Code of Ethics

Our code of ethics

• Through our various lines of action, VJ Salomone Pharma aims to contribute positively to the well-being of society. Our role in the pharmaceutical business is to help in the implementation of the changes necessary to improve healthcare standards in the population we service.

Access to Medicines

• To make more of our medicines available to the entire population that depends on us for supply. We will systematically integrate access strategies into how we deliver all our medicines on the market.
• We want to address the needs of all patient populations.

Anti-corruption

• Not to tolerate any form of bribery or corruption. We will not give, offer or promise to give anything of value or accept, request or agree to receive anything of value for the purpose of improperly influencing any decisions. We will not use third parties to commit acts of bribery or corruption.

Antitrust and fair competition

• To engage in fair competition and compete on the merits of our products. We will not engage in agreements or conduct that unlawfully prevent or restrict competition. We are proud to compete on the merits of our products alone.
• Competition drives innovation and leads to greater choice of high quality products at competitive prices, benefiting patients and society.

Business continuity and crisis management

• To ensure an uninterrupted supply of key products and services to patients.
• We will take all reasonable precautions to protect patients, associates, assets and the business from any disruptive incident.
• Our medicines save and prolong people’s lives. Patients, suppliers and our business rely on the continuous supply of our products.

Conflicts of interest

• To ensure our business judgment is not influenced by personal interests. We will disclose and manage potential, perceived, and existing conflicts of interest.
• To maintain trust and confidence with all our stakeholders, we must ensure that we make decisions that are in the best interest of VJ Salomone Pharma and the patients we serve.

Customs and trade compliance

• • To comply with customs regulations, export and import controls, and trade sanctions laws.
  • We will ensure that we do not engage with persons or companies that have been placed by governments on sanctioned party lists.
  • Complying with customs regulations, export and import controls, and trade sanctions laws allows us to deliver our medicines in a timely manner to patients who need them, whilst building trust within our society.

Data use

• • • To use personal information that we are entrusted with in a responsible way.

We will adhere to our Data Privacy principles.

• The responsible use of data helps us maintain trust with stakeholders, including suppliers, patients, healthcare professionals, and society. It ensures we will continue to have access to the data we need to operate.

Diversity and inclusion

• • • To create a diverse and inclusive environment that treats all employees with dignity and respect. We will educate our people on inclusivity and provide all employees with equal opportunities to contribute to our company and advance their careers.

Drug safety

• • • We will report adverse events and quality complaints within 24 hours of discovery to our principals and marketing authorization holders and coordinate any communications of risks of medicines and devices to regulatory authorities upon approvals from our principals.
    • The safety of medicines and treatment of patients is of critical importance. Medicines and treatments can have potentially undesirable effects. Reporting those adverse events is critical in order to take appropriate actions to safeguard patient wellbeing.

Environmental sustainability

• • • To minimize the environmental impact of our activities and products. We will strive for a positive effect on climate, by reducing our carbon footprint, waste and water usage and making efficient use of natural resources.
    • As members of society, we have to protect the environment for future generations.

Fair employment practices

• • • To create a safe place to work in, where all our employees have an equal opportunity to succeed. We will not tolerate discrimination, harassment, retaliation, bullying or incivility. We value the contributions of all our employees and encourage them to express themselves and give their opinions freely in a professional way.
    • Fair employment practices benefit all our employees, as well as society, and provides the integral foundation to support our commitment to human rights.

Taxation and Financial Integrity

• • • VJ Salomone consists of a group of companies formed in Malta and operating locally. The tax obligations of the group of companies comprise compliance mainly with the following regimes that all fall under the Commissioner forb Revenue (CFR):

– Income Tax;

– Value Added Tax;

– Social Security taxes; and

– Duty taxes on importation of products, where applicable.

Income Tax Act

• • • The obligation of the group of companies is to compute the tax expense of the respective entity on a yearly basis in conjunction with the preparation of audited financial statements. The filing deadline for the income tax return of any particular year is 21 November of the following year. Provisional tax payments, as instructed by the CFR at the beginning of any year, are to be made by end of April, August and December. If, on the basis of the audited accounts, top-up payments are required, these need to be made by the end of September of the following year and the tax return to be then submitted by 21 November. Failure to comply to these dates will result in fines and penalties.

Value Added Tax (VAT)

• • • The obligation for the group of companies is to file VAT returns every quarter. The VAT returns are compiled by extracting the relevant financial information from the company’s accounting system. The deadline to submit and pay a VAT return (which in our case is done on line) is 45 days after the end of the quarter. Failure to comply to this date will result in fines and penalties.

Social Security Taxes

• • • The obligation of the group of companies is to compile an FS5 of the respective entity, which in essence is the summary of the payroll cost in relation to that particular month and is extracted from the company’s payroll system, and to be submitted to the CFR by the end of the following month.
    • Upon submission, a payment reference is provided to settle the amount due for that particular month. Failure to comply to this date will result in fines and penalties.

