Anti-corruption and Ethical Policy of “MEDICO GLOBAL” Company

The company, adhering to the principles of the Constitution of Ukraine, the Law of Ukraine “On the Prevention of Corruption” and other normative legal acts of the current legislation of Ukraine, taking into account the world experience expressed in the United Nations Convention against Corruption of December 11, 2003, the Convention on Combating Corruption, which affects officials of the European Communities or officials of member states of the European Union of May 26, 1997, the Convention on Combating Bribery of Foreign Officials in International Commercial Agreements of November 21, 1997, the Criminal Convention on Combating Corruption of January 27, 1999, the Civil Convention on the fight against corruption dated November 4, 1999, the United Nations Convention against Transnational Organized Crime dated September 29, 2003, the US Law on Combating Corruption in Foreign Economic Activity (FCPA), etc., on the regulation of public relations to prevent the emergence and the further impact of negative manifestations of corruption at both the local and global level, in order to achieve the goals of taking and strengthening measures aimed at more effective and efficient prevention of corruption and the fight against it, encouraging honesty, responsibility and proper introduction of business, approved the Anti-Corruption Program, the text of which can be found publicly available on the Society’s website.
For the purposes of this Code, corruption is the use of official powers or opportunities related to them for the purpose of receiving an improper benefit or accepting such a benefit or accepting a promise/offer of such a benefit for oneself or other persons or, accordingly, a promise/offer or granting of an improper benefit to a person specified in part 1 of Article 3 of the Law of Ukraine “On Prevention of Corruption”, or at her request to other natural or legal persons with the aim of inciting this person to unlawfully use the official powers granted to her, or opportunities related to them.
An atmosphere of intolerance to corrupt behavior is created and maintained in the Company. The Society does not accept any form of illegal influence on the decisions of state bodies, including bribery, offering unacceptable gifts, employment of relatives of state employees, charitable or sponsoring assistance at the request of state employees. The Company’s employees comply with the requirements and restrictions established by the current legislation of Ukraine on the prevention of corruption.

The Company’s anti-corruption measures include:
1) periodic assessment of corruption risks in the Company’s activities;
2) introducing new employees to the contents of the Anti-corruption program, holding training events on the prevention and countering of corruption;
3) anti-corruption inspection of business partners;
4) provisions on mandatory compliance with the Anti-Corruption Program;
5) criteria for selecting the Company’s business partners;
6) restrictions on the Society’s support of political parties, charitable activities;
7) the notification mechanism on the detection of signs of violation of the Anti-Corruption Program, signs of committing a corruption or corruption-related offense, as well as the confidentiality of such reports and protection of whistleblowers;
8) mechanisms for preventing and resolving conflicts of interest;
9) restrictions on gifts;
10) supervision and control of compliance with the requirements of the Anti-Corruption Program.

The company conducts an internal assessment of corruption risks in its activities at least once a year. Corruption risk means the reasonable probability of a corruption or corruption-related offense or a violation of the requirements of the Anti-Corruption Program.

Corruption offense – an act containing signs of corruption, committed by a person stipulated by the Law of Ukraine “On Prevention of Corruption”, for which criminal, disciplinary and/or civil liability is established by law. Monitoring (assessment) of corruption risks in the Company is carried out by the legal department on behalf of the head of the Company.

The purpose of monitoring is to prevent, identify and eliminate corruption risks in the Company’s activities.

Corruption risks for the purpose of monitoring are divided into internal and external.

Internal corruption risks are identified in organizational-management, financial-economic, personnel, and legal procedures of the Company’s activities.

External corruption risks are identified in the activities of business partners, including state authorities, local self-government bodies, with which the Company has legal relations.

