

Our duty to our shareholders includes

making the best use o the Companys

property, money and other resources.

As part o our strategic commitment to driving

operational excellence, we must ensure that

our property, resources and inormationsystems are protected and kept secure at

all times rom unauthorised use, damage,

disclosure, diversion or removal, whether

through accident, improper act or breach

o trust.

As part o this, everyone has responsibility

or protecting the Companys electronic

systems, communications network and

computing resources, as well as preservingthe integrity and condentiality o Company

inormation.

Property and resources include physical assets,intangible assets and condential inormation.Physical assets are items such as materials,

supplies, equipment and cash, while intangibleassets include intellectual property, inormation

assets, brand value and employee time and talents.

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communIcatIons, dIsclosures and records

astraZeneca Is commItted to communIcatIng wIth IntegrIty,to dIsclosIng InformatIon In a tImely and approprIate mannerand to maIntaInIng accurate company books and records.

All our communications, through whatever

channel, must be air, accurate, timely and

appropriately authorised. All employees must

be mindul o situations in which they may be

perceived to be communicating on the

Companys behal.

AstraZenecas policy is to disclose inormation

in a timely manner, as necessary, to comply with

all relevant legal and regulatory requirements.

All such disclosures must be accurate and

not misleading, with no material* omissions.

This policy applies to all inormation, whether

avourable or unavourable to AstraZeneca.

We must maintain proper Company books

and records to provide an accurate picture oAstraZenecas business activities and nancial

position. We must not alsiy or inappropriately

alter Company records, and we must only

destroy records in accordance with relevant


We must not record sales articially to boost

perormance or otherwise. We must only

sell products pursuant to bona de ordersunderpinned by bona de market demand, and

we must only record such sales once the product

has been shipped and an invoice submitted.

Communications are any internal or external messages about AstraZeneca or our products, includingany that may be deemed to be made by us or on our behal. They include press releases, advertisementsand promotional materials. Disclosures are statements published or submitted by the Company to its

shareholders, regulators, securities exchanges, the media and other third parties. Records includecontracts, accounts, research and development data, batch records, and nancial and non-nancial

documents.

quIck reference

Ensure that all communications, whetherprint, web-based or verbal, comply with allappropriate internal and external standards,and have received appropriate internal

approval beore release.

Do not communicate on behal o theCompany unless you are authorised to doso. This includes communications about theCompany or our products on the internetor in other electronic media.

Promptly communicate potentially material,non-public inormation to the AstraZenecaDisclosure Committee, via the VP o

Investor Relations or the Assistant Secretary

at the Corporate Head Oce, or ajudgement on its disclosability and approvalprior to any disclosure.

Preserve records that are relevant toinvestigations or litigation involving theCompany or its employees.

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*For a denition o material, see page 21.

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quIck reference

Comply with external regulations and internalsupporting policies on insider trading and thesale or purchase o securities, includingrestrictions on trading during close periods.

Seek guidance i you are unsure whetherinormation is material* or whether otherrestrictions apply.

Do not act upon material, non-publicinormation that a reasonable investor wouldconsider important, such as a possibleacquisition, nancial results inormation orthe results o a clinical study.

Follow AstraZenecas supporting policies,

including obtaining permission rom the relevantpersons, beore disclosing condentialinormation to other employees or personsoutside the Company.

Ensure that condentiality agreements are inplace with third parties with whom we sharecondential inormation.

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Insider trading generally reers to buying, sellingor exercising an option over a security (orexample, stocks, shares and ADRs) while in

possession o material, non-public inormationabout the security.

InsIder tradIng and confIdentIal InformatIon

all offIcers and employees are prohIbIted from InsIder tradIngfor theIr own or others personal profIt.

We must not use any non-public inormation

about AstraZeneca or other companies

learnt through our employment to infuence

our, or anyone elses, decision to purchase

or sell securities.

This requirement applies even ater a personhas nished working or AstraZeneca.

Condential inormation should be protected

rom improper disclosure, and any authorised

communication o condential inormation

should be limited to individuals who have a

need to know.

*For a denition o material, see page 21.

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quIck reference

Never enter into agreements andunderstandings that are anti-competitive.

Consult your local Legal Department beore

having discussions or interactions withcompetitors that are, or could appear tobe anti-competitive. Participation in tradeassociations can be a legitimate activity, but isstill subject to the same rules and standards.

Avoid exchanging non-public or othersensitive inormation with customers orother third parties, i it is not necessary orlegitimate business purposes, or i it couldgive the appearance o an inappropriate

agreement or understanding.

Only gather inormation about competitorsin an appropriate and lawul manner.

Report any suspicions or allegations oactual or potential anti-competitivediscussions or activities.

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Competition and anti-trust laws promote andprotect the competitive process. These lawsprevent companies rom entering into anti-

competitive agreements with each other, or romabusing a dominant position. In many cases,

these laws can be applied to conduct that occursoutside a countrys borders.

competItIon and antI-trust laws

astraZeneca Is commItted to complyIng wIth all competItIon andantI-trust laws applIcable In the countrIes where we operate.

In our eorts to drive the success o our

business, we must only seek competitive

advantage through lawul means.

We must not act in ways that stife the

ree market, and we must not exchange

inormation or enter into agreementsor understandings with competitors,

customers, suppliers or other third parties

in a way that improperly infuences research

and development activity, manuacturing,

marketing, sales, distribution or employee

compensation practices, or involves

bid-rigging or boycotts.

I we have a dominant or monopoly position,

competition laws may impose a specialresponsibility on the Company not to abuse

that position to keep out competitors or to

exploit customers.

