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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COMPETITION AND ANTI-TRUST LAWS

ASTRAZENECA IS COMMITTED TO COMPLYING WITH ALL COMPETITION AND ANTI-TRUST LAWS APPLICABLE IN THE COUNTRIES WHERE WE OPERATE.

In our efforts to drive the success of our business, we must only seek competitive advantage through lawful means.

We must not act in ways that stifle the free market, and we must not exchange information or enter into agreements or understandings with competitors, customers, suppliers or other third parties in a way that improperly influences research and development activity, manufacturing, marketing, sales, distribution or employee compensation practices, or involves bid-rigging or boycotts.

If we have a dominant or monopoly position, competition laws may impose a special responsibility on the Company not to abuse that position to keep out competitors or to exploit customers.

We must only engage in dialogue with our competitors when there is a legitimate business reason to do so.

QUICK REFERENCE
>	Never enter into agreements and understandings that are anti-competitive.
>	Consult your local Legal Department before having discussions or interactions with competitors that are, or could appear to be anti-competitive. Participation in trade associations can be a legitimate activity, but is still subject to the same rules and standards.
>	Avoid exchanging non-public or other sensitive information with customers or other third parties, if it is not necessary for legitimate business purposes, or if it could give the appearance of an inappropriate agreement or understanding.
>	Only gather information about competitors in an appropriate and lawful manner.
>	Report any suspicions or allegations of actual or potential anti-competitive discussions or activities.

Competition and anti-trust laws promote and protect the competitive process. These laws prevent companies from entering into anti- competitive agreements with each other, or from abusing a dominant position. In many cases, these laws can be applied to conduct that occurs outside a country's borders.

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