Code of Ethics of Bajir.

Basic ethical principles

• The Company Bajir rejects any form of discrimination and unequal treatment and actively creates an environment with equal and fair working conditions for all its employees. We do not tolerate harassment, intimidation, bullying or other forms of inappropriate behaviour.
• Employees must always act properly and honestly towards clients, suppliers, business partners and other employees, and must protect the good name and reputation of the Company Bajir and of its clients, suppliers and business partners in public.
• Employees are expected to avoid any actual or potential conflict of interest that could influence, or appear to influence, their judgement or conduct in performing their duties for the Company Bajir.
• Employees must immediately report any suspicion of possible unethical or unlawful conduct to their direct superior or to the executive director of the Company Bajir. The Company Bajir will investigate all justified suspicions and take appropriate measures. At the same time, it will ensure to the greatest possible extent the confidentiality and protection of the complainant against any retaliation.
• The Company Bajir and its employees must not use forced or involuntary labour. The Company Bajir requires the same commitment from its business partners.
• Employees have freedom of association in trade unions and other employee representative bodies. Bajir respects the right of employees to join or not to join trade unions and other employee representative bodies in accordance with the Labour Code. Bajir likewise respects the rights of employee representatives arising from the Labour Code and the rules of collective bargaining.

Anti-corruption principles

Since its establishment, the Company Bajir has maintained a corporate policy prohibiting employees from providing any payment or benefit to anyone where the purpose is to improperly influence a public official or to obtain an unfair business advantage. The Company Bajir requires all its employees to act in accordance with these principles.

Bribery of public officials

Most countries, including the Czech Republic, have adopted legislation prohibiting the direct or indirect giving, offering or authorising of bribes or any benefit to a public official where the intention is to influence that person's conduct or decision-making in order to obtain or retain business. Under the corporate policy of the Company Bajir, the term “public official” is interpreted broadly and includes:

• any elected or appointed official of public administration (e.g. an employee of the Ministry of Health);
• any employee or person acting for or on behalf of an official of public administration, or of a body or entity performing public administration functions;
• any political party, candidate for public office, functionary, employee or person acting on behalf of a political party or a candidate for public office;
• any employee of a public international organisation or a person acting on behalf of such an organisation.

The term “public” covers all levels and branches of public administration (i.e. local, regional and national level and the judicial, legislative or executive branch). Given that this definition of a “public official” is very broad, business partners are likely to deal with public officials in the course of their ordinary business activities for the Company Bajir. For example, doctors employed in public hospitals may be regarded as “public officials” under these principles of the Company Bajir.

Anti-corruption principles governing dealings with authorities and public officials

In connection with work performed for the Company Bajir, employees must not directly or indirectly give or offer any bribe or any benefit to any public official, nor authorise such giving, where the purpose is to persuade that person to take any official action or adopt a decision that would help the Company Bajir obtain or retain business. Employees must not give or offer a public official any payment, gift or benefit, regardless of its value, where the purpose is to induce that public official to approve, reimburse, prescribe or purchase products of the Company Bajir, to influence the results of clinical trials, or to take other inappropriate steps in favour of the business activities of the Company Bajir.

Employees are informed by the Company Bajir whether local laws and directives or operating procedures (including requirements imposed by public institutions such as state hospitals or research institutions) set any limits, restrictions or disclosure obligations regarding the provision of compensation, financial support, contributions or gifts to public officials. When carrying out activities for the Company Bajir, employees are obliged to take note of and comply with any applicable restrictions. If an employee is unsure of the meaning or applicability of any limit, restriction or disclosure requirement in connection with dealings with public officials, they must consult the relevant contact person at the Company Bajir before taking the step in question.

In connection with work performed for the Company Bajir, employees are not permitted to make so-called “facilitation payments”. These are primarily minor unofficial payments to public officials in order to secure or speed up the performance of routine activities that do not involve discretion. Examples of facilitation payments include payments to speed up proceedings for the issue of licences, permits or visas where the relevant application has been duly filed. If, in connection with work performed for the Company Bajir, an employee receives or learns of a request for a facilitation payment or a bribe, they must report such a request to the relevant contact person at the Company Bajir before taking any further steps.

Bribery in the private sector

Bribery and corruption may also arise in private business relationships. Most countries, including the Czech Republic, have adopted legislation prohibiting the giving, offering, soliciting, accepting or authorising of payments or any benefit in order to obtain an improper business advantage. Examples of prohibited conduct include, among others, the provision of improper gifts or hospitality, or the provision of a business opportunity where the intention is to induce a person to purchase goods or services.

