EthicsPoint - AstraZeneca

Introduction Who is the code for and what does it mean in practice? How to ask a question or raise a concern Patient safety and benefit Research and development ethics Providing information about our products Interactions with healthcare professionals and organisations Preventing bribery and corruption Employment Principles Safety, health and 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 information Competition and anti- trust laws Trade controls Telephone numbers for Asking a Question or Raising a Concern Definitions Download Code of Conduct PDF

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FIRST In general, you should seek to address your concerns with your manager. If you believe this is not appropriate, you may also contact your Human Resources, Legal department, or Compliance representative.

MESSAGE FROM DAVID BRENNAN

Chief Executive Officer

CODE OF CONDUCT

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PREVENTING BRIBERY AND CORRUPTION

ASTRAZENECA DIRECTORS, OFFICERS AND EMPLOYEES, AND OTHERS WHO ACT ON ASTRAZENECA'S BEHALF, MUST NOT OFFER, PAY OR ACCEPT BRIBES.

We must not offer or give money or anything else of value either as an inducement to make, or as a reward for making, any decision favourable to the interests of AstraZeneca.

This includes providing such benefits to government officials (including those from national and local governments and those serving in public international organisations) and other healthcare professionals 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 behalf to engage in this type of conduct.

As well as not offering bribes, we must also not accept them. See "Avoiding Conflicts of Interest" on page 14 for more information.

QUICK REFERENCE
>	Never make or authorise payments or gifts in order to obtain or retain business or to secure an improper advantage. Never ask or permit third parties to do so on your behalf.
>	It is acceptable to engage the services of healthcare professionals and organisations, and provide modest and customary meals and gifts, as long as they comply with any local laws and applicable codes and our supporting policies (including page 7 of this Code).
>	Make sure all gifts, activities and conduct are of a nature that would not be open to misinterpretation if publicly disclosed.
>	Pay particular attention to relationships with third parties; visits to our facilities; sponsoring people to attend events or meetings; consulting arrangements; post-marketing studies; gifts and hospitality, and facilitating payments.
>	Report any suspicion of potentially corrupt behaviour.

Offering or making payments to government officials to obtain favourable treatment, to secure business, or to obtain an improper advantage is a crime in 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 of payments to government officials of another country, and also a crime in most jurisdictions to pay commercial bribes to persons who are not government officials.

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