As a leading global CDMO, we are committed to complying with laws and ethical standards, maintaining a clean organizational culture, and fulfilling our responsibilities as a global corporate citizen.

To uphold these principles and promote compliance, we declare the following as our Compliance Policy.

• The Company shall implement, operate, and continually improve its Anti-Bribery Management System (ABMS) and Compliance Management System (CMS)
• The Company shall operate a whistleblowing channel through which concerns regarding bribery, corruption, and other compliance violations may be raised in good faith, and shall ensure that no harm comes to the whistleblower as a consequence of their actions.
• Company shall designate the Compliance Officer as the person responsible for overseeing compliance governance and ensuring adherence to applicable obligations.
• The Company shall take appropriate action against employees who violate compliance obligations, in accordance with internal policies and regulations.
• Employees shall comply with company policies and applicable laws relevant to conducting company business.
• Employees shall not engage in, or be complicit in, any acts of bribery.

Samsung Biologics President & CEO
John Rim

Purpose

Samsung Biologics conducts its business by taking its responsibility as a global corporate citizen and complying with anti-corruption laws worldwide to uphold the business principles of complying with legal and ethical standards and maintaining a transparent organizational culture. Samsung Biologics has a zero-tolerance policy against corruption and bribery and it does not deliberately ignore nor overlook any corruptive acts. This Anti-Corruption and Bribery Policy (”Policy”) provides detailed anti-corruption guidelines and standards for directors, officers, and employees relating to all business activities of Samsung Biologics.

Application

This Policy applies to all directors, officers, and employees (including all permanent and temporary employees, contract workers, and corporate advisors) at Samsung Biologics Co. Ltd., and its subsidiaries and affiliated companies worldwide (collectively “Samsung Biologics”). Anti- corruption laws vary among countries. Therefore, certain subsidiaries or affiliated companies may have their own anti-corruption policies. In such case, both this Policy and the local policy must be followed. In case of any conflict in terms between the policies, the stricter standard will apply.

Definitions

• ‘Government officials’ are broadly defined to include public officials (individuals engaged in the legislative, administrative, or judicial affairs of the government, whether appointed or elected), candidates for government offices, executives of political parties, employees of corporations that are government-owned or effectually operated by a government, employees of public institutions or organizations established to carry out public affairs, employees of international organizations (e.g. IMF, and etc.), an official agent or consultant of a government, and employees of other public service-related organizations or an individual entrusted with public affairs.
• ‘Unfair business profit’ means any profit that is acquired in an unjustifiable way against laws, and etc.
• ‘Anything of value’ means any tangible or intangible economic benefit provided in a favorable manner, and may include, but are not limited to: gifts, entertainment, cash, or securities.

Basic Principles

Compliance with Laws, Policies and Guidelines

Samsung Biologics’ executives and employees are responsible for complying with all applicable anti-corruption and bribery laws, and this Policy.

• In addition to the local laws, applicable anti-corruption and bribery laws may include the US Foreign Corrupt Practices Act (“FCPA”), UK Bribery Act (“UKBA”), and the Improper Solicitation and Graft Act of Korea.

Prohibited Activities

• No Bribery: Do NOT receive or request illegal money or valuables in connection with your work
• Prohibition of providing illegal money or valuables to government officials, and etc.: Do NOT provide, offer, nor promise to give, money or anything of value, directly or through a third party to government officials, in exchange for an improper business interests.
• Prohibition of improper solicitation: Do NOT make any illegal requests or make request that elicits abuse of authority, when dealing with government officials.
• Prohibition on payment of facilitation fee: ‘Facilitation fee’ refers to a small amount of money paid to government officials for the purpose of expediting or facilitating the routine government services. DO NOT pay such fee.

Providing Gifts Hospitality and other Benefits

Gifts or hospitality provided to serve legitimate business purposes, or to maintain business relationships, are permissible if all of the following principles are met:

• Conform to all applicable laws and the policies of a recipient’s organization
• Have a legitimate business purpose and appearance of propriety
  * When there is a pending issue (e.g. admission, license, inspection, pending contract), providing a gift or hospitality requires extreme caution and providing cash is strictly prohibited.
• Be reasonable in value and frequency
  * Gifts and hospitality should be nominal, infrequent, and appropriate under the circumstances, so that it does not exert improper influence on the recipient’s decision making.

* Particular care is required when offering gifts or hospitality to a government official and must be in compliance with the internal processes.

Donations, Contributions, and Sponsorships

Political Donations

Illegal political donations using Samsung Biologics’ assets are strictly prohibited.

Charitable Donations, Contributions, and Sponsorships

It is permissible to make legitimate charitable donations, contributions, or sponsorships to credible institutions and organizations. However, there must be no improper advantage or undue influence, and must be made in compliance with the internal processes.

Books and Records

Executives and employees must manage books and records in detail and accurately, through reflecting various transactions. Executives and employees must prepare accounting and financial reports fairly and appropriately in accordance with relevant laws and regulations, and must not record untrue or falsified information or omit information that should be recorded. In addition, the company must maintain and manage the integrity of data to prevent recorded contents from being forged, altered, or deleted during storage.

Implementation of Policy

Anti-Bribery Management System (ABMS)

Samsung Biologics will operate and continuously improve its ISO 37001 certified Anti-Bribery Management System, in order to effectively implement and enforce this Policy.

Reporting

Any Samsung Biologics employee, who knows of or suspects a violation of this Policy, or any anti-corruption and bribery laws of relevance, should report such violations to Samsung Biologics.

Reports may be made anonymously through e-mail (bio.cp@samsung.com or sbl.audit@samsung.com) or through the Samsung Biologics webpage. The whistleblower’s personal information will be kept confidential, and the contents of the report will also remain confidential. There will be no retaliation against a whistleblower who reports in good faith.

Disciplinary Actions and Others

Matters and procedures not specified in this Policy such as inspection and monitoring of compliance with the guideline and anti-corruption and bribery laws shall be subject to the company’s regulations and compliance program. Failure to comply with this Policy and anti-corruption and bribery laws will be grounds for disciplinary action according to the internal standards, up to and including termination of employment.