We must only engage in dialogue with

our competitors when there is a legitimate

business reason to do so.

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quIck reference

Consult your Legal Department to ensurethat trade controls to which we are subjecthave been ollowed, and that you haveobtained all approvals required by authorities

recognised by AstraZeneca.

Report promptly to your local LegalDepartment all actions or requests that maybe related to countries subject to boycotts.

Reuse to engage in prohibited restrictivetrade practices.

Do not do business with parties subject torecognised trade restrictions.

Comply with all relevant local laws, regulationsand AstraZeneca supporting policies inprocessing the import or export o any item.

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Trade restrictions (including sanctions or embargoes)seek to prevent or limit trading with or in speciccountries. Boycotts involve a country reusing (or

whatever reason) to do business, or prohibitingothers rom doing business with, one or more

other countries.

trade controls

astraZeneca Is commItted to tradIng In a legaland ethIcal manner.

We must comply with trade regulations

and restrictions i they have been approved

by recognised national and international

authorities, including the United Nations,

the European Union, the United Kingdom,

Sweden and the United States.

We must not comply with other boycotts

or trade restrictions.

We must obtain necessary licences or

the import and export o our products and

other items, and we must provide accurate,

truthul inormation about our products to

Customs authorities.

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telephone numbers for askIng a questIonor raIsIng a concern

aZethIcs lIne

From the UK: 0800 0328483

From Sweden: 020 798 729

From the US: 866 993 8442

For other countries, local toll-ree numbers

are listed on AZethics.com. I you cannotaccess the web, or i your country is not

listed, you can call the ollowing collect

call (reverse charge) number through your

local operator:

+ 1 503 748 0641

When you are put through to the call centre,

tell them you are rom AstraZeneca and state

which language you require.

I you have any problems connecting,

you can also call Global Compliance on:

+ 44 20 7491 2059

for medImmune employees

AlertLine is MedImmunes toll-ree,

anonymous compliance hotline or

employees to raise concerns or issues.

AlertLine toll-ree number: 877 846 8838

From the Netherlands:

Dial access code 0800 022 9111

From the UK:

Dial access code 0800 89 0011 or

0500 89 0011

An English-language voice prompt or operator

will ask you or the AlertLine toll-ree number

and connect you to an AlertLine sta person.

for aptIum oncology employees

Aptium Oncology maintains a toll-ree

hotline or reporting suspected violations

o the law, Aptium Code o Conduct,

Aptium policies and procedures, and

any other compliance or ethics issues.

Telephone: 800 846 3691

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ADRs reers to American Depositary Receipts.

Applicable codes reers to those codes thatAstraZeneca has ormally adopted, or with which it isotherwise obliged to comply.

AstraZeneca,AstraZeneca Group, the Group, theCompany, we, us and our reer to AstraZeneca PLC

and its consolidated entities, including MedImmune,KuDOS, Astra Tech, Aptium Oncology and Arrow

Therapeutics.

Confdential inormation reers to any and allcondential and/or proprietary inormation ormaterial belonging to or in the possession o anymember o the AstraZeneca Group. It may be oral,visual, in writing, in the orm o or contained inmaterials, or in any other orm. It includes anyinormation or material in any way related to

AstraZenecas (a) nancial inormation, business

plans, projections or strategies, property, businesspractices and relationships, processes, systems,methods o operation or marketing plans, (b)research, development or other investigative

activities, (c) regulatory practices, procedures orpolicies, (d) products, specications, ormulae,ingredients, pricing policies, marketing plans,product costs or promotional activities, (e) customer,supplier or employee inormation or agreements,() medical, scientic or other technical inormation,(g) corporate, strategic, commercial, licence orother agreements or (h) inventions, innovations,

improvements, know-how, trade secrets or otherproprietary inormation.

Contractor reers to any supplier or other third partywith whom or which AstraZeneca has a contract.

Healthcare proessionals and organisationsreers to any persons who or which may prescribe,administer, recommend, purchase, pay or, reimburse,authorise, approve or supply any product or servicesold or provided by AstraZeneca. It includes:

> any members o the medical, dental, pharmacyor nursing proessions, or relevant associatedadministrative sta; and/or

> hospitals and other care organisations, healthinsurers (including managed care organisations),pharmacies, and ormulary or benetadministrators, and relevant sta at such entities.

Material reers to inormation that would beconsidered infuential in making a decision to buy

or sell securities.

Person reers to any natural person (ie an individual)or legal person (eg a company).

Supplier reers to any person providing AstraZenecawith goods or services, including vendors andconsultants.

Supporting policies reers to any and all Companypolicies, codes, standards and procedures.

defInItIons

Designed by Addison Corporate Marketing Ltd.

This Code o Conduct applies to all ull- and part-time AstraZeneca Group directors, ocers

and employees worldwide. It requires compliance with all laws and regulatory requirements

and applicable codes, as well as our own high ethical standards, as outlined in this Code

and supporting policies. This includes a commitment to ull compliance with all US Federalhealthcare programme requirements, including those related to marketing, selling and

reporting prices or US government reimbursed products.

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In your everyday busIness actIvItIes,ask yourself:

> Is the decIsIon or actIon I am goIng to takeIn lIne wIth our core values and thIs codeof conduct?

> have I understood the rIsk and the possIbleImplIcatIons of what I am doIng?

> If necessary, have I sought advIce to help memake an Informed decIsIon?

> am I leadIng by example?

> have I consIdered any potentIal Impact onastraZenecas reputatIon?

> how wIll I feel If the actIon I take today Isfeatured In the newspapers or on televIsIontomorrow?

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