Sustainability Report 2012 Lek d.d.

53 Human rights and antitrust compliance 5. Human rights and antitrust compliance The business operations of Lek, a Sandoz company, are si- gnificantly marked by the company's commitment to ethical and accountable decision making as stated in our Code of Conduct, our key document regulating our social and envi- ronmental responsibility and our compliance with the regula- tions and Good Business Practice. 75 It provides a basis for the trust of our key stakeholders (patients, employees, sha- reholders, healthcare partners and society at large). In 2012, we organized for all our employees online training on the Code of Conduct which had been upgraded the year before to meet employees' requirements better. They were given the opportunity to refresh their knowledge of fully transparent and clear principles and to confirm their implementation in every- day operations. Together with our policies and guidelines, the Code of Conduct provides guidance for all our employees since any violation of its rules may severely damage the company's reputation. In order to prevent corruption and to ensure legal complian- ce, we follow Novartis' global initiative regulating this area. In 2012, we adopted a new global anti-bribery policy, updating the Third-Party Guidelines requiring our business partners to comply with and to implement the ethical business standards and compliance principles binding on the Novartis employees and its companies. We treat our employees equally, with integrity and respect, thereby creating an inclusive working environment to which every employee can fully contribute regardless of their ethnic origin. We expect our employees to demonstrate respect towards each other and to avoid any form of harassment or discriminatory behavior. Individual diversity and personal cha- racteristics of our employees constitute an asset and strength of our company, and are s source of our teams' creativity. They serve as a link between the company, patients and cu- stomers. We firmly believe that they are a basis for mutual understanding and successful business performance. In parti- cular, the Code of Conduct prohibits any form of discrimination on the basis of personal employee characteristics such as ci- tizenship, gender, age, nationality, religion, sexual orientation or disability. The highly inclusive working environment is also created through the implementation of the Diversity and In- clusion initiative which significantly outgrew Novartis' original female inclusion initiative. Lek d.d. refuses any form of child, bonded or forced labor. In 2012, there were no cases of discrimination and no reque- sts to remedy any violation in this area in Slovenia. 76 In 2012, the company was not involved in any antitrust proce- dure for any violation of antitrust regulations. 77 75 Disclosure GRI 4.8 76 GRI Indicator HR4 77 GRI Indicator SO7