The tasks of monitoring are:
1) identify corruption risks, as well as the causes that give rise to them and the conditions that contribute to them;
2) carry out an assessment of identified corruption risks;
3) submit proposals for measures to prevent, eliminate (reduce) the level of identified corruption risks

The Company guarantees the confidentiality of employees and their reports to the head of the Company, the director of the security department or the director of legal affairs about detected signs of violations of the Anti-Corruption Program, corruption or corruption-related law enforcementeavesdropping on the activities of other employees (regardless of their position and subordination) of the Company and reports on the facts of inciting the Company’s employees to commit corruption or corruption-related offenses.

Notifications of detected signs of violations of the Anti-Corruption Program, as well as notifications of facts of incitement of the Company’s employees to commit corruption or corruption-related offenses can be made orally or in writing, using normal communication channels, such as an internal phone or a corporate email address mail of the relevant employee of the legal department, the security department or the head of the Company.

The Company notes that the program also applies to messages that can be made by employees and officials of the Company’s business partners.

Submission of knowingly false messages is not allowed.

Notifications about the detection of signs of corruption or corruption-related offenses cannot be anonymous.

The security department or a person designated by the head of the Company shall verify the information contained in the notification. The persons involved in the verification of the information contained in the message do not have the right to disclose it.

Any data that makes it possible to identify the person who reported the facts of incitement to commit a corruption or corruption-related offense or the detection of signs of violation of the requirements of the Anti-Corruption Program, the commission of corruption or corruption-related offenses by employees or other persons, belong to to confidential information and protected by law.

Information about an employee who reported signs of violation of the requirements of the Anti-Corruption Program, detection of signs of a corruption or corruption-related offense (hereinafter referred to as a whistleblower) may not be disclosed, except in cases established by law.

The whistleblower may not be fired or forced to fire, brought to disciplinary action or subjected to other negative influence measures by the Company’s management, or the threat of such influence measures in connection with his notification of a violation of the requirements of the anti-corruption legislation and/or the requirements of the Anti-Corruption Program.

CODEX
BUSINESS ETHICAL BEHAVIOR
MEDICO GLOBAL Limited Liability Company

I. INTRODUCTION
1.1. Compliance with the highest standards of ethical and responsible business behavior is the basis of MEDIKO GLOBAL Limited Liability Company’s activities (hereinafter referred to as the Company).
The Code of Business Ethics (hereinafter referred to as the Code) lays down the foundations of the Company’s activities, which are carried out on the basis of integrity, responsibility and continuous improvement. This Code is intended to provide an understanding of the expectations and standards for ethical business conduct and responsible business conduct.
1.2. The Code of Business Ethics defines:
– our values;
– standards and behavior expected from each employee of the Company;
– rules of interaction of the Company’s employees with each other;
– rules of interaction of the Company’s employees with interested parties;
– our obligations to comply with the Code;
– responsibility for failure to comply with the requirements of this Code.
1.3. All employees of the Company must not only formally adhere to the Code of Business Ethical Conduct, but also be deeply aware of its meaning and practical expediency.
The company requires all its partners to adhere to the rules of ethical conduct of business, especially those related to quality standards, compliance with labor rights and the fight against corruption.
1.4. The company is a member of the association of market operators of medical products AMOMD®, which in turn is the initiator and coordinator of the implementation among its members of the business ethical behavior stipulated by this Code.

II. OUR VALUES
2.1. Perfection – everything we do meets the highest quality standards: both our internal and global ones.
2.2. Neatness – we carefully choose products, pay a lot of attention to details and bring the final product to perfection.
2.3. Responsibility – we are responsible to consumers for the quality of our products, because they trust us with something more valuable – their health.
2.4. Innovativeness – we follow market trends and implement them in our products. Our products are always modern and easy to use.
2.5. Development – we constantly develop and implement new ideas, so we constantly focus on market analysis and user behavior.
2.6. Timeliness – we promptly respond to events and tasks, creating relevant conditions for cooperation with customers and suppliers.

