Conflict of Interests

We seek to ensure our decisions and actions are always for the benefit of the Company.

PharmaNest recognizes and respects the rights of employees to engage in outside activities. As employees, we should avoid situations that present a conflict between our personal interests and the best interests of the Company. Additionally, we should avoid situations that may create even the appearance of a conflict of interest. A conflict of interest may involve internal Company activities, external opportunities or employment, vendor relations, human resource decisions or any number of other activities where an employee’s interests may not align with those of the Company.

Never abuse your position or Company property for your own personal benefit. We must always conduct business in a way that serves the interests of the Company and is not influenced by personal, family, or financial interests.

Employees must disclose all potential conflicts of interest to their manager or the Human Resources, Legal or Compliance Departments.

Gifts and Entertainment

We do not give or accept gifts and entertainment that could call into doubt our personal integrity.

PharmaNest understands that giving or accepting gifts and entertainment is often associated with customary business practices as well as cultural norms.

Under these circumstances, giving or accepting gifts and entertainment may be appropriate, so long as it is done with pure intent and not for the purpose of unduly influencing the recipient, whether it be a third party or Company employee.

Even the appearance or perception of an improper gift or entertainment could compromise the business operations and reputation of the Company. As such, employees must use caution when giving or accepting gifts and entertainment during the course of their interactions with our business partners, vendors, suppliers and other third parties. We must adhere to the following requirements when giving or accepting gifts or entertainment:

• Gifts and entertainment must be of modest value, consistent with customary business practices and cultural norms

• Gifts and entertainment must not be lavish, excessive or based on a quid pro quo understanding.

• Requesting or soliciting gifts or entertainment is strictly prohibited.

The giving or accepting of gifts and entertainment must adhere to the Code and the Company’s policies and applicable procedures, especially those focusing on anti-bribery, corruption, and interactions with healthcare professionals.

For further clarification or guidance, employees should consult their manager or the Human Resources, Legal or Compliance Departments.