EthicsPoint - AstraZeneca

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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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COMMUNICATIONS, DISCLOSURES AND RECORDS

ASTRAZENECA IS COMMITTED TO COMMUNICATING WITH INTEGRITY, TO DISCLOSING INFORMATION IN A TIMELY AND APPROPRIATE MANNER AND TO MAINTAINING ACCURATE COMPANY BOOKS AND RECORDS.

All our communications, through whatever channel, must be fair, accurate, timely and appropriately authorised. All employees must be mindful of situations in which they may be perceived to be communicating on the Company's behalf.

AstraZeneca's policy is to disclose information 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 information, whether favourable or unfavourable to AstraZeneca.

We must maintain proper Company books and records to provide an accurate picture of AstraZeneca's business activities and financial position. We must not falsify or inappropriately alter Company records, and we must only destroy records in accordance with relevant supporting policies.

We must not record sales artificially to boost performance or otherwise. We must only sell products pursuant to bona fide orders underpinned by bona fide market demand, and we must only record such sales once the product has been shipped and an invoice submitted.

QUICK REFERENCE
>	Ensure that all communications, whether print, web-based or verbal, comply with all appropriate internal and external standards, and have received appropriate internal approval before release.
>	Do not communicate on behalf of the Company unless you are authorised to do so. This includes communications about the Company or our products on the internet or in other electronic media.
>	Promptly communicate potentially material, non-public information to the AstraZeneca Disclosure Committee, via the VP of Investor Relations or the Assistant Secretary at the Corporate Head Office, for a judgement on its disclosability and approval prior to any disclosure.
>	Preserve records that are relevant to investigations or litigation involving the Company or its employees.

Communications are any internal or external messages about AstraZeneca or our products, including any that may be deemed to be made by us or on our behalf. They include press releases, advertisements and promotional materials. Disclosures are statements published or submitted by the Company to its shareholders, regulators, securities exchanges, the media and other third parties. Records include contracts, accounts, research and development data, batch records, and financial and non-financial documents.

*For a definition of "material", see page 21.

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