This Code of Business Conduct and Ethics describes the principles and practices that guide business conduct at Novolog. This code reflects management’s objective to reinforce the company’s ethical standards and to sustain a work environment that ensures integrity, respect and fairness. It is Novolog’s confidence that the long-term interests of the company are best served by strictly following policies to be lawful, highly principled, and socially responsible in all business activities.

Maintaining the trust and confidence of our business partners means ensuring that our high level values are translated into consistent and appropriate behavior. This Code is applicable to all Novolog’s employees.

  1. Compliance with Laws
    Novolog is committed to conducting its business in compliance with all applicable laws and regulations and with the highest ethical standards. Novolog’s reputation for integrity, quality and high standards is based on this commitment and helps to ensure its long-term success.

 

  1. Corporate Responsibility
    Novolog is dedicated to operating in a manner that is socially, environmentally and economically responsible. Novolog strives to ensure that its services meet appropriate multinational and legislative standards and operates at the highest level of compliance with those standards. Appropriate procedures designed to promote product safety and high quality service are communicated to, understood, and applied by each employee, and performance is monitored and measured on an ongoing basis.   

 

  1. Avoidance of Conflict of Interest
    Novolog operates with all business partners in a completely fair and objective manner. Novolog does not favor or show preference based upon personal or financial relationships. Company employees must not act in a way which might even appear to constitute a conflict of interest between business partners and their own role in the company.   

 

  1. Anti-corruption
    Novolog will not tolerate any practice which seeks to obtain or promote business through improper means such as corruption or bribery. This includes any offer or acceptance of an offer of bribery; the giving or receiving of any illegal, covert, or unethical payment; and the avoidance of any corrupt business activity.

 

  1. Antitrust
    Novolog believes in fair trade practices and unrestricted competition. Each employee is required to fully comply with all antitrust rules and regulations, and strictly avoid all practices regarding price fixing, allocation of customers or markets among competitors and boycotts, and at all times are forbidden to discuss or exchange with Novolog’s competitors any information regarding (i) prices, price changes, price quotations, pricing policies, discounts, payment terms, credit, allowances, or terms or conditions of sale; (ii) profits, profit margins or cost data; (iii) market shares, sales territories or markets; (iv) the allocation of customers or territories; (v) selection, rejection or termination of customers or suppliers; (vi) restricting the territory or markets in which a company may resell services or products; (vii) restricting the customers to whom a company may sell; (iix) unreasonable restrictions on the development or use of technologies.

 

  1. Confidentiality and Privacy
    Novolog’s directors and employees are obligated to maintain the confidentiality of information entrusted to them by their business partners or learned in the course of their service. Moreover, they must take all reasonable measures to safeguard and protect information. This obligation applies even after leaving the company.

 

  1. Fair Working Conditions
    Novolog recognizes that its employees are the company’s greatest asset and resource. Novolog is committed to providing a supportive and safe work environment, creating a workplace where every individual has the opportunity for professional and personal growth.

 

  1. Equal Employment Opportunity
    It is Novolog’s policy to provide equal employment opportunities and to treat applicants and employees without regard to personal characteristics such as race, color, religion, gender, sexual orientation, age, gender identity or gender expression, national origin, marital status, disability, veteran status, or any other characteristics protected by applicable laws.

 

  1. Accountability
    All employees are required to comply with the standards set forth in this Code. Violations of the Code will lead to consequences. Such consequences may include removal from office or termination of employment.

Each and every one of the company's employees is required to conduct him or herself in compliance with the company's Code of Ethics. Any employee who believes that another employee is in breach of any of the provisions of the Code of Ethics must report such breach to his or her supervisor within the company, or to a senior officer of the company. Failure to report such a breach constitutes in itself a breach of the Code of Ethics and is subject to all possible consequences. Any breach of the Code of Ethics may result in disciplinary steps against the employee, including termination of employment or even initiation of criminal proceedings.