III. OUR BUSINESS STANDARDS
3.1. Compliance with legal requirements and internal standards: in our activities, we comply with all applicable laws and do not engage in activities that violate the laws of Ukraine, the legislation of the European Union, international standards and requirements for conducting business from international organizations and institutions of which Ukraine is or aspires to become a member .
In addition to complying with relevant laws and regulations, we comply with the requirements of applicable internal documents, including this Code.
In our decisions and actions, we are also guided by high ethical standards: we fulfill our obligations to customers, suppliers, government bodies and business partners honestly, conscientiously, professionally and ethically. We prioritize legality, quality and integrity over profit, schedule or achieving competitive advantage.
3.2. Fair and lawful competition: We act independently and do not coordinate our actions with competitors, except where a legitimate business arrangement exists, such as a joint venture or partnership; we avoid even the appearance of improper deals with competitors.
We condemn anti-competitive practices, such as collusion between competitors to fix prices, share markets or bid collusion, that result in inflated prices and inferior products, works or services.
We believe that competition makes us better, because free markets encourage us to be more efficient and innovative, and to provide better products, jobs and services.
We consult with legal or compliance departments before engaging in commercial activities that may restrict competition, including, but not limited to, sharing information with competitors, bundling or tying arrangements, exclusive dealer contracts, disclaimers supplies to our competitors, internal regulations on non-competition, obtaining permission to participate in trade associations and other groups that require frequent contacts with competitors, etc.
3.3. Adherence to the rules of international trade and sanctions restrictions: we comply with the legislation of Ukraine, the legislation of partner countries and international standards on issues of export-import control, imposition of sanctions and embargoes, which are aimed at protecting national security. We strive to be a reliable exporter and importer, as any violation of these requirements may jeopardize our foreign economic activity and have serious consequences.and the consequences, including the refusal of our partners to cooperate.
We must never violate trade sanctions and export-import controls and must minimize the risk that cooperation with us will be used by third parties as a means of evading established restrictions and prohibitions or money laundering.
We consult with legal departments before working or entering into agreements with third parties or before carrying out any export, re-export, import or transfer of controlled goods, in order to ensure compliance with export-import control laws and sanctions restrictions within the relevant jurisdictions.
3.4. Responsibility at work: we ensure the reliability of our obligations – we adhere to the agreed terms of the concluded contracts and do not deviate from them without the appropriate authorization, we always immediately report any doubts about the safety and quality of the products to resolve discrepancies before they have an impact on quality We apply the same standards of care to property and equipment entrusted to us under our responsibility and owned by our customers, business partners and other third parties.
3.5. Ensuring the quality and safety of products, works, services: We are responsible for ensuring that the products we supply, the works and services we perform and provide meet the expected level of safety and quality agreed with buyers/customers.
We fulfill every order by adhering to our product safety and quality policies, standards and processes. Our policies, standards and processes remain relevant throughout the product lifecycle.
It is our job to ensure that the necessary quality standards are understood, communicated and applied in all processes to ensure that our products meet the quality and performance requirements agreed with our buyers/customers.
3.6. Virtuous leadership:
– “Tone from the top” – we adhere to the “Tone from the top” principle, which defines the responsibility of managers for introducing a culture of integrity, mutual respect and free expression of opinions in teams. By their actions, managers contribute to the creation of a positive work environment free from harassment that encourages high standards of ethical behavior.
The Company’s managers contribute to raising the awareness of employees on issues of ethics and business conduct by introducing an introductory course on the rules of business ethical conduct for new employees, introducing tools for compliance with the rules of business ethical conduct, and also undertake to undergo regular training on ethical leadership;
Company managers discuss the importance of ethics with employees and emphasize the need to report ethical issues, promptly and appropriately respond to employee concerns and requests for recommendations on ethical behavior;
– prevention of corruption – we act on the principles of integrity, zero tolerance for manifestations of corruption and responsibility. We fulfill our obligations legally and honestly, every employee, including management, acts honestly, legally and adheres to the highest business standards. We do not offer, pay or accept bribes (illegal benefits) or kickbacks for any purpose, either directly or through third parties. We do not make referral payments or allow others to do so on our behalf;
– avoidance of conflict of interest – we do not participate in any activity that creates a conflict of interest for the employee or for the Company. We do not allow personal interests to interfere or interfere with our ability to make fair and objective decisions in the performance of our duties. A conflict of interest is not necessarily a problem in itself, but we are required to fully disclose situations where non-business activities, personal or financial interests may potentially conflict with the interests of the Company;
– compliance with the norms of business hospitality – before offering or accepting any gifts or tokens of hospitality, we make sure that their value is reasonable, in line with standard business practices and allowed by internal standards.
We do not offer, provide, demand or accept gifts or other signs of hospitality to influence our decisions and actions and the decisions and actions of our partners, customers or authorities. We do not offer, provide, demand or accept gifts in the form of cash.