Duty taxes

• • • The operation of the group of companies is principally that of importing products for sale in the local market. Depending on the nature of origin of the imported product, particularly if imported from outside the EU, duty taxes may be applicable, and the obligation of the company is to declare the imported products and settle any duty tax upon receipt of the products. Failure to comply to this date will result in fines and penalties.

Other laws directly related to finance

• • • The local law governing financial reporting is the Maltese Companies Act, 1995. This sets out the rules and obligations for limited liability companies in Malta. In accordance with this legislation, the group of companies is mandated by law to present yearly audited financial statements approved by the board of directors by 31 October (since the financial year end of the group of companies is 31 December) of the following year. These are then to be filed with the Malta Business Registry by 12 December. Failure to comply to both dates will result in fines and penalties.
    • The finance function of the group of companies is committed to meet the above requirements and respect the various statutory deadlines for filing, reporting and timely settlement of any dues with the respective Government entities.

Health and safety

• • • To protect and promote the health and safety of our employees, contractors, visitors and patients. We ensure and promote health and safety best practices.

Human rights

• • • To conduct our business in a manner that respects the rights and dignity of all people. We will strive to prevent, mitigate and remedy adverse human rights impacts throughout our workplace, business operations and in the communities in which we work. We want to protect people from abuse by those who are more powerful.
    • Respect for human rights is an ethical obligation and an opportunity for transformative change in people’s lives.

Intellectual property

• • • We also respect the intellectual and industrial property rights of our business and our business partners and third parties, and do not make use of protected inventions without express permission.
    • We ensure that the intellectual and industrial property rights of third parties are not infringed when preparing materials of any kind.

Confidential information and business secrets

• • • We handle confidential information and business secrets carefully, ensuring that the only people who have access to the information are the people who need it for their job, and making sure they make responsible use of the information.
    • We have the appropriate data protection and security measures in place to safeguard confidential information and business secrets, stored on any format, against any risk, accident, or tampering, including access controls and device encryption.

Information and cyber security

• • • To protect our data and technology and ensure that information is kept safe from theft, loss, misuse, or disclosure. We will take accountability for the information and technology we handle.
    • Having access to the right data is instrumental to achieving our vision. At the same time, we have an obligation to safeguard our patients’ and partners information.

Professional practices

• • • To maintain high standards of ethical business conduct. We are committed to the same high standards of ethical business conduct wherever we do business. We will adhere to our Professional Practices and Anti-Bribery Policy, which help to guide our daily decision-making.
    • Interacting in an ethical manner and operating with integrity has a profound impact on finding new ways to expand patient access to our treatments and building trust with society.

Responsible lobbying

• • • To share fact-based information in a transparent way and take the perspectives of all relevant stakeholders into account. We will engage in public discourse on social issues that are linked to our mission of providing healthcare products to the patient population that depend on us for supply.
    • Contributing to the development of policies that are beneficial for our society helps builds trust. Data and insights provided to policy makers enables them to make better informed decisions to help improve patient outcomes.

Third-party risk management

• • • To work with third parties who operate in a manner that is consistent with our values and ethical principles. We will select the parties best suited for our business and society based on objective criteria, evidencing their competence, integrity, and other relevant merits. We will strive to ensure that throughout our relationship, the third party continues to uphold the same standards.
    • Our success depends on strong, reliable and reputable partners. They help us build trust with all our stakeholders, by maintaining the same standards.

Our responsibilities

• • • We are all personally accountable for adhering to our Code of Ethics, as well as our other policies, guidelines and local laws. In case of uncertainty, we are responsible for seeking advice from the local Ethics, Risk & Compliance Team.
    • Breaches of this Code of Ethics, as well as our policies, guidelines or local laws, will result in remedial, corrective or disciplinary actions up to and including termination of employment. It is an obligation for each of us to report actual or suspected incidents of misconduct to the Human Resources Office. VJ Salomone Pharma guarantees non-retaliation and confidentiality, to the extent legally possible, for good-faith reports of such breaches. The Human Resources Office will handle every matter in compliance with company policies. The necessary steps will be taken to protect the confidentiality of the reporter and other employees involved in the investigation.
    • Every complaint is taken seriously. Any employee who raises a potential misconduct concern, assists or provides information during an investigation, or otherwise acts in good faith in the best interests of VJ Salomone Pharma will be protected against retaliatory action.

Who is the Ethics & Compliance Team?

• • • Our Ethics and Compliance Team is comprised of the following:

Contact us

• • • If in doubt, ask first and act later.
    • We encourage all our professionals to express their doubts or concerns. If you have any questions regarding the Ethical Code or other regulations that apply to VJ Salomone Pharma, please contact the Ethics & Compliance Team personally or by email at: [email protected]

Speak UP!

• • • If you know of or suspect any improper behaviour, or become aware of a situation that goes against VJ Salomone Codes of Ethics, please report it by sending an email to: [email protected]

Publishing date: 06^th March 2024

Code of Ethics effective date: 31^st July 2023