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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PUBLIC POLICY AND POLITICAL ACTIVITIES

ANY PUBLIC POLICY OR POLITICAL ACTIVITY UNDERTAKEN ON BEHALF OF ASTRAZENECA MUST BE LAWFUL, ETHICAL AND APPROVED UNDER ESTABLISHED COMPANY PROCEDURES.

PUBLIC POLICY ACTIVITIES

Employees and others who, on AstraZeneca's behalf, engage in dialogue with governments and other public bodies to inform or influence public policy must ensure that all communications are based on facts and evidence and are not misleading or open to misinterpretation. People engaged in these activities must always make it clear that they represent AstraZeneca.

All interactions with government officials and other third parties must also be in accordance with page 8 of this Code (Preventing Bribery and Corruption).

POLITICAL CONTRIBUTIONS

We must not use, or consent to the use of, any of our corporate funds, resources or facilities to support a governmental entity, political organisation, party or candidate, except where permitted by law and where acceptable as part of local custom and practice with respect to government/industry engagement. This includes support for policy advocacy organisations, such as certain patient groups.

QUICK REFERENCE
>	Do not engage in any public policy or political activity on behalf of AstraZeneca unless you are authorised to do so.
>	Do not use Company resources or facilities to carry out, support or further any personal political activities.
>	Do not act, or appear to act, as a representative of AstraZeneca when engaging in personal political activities.

No political contribution should be made which, by its scale or affiliation, might be seen as excessive or inappropriate.

All political contributions made by the Company must comply with policies approved by the Corporate Head Office, London, United Kingdom and be reported through the Finance function as part of the annual consolidation of results.

Our standards reflect AstraZeneca's commitment to acting lawfully and with integrity in this highly regulated area. They are not intended to discourage you from making any personal donations with personal funds in situations in which your role as an AstraZeneca employee is not implicated or compromised.

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