3.7. Fair procurement: We establish business relationships with our suppliers based on mutual good faith. Fair treatment is an integral part of the procurement process and requires transparency regarding the rules by which suppliers are selected, in particular, fair treatment of each partner throughout the decision-making process, verification of the integrity of suppliers, subcontractors and partners, reasonableand due diligence regarding the acceptance of risks, the obligation to comply with the agreed agreements, the guarantee of neutrality and independence of suppliers during the entire period of the legal relationship.
Procurement units are committed to guaranteeing and maintaining competitiveness in procurement in the long term. We do not share tender details with anyone unless it is legal or permitted by our internal rules. The personal interests of employees (private, professional or financial interests of the employee or a member of his family, the environment that calls into question the ability of the employee to act impartially and objectively in his professional activity) should not influence the choice of supplier or any decision concerning purchases under no circumstances.
3.8. Proper working conditions:
– healthy and safe working conditions – we take measures to provide our employees with a suitable, safe and healthy workplace, protect the environment wherever we operate and strive for excellence in safety, health and health and environmental management the environment
The Company’s managers promote well-being by encouraging employees to maintain a balance between their professional and personal lives. Drugs, alcohol, weapons (except for certain cases confirmed by relevant regulatory documents) and violence in the workplace are prohibited in the Company;
– mutual respect and non-discrimination – Companies are committed to creating a work environment that promotes communication, productivity, creativity, teamwork and employee engagement. In our relationships with each other, we adhere to our business standards, social norms of behavior and ethical principles that go beyond the legal field. We try to resolve any disagreements through constructive dialogue with each other or with the involvement of the manager.
We prohibit discrimination on grounds protected by current legislation and UN international conventions, including: race, skin color, political, religious and other beliefs, sex, age, disability, health status, gender, ethnic and social origin, citizenship, family and property status, place of residence, language or other characteristics that were, are and may be valid or assumed;
– an environment of equality and inclusiveness – ensuring equal opportunities allows us to hire and work with the best candidates and realize our desire for excellence in the Company’s processes, products, works and services. We are responsible and honest in our efforts to attract talented employees and develop their potential. We focus exclusively on the relevance of skills and experience, as well as the fit with our values ​​and culture. Ensuring equality means we make hiring and promotion decisions based on qualifications, aspirations and performance, not on favoritism or bias, and we help each other to develop and reach their potential.
We understand the importance of fair treatment, based on achievements, because it encourages employees to be more engaged and productive, and also supports the Company’s desire to create innovative and reliable products.
We work to support the Society’s aspiration to create an inclusive culture where diverse experiences and voices are heard, respected and considered in addressing the most important issues facing us as a single team. We take measures to create an inclusive space for employees with disabilities or special religious needs, etc., if necessary;
– prevention of child labor – we strongly support the principles of prevention of the use of child labor in all aspects of our activities. We adhere to international and national standards for the protection of children’s rights and do not cooperate with enterprises that engage children in unacceptable forms of labor. We support initiatives aimed at ensuring the education and development of children and work for the benefit of children’s communities.
– protection of personal data – we ensure proper storage, processing, exchange, transfer and deletion of personal data, in accordance with internal regulatory requirements for their handling, which apply to such information and do not allow their leakage, disclosure and transfer, except in cases where such actions are permitted and mandatory in accordance with legal requirements.
3.9. Careful attitude to resources – responsible use of resources – we are responsible for the proper use, protection and management of all assets – both tangible and intangible – owned or controlled by the Company. In particular, we handle financial resources with care, prevent and detect fraud. We undertake to ensure the preservation of the property and equipment of the Company that we use in our work, including tools, materials, parts, equipment, software and documentation, wewe do not allow its loss, damage, abuse, improper or inappropriate use. We follow and enforce security measures regarding access to our facilities and report any suspicious activity;
– protection of intellectual property – we protect our intellectual property rights and trade secrets from unauthorized access, use, misappropriation, destruction or loss.
We immediately inform you about the creation of objects of intellectual property rights during the performance of official duties for their proper and timely protection.
We respect the intellectual property rights and trade secrets of others as we would want them to respect ours;
– information protection – we are responsible for the proper use of the Company’s IT networks and systems, as well as for the protection, storage and proper processing of information, data of customers, business partners and other interested parties. In order to protect the information we own, work and business activities should be carried out only on authorized devices and on the Company’s networks or on agreed networks and applications of third parties and customers;
– protection of reputation – we choose a method of activity that will not call into question the honesty, impartiality or reputation of the Company. If an internal problem is detected, we immediately inform the Company’s management to minimize the consequences before the information becomes known to third parties or is publicly disclosed. We support the responsible use of social networks for business purposes and ensure that our personal activity on the Internet does not harm the reputation of the Company.
3.10. Reliable accounting and reporting: we ensure that all business transactions are accounted for correctly, properly and on time. We ensure reliability, accuracy and completeness of reports in accordance with established procedures, accounting principles, relevant accounting systems and controls. We ensure that the information we disclose or provide is accurate, timely, complete and understandable.