In connection with work performed for the Company Bajir, employees are not permitted to offer, give, solicit or accept bribes, and the business partners of the Company Bajir and persons acting on their behalf are expected to observe the same principles in connection with work performed for the Company Bajir.

Anti-corruption principles governing dealings with private persons and employees of the Company Bajir

In connection with work performed for the Company Bajir, employees must not directly or indirectly give or offer any bribe or benefit to any person, nor authorise such giving, where the purpose is to persuade that person to provide the Company Bajir with an unlawful business advantage.

In connection with work performed for the Company Bajir, employees must not directly or indirectly solicit, agree to accept or accept any payment or benefit where the purpose is the improper approval of business activities carried out for the Company Bajir.

Employees are not permitted to accept from business partners or persons acting on their behalf, in connection with work performed for the Company Bajir, any gifts, services, benefits, entertainment or other consideration exceeding a symbolic or negligible monetary value. Gifts of negligible value are moreover permitted only if they are accepted infrequently and only on appropriate occasions.

Reporting potential and actual breaches

We expect our business partners and persons acting on their behalf, in connection with work performed for the Company Bajir, to report potential breaches of these anti-corruption principles of the Company Bajir. Business partners may submit such reports to the contact person at the Company Bajir, by e-mail to info@bajir.cz or by telephone at +420 734 855 974.

Pharmacovigilance (reporting of adverse events)

In carrying out its activities, the Company Bajir follows the principles for reporting adverse events in connection with the products of its clients.

Adverse event

An adverse event means any unfavourable change in the state of health affecting a patient or a clinical trial subject receiving a medicinal product, which need not necessarily be causally related to treatment with that product. An adverse event may therefore be any unfavourable and unintended manifestation or sign (e.g. an abnormal laboratory test result), symptom or disease temporarily associated with the use of the product, regardless of whether a causal relationship with the product is presumed.

The same procedure as for reporting adverse events applies to all cases of drug interactions, exposure to the product during pregnancy (through the mother or the father, with or without an outcome), use of the product during lactation or breastfeeding, lack of efficacy, overdose, abuse and misuse of the product, incorrect administration of the product or accidental exposure to it, and dispensing errors of which the Company Bajir may become aware, even where no adverse event has been reported.

Obligations of the Company Bajir

• If the Company Bajir becomes aware of an adverse event in a patient using a product or products of a client, it undertakes to report that event to the client within twenty-four hours of becoming aware of it, regardless of whether it or the person who reported the event has assessed a causal relationship between the client's product and the adverse event. Upon receiving a report of an adverse event, the Company Bajir undertakes to obtain and pass on to the client as much information about it as possible.
• The Company Bajir duly and regularly (at least once a year) trains all employees in the reporting of adverse events. The Company Bajir keeps records of such training and, upon request, sends them to the client in electronic form.
• The Company Bajir undertakes to retain records of adverse event reports sent to the client, both during the cooperation with the client and for a reasonable period after its termination. Upon the client's request, the Company Bajir will send these records in electronic form.
• Upon the client's request, the Company Bajir provides cooperation in the regular internal reconciliation between adverse events reported by the Company Bajir in a given period and adverse events recorded by the client as received from the Company Bajir. Such cooperation may include, in particular, confirmation of the adverse event reports sent to the client during a given period.

Obligations of employees

• It is the employee's duty to attend regular training on the reporting of adverse events.
• Employees are obliged to report all adverse events without delay to their direct superior or to the executive director of the Company Bajir and to cooperate with them in obtaining as much information as possible about the adverse event.
• The direct superior or the executive director of the Company Bajir shall ensure that adverse events are reported to the client in accordance with Article III. 2. of this Code of Ethics.

Responsible use of resources

The Company Bajir complies with all applicable environmental protection legislation and minimises adverse environmental impacts in all its activities. To the greatest extent possible, it provides its services using sustainable resources (i.e. from eco-labelled, recycled or renewable energy sources). In the area of responsible use of resources, the Company Bajir further:

• Has rules in place to ensure the safe handling, movement, storage, disposal, recycling, reuse or management of raw materials, waste and emissions.
• Continuously sets environmental targets focused on reducing the environmental impact of the services provided. It evaluates the targets on an ongoing basis.
• Actively applies and updates the targets in interaction with its customers and business partners.

Final provisions

• The Company Bajir continuously monitors whether employees fulfil the obligations set out in this Code of Ethics.
• Failure by employees to comply with this Code of Ethics is regarded as a breach of obligations arising from the legislation applicable to the work performed, with the consequences laid down in the Labour Code.
• Employees will be made familiar with this Code of Ethics no later than 15 days after it is issued.
• This Code of Ethics takes effect on 1 January 2024 and is issued for an indefinite period.