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.

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CODE OF CONDUCT

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INSIDER TRADING AND CONFIDENTIAL INFORMATION

ALL OFFICERS AND EMPLOYEES ARE PROHIBITED FROM INSIDER TRADING FOR THEIR OWN OR OTHERS' PERSONAL PROFIT.

We must not use any non-public information about AstraZeneca or other companies learnt through our employment to influence our, or anyone else's, decision to purchase or sell securities.

This requirement applies even after a person has finished working for AstraZeneca.

Confidential information should be protected from improper disclosure, and any authorised communication of confidential information should be limited to individuals who have a "need to know".

QUICK REFERENCE
>	Comply with external regulations and internal supporting policies on insider trading and the sale or purchase of securities, including restrictions on trading during close periods.
>	Seek guidance if you are unsure whether information is material* or whether other restrictions apply.
>	Do not act upon material, non-public information that a reasonable investor would consider important, such as a possible acquisition, financial results information or the results of a clinical study.
>	Follow AstraZeneca's supporting policies, including obtaining permission from the relevant persons, before disclosing confidential information to other employees or persons outside the Company.
>	Ensure that confidentiality agreements are in place with third parties with whom we share confidential information.

Insider trading generally refers to buying, selling or exercising an option over a security (for example, stocks, shares and ADRs) while in possession of material, non-public information about the security.

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

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