IV. OUR OBLIGATIONS
4.1. We know and understand the provisions of the Code
Each of us is responsible for reading and understanding the provisions of this Code. All managers are responsible for ensuring effective communication and monitoring the familiarization of this Code with their subordinates. Our divisions and employees organize systematic training and communication of employees on the issues specified in this Code, as well as provide relevant materials and documents for this purpose. In all business situations where legal requirements or this Code of Business Conduct appear to be incomplete or unclear, we use prudence and common sense.
4.2. We follow the Code
We must not only follow the letter of this Code in all business matters, but also live and imbibe its spirit. Regardless of position, we will adhere to the Code and encourage our colleagues, especially those who report to us, to do the same. When in doubt, we refer to our management, legal or compliance departments.
4.3. We report violations of this Code
We treat our colleagues with respect and understanding, but we do not ignore violations of the Code. We report violations in good faith to our standards for a prompt and thorough investigation.

V. LIABILITY FOR NON-COMPLIANCE WITH THE CODE
5.1. Failure to comply with the norms and standards of conduct contained in this Code is considered a serious violation. Such a violation is considered through an investigation and may result in disciplinary action, including dismissal.
5.2. Managers at all levels are responsible not only for their actions, but also for compliance with the Code by their subordinates. Accordingly, they must demand compliance with the policies, procedures of the Company and applicable legislation, as well as prevent, detect and promptly respond to cases of violation of norms and standards of business conduct by their subordinates.
5.3. Liability also occurs in the following cases:
– addressing other employees with a request or demand to violate the company’s internal normative documents or provisions of the Code or current legislation;
– concealment or untimely notification of known facts of violation of the Code;
– prosecution of persons who reported violations.

VI. CONTACTS AND ADDITIONAL INFORMATION
If you become aware of a violation or abuse in your Company, report it to: the Company’s hotline
“MEDICO GLOBAL” e-mail:
info@medikoglobal.com.ua by letter to the address:
Dnipro, Panikahi street, building 2, building 1, office 319
(marked “notification of violation”).
Director of “MEDICO GLOBAL” LLC O.V. Yatsunskyi