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Anti-retaliation

We prohibit retaliation or harassment against anyone who, in good faith, reports an identified or potential violation of the Code or the Company’s policies and applicable procedures and applicable laws.

Our Company seeks to create a workplace that promotes an open and trusting environment.

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We value our employees and have established Company policies and applicable procedures to encourage the reporting of potential illegal, unethical or otherwise non- compliant conduct without fear of retaliation

We prohibit retaliation against any employee who raises a compliance concern in good faith. Retaliation includes any employment decisions, intimidation, harassment, or other misconduct that has the intent of punishing an employee in response to reporting an identified or potential violation or assisting in a Company investigation.

We take reports of retaliation or harassment against those reporting identified or potential compliance violations seriously and will take appropriate disciplinary action when warranted.

We actively promote these principles to our vendors, strategic partners, contractors, if possible, in the form of contractual agreements

Compliance with laws and regulations

We respect and adhere to the laws and regulations governing our industry.

At PharmaNest, we are committed to following all laws and regulations applicable to our business activities, especially those designed to protect patients and improve the quality of medicines and healthcare services. As a global company, we recognize that the laws and regulatory requirements of one country may apply to our activities taking place in another country.

Furthermore, the laws and regulations governing our Company cover a wide range of business activities, such as clinical research, product marketing, securities trading, fair competition, privacy, labour and employment and environmental protection. While employees are not expected to know the details of every law or regulation, we should remain aware of the core requirements established in this Code and understand when to seek advice.

Each of us is expected to be familiar with the Company’s policies and applicable procedures relevant to the area in which we work. When appropriate, our Company provides training and education relevant to the laws and regulations governing our employees. Situations may arise in which the laws and regulations are not clear. In these cases, employees are expected to contact their manager or the Legal or Compliance Departments for additional guidance.

We actively promote these principles to our vendors, strategic partners, contractors, if possible, in the form of contractual agreements

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