Established March 1, 2020

Introduction
The Mission of the CMIC Group (“We”) is ” CMIC is an innovative and unique provider of high-quality solutions for the healthcare industry. We create value by accelerating the access to therapies that improve patients’ lives.”

In accomplishing this mission, we will comply with the fundamental principles of conduct set forth in the CMIC Group Code of Conduct and observe the following items with respect to ethics, labor, safety, health, environment and related management systems in accordance with the Pharmaceutical Industry Principles for Responsible Supply Chain Management (the “Principles”).

Ethics
We conduct our business ethically and act with integrity. The Ethics elements include:

1. ANTI-BRIBERY AND CORRUPTION
All forms of bribery, corruption*, extortion and embezzlement are prohibited. We do not pay or accept bribes or participate in other illegal inducements in business or government relationships, or through the use of intermediaries. We ensure that we have adequate systems in place to prevent bribery and comply with applicable laws.

2. FAIR COMPETITION
We conduct our business consistent with fair and vigorous competition and in compliance with all applicable anti-trust laws. We employ fair business practices including accurate and truthful advertising.

3. ANIMAL WELFARE
Animals shall be treated humanely with pain and stress minimized. Animal testing should be performed after consideration to replace animals, to reduce the numbers of animals used, or to refine procedures to minimize distress. Alternatives should be used wherever these are scientifically valid and acceptable to regulators.

4. DATA PRIVACY AND SECURITY
We safeguard and make only proper use of confidential information to ensure that company, worker, patient, subject* and donor* privacy rights are protected. We comply with applicable privacy and data protection laws and ensure the protection, security and lawful use of personal data.

5. PATIENT SAFETY AND ACCESS TO INFORMATION
We ensure that adequate management systems are in place to minimize the risk of adversely impacting on the rights of patients, subjects and donors, including their rights to health and to access information directly.

6. CONFLICTS OF INTEREST
We take reasonable care to avoid and manage conflicts of interest.

Human Rights and Labor
We are committed to uphold the human and employment rights of workers and to treat them with dignity and respect. The Labor elements include:

1. FREELY CHOSEN EMPLOYMENT
We do not use forced, bonded or indentured labor or involuntary prison labor. No worker shall pay for a job or be denied freedom of movement.

2. CHILD LABOR AND YOUNG WORKERS
We do not use child labor. The employment of young workers below the age of 18 shall only occur in non-hazardous work and when young workers are above a country’s legal age for employment or the age established for completing compulsory education.

3. NON-DISCRIMINATION
We provide a workplace free from discrimination. There shall be no discrimination for reasons such as race, color, age, pregnancy, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership or marital status.

4. FAIR TREATMENT
We provide a workplace free of harassment, harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers and no threat of any such treatment.

5. WAGES, BENEFITS AND WORKING HOURS
We pay workers according to applicable wage laws, including minimum wages, overtime hours and mandated benefits.

We communicate with the worker the basis on which they are being compensated in a timely manner. We are also expected to communicate with the worker whether overtime is required and the wages to be paid for such overtime. Overtime shall be consistent with applicable national and international standards.

6. FREEDOM OF ASSOCIATION
Open communication and direct engagement with workers to resolve workplace and compensation issues is encouraged.

We respect the rights of workers, as set forth in local laws, to associate freely, join or not join labor unions, seek representation and join workers’ councils. Workers shall be able to communicate openly with management regarding working conditions without threat of reprisal, intimidation or harassment.

Health and Safety
We provide a safe and healthy working environment, including – where applicable – for any company-provided living quarters. Health and Safety measures shall extend to contractors and subcontractors on supplier sites. The Health and Safety elements include:

1. WORKER PROTECTION
We protect workers from over exposure to chemical, biological, physical hazards and physically demanding tasks in the workplace and in any company provided living quarters. We ensure appropriate housekeeping and provide workers with access to potable water.

2. PROCESS SAFETY
We have management processes in place to identify the risks from chemical and biological processes and to prevent or respond to catastrophic release of chemical or biological agents.

3. EMERGENCY PREPAREDNESS AND RESPONSE
We identify and assess emergency situations in the workplace and any company provided living quarters, and to minimize their impact by implementing emergency plans and response procedures.

4. HAZARD INFORMATION
Safety information relating to hazardous materials – including pharmaceutical compounds and pharmaceutical intermediate materials – shall be available to educate, train, and protect workers from hazards.

Environment
We operate in an environmentally responsible and efficient manner to minimize adverse impacts on the environment. We are encouraged to conserve natural resources, to avoid the use of hazardous materials where possible and to engage in activities that reuse and recycle. The Environmental elements include:

1. ENVIRONMENTAL AUTHORIZATIONS AND REPORTING
We comply with all applicable environmental regulations. All required environmental permits, licenses, information registrations and restrictions shall be obtained, and their operational and reporting requirements followed.

2. WASTE AND EMISSIONS
We have systems in place to ensure the safe handling, movement, storage, disposal, recycling, reuse, or management of waste, air emissions and wastewater discharges. Any waste, wastewater or emissions with the potential to adversely impact human or environmental health shall be appropriately managed, controlled and treated prior to release into the environment. This includes managing releases of active pharmaceuticals into the environment (PiE).

3. SPILLS AND RELEASES
We have systems in place to prevent and mitigate accidental spills and releases to the environment and adverse impacts on the local community.

4. RESOURCE USE
We take measures to improve efficiency and reduce the consumption of resources.

5. SUSTAINABLE SOURCING AND TRACEABILITY
We carry out due diligence on the source of critical raw materials to promote legal and sustainable sourcing.

Management Systems
We use management systems to maintain business continuity, facilitate continual improvement and compliance with the expectations of these Principles. The Management System elements include:

1. COMMITMENT AND ACCOUNTABILITY
We demonstrate commitment to the concepts described in this document by allocating appropriate resources and identifying senior responsible personnel.

2. LEGAL AND CUSTOMER REQUIREMENTS
We identify and comply with applicable laws, regulations, standards and relevant customer requirements.

3. RISK MANAGEMENT
We have mechanisms to determine and manage risks in all areas addressed by these Principles.

4. DOCUMENTATION
We maintain documentation necessary to demonstrate conformance with these Principles and compliance with applicable regulations.

5. TRAINING AND COMPETENCY
We have a training program that achieves an appropriate level of knowledge, skills and abilities in management and workers to address the expectations in these Principles.

6. CONTINUAL IMPROVEMENT
We are expected to continually improve by setting performance objectives, executing implementation plans and taking necessary corrective actions for deficiencies identified by internal or external assessments, inspections, and management reviews.

7. IDENTIFICATION OF CONCERNS
All workers shall be encouraged to report concerns, illegal activities or breaches of these Principles in the workplace without threat of or actual reprisal, intimidation or harassment. We investigate and take corrective action if needed.

8. COMMUNICATION
We have effective systems to communicate these Principles to workers, contractors and suppliers.