Sustainability Report 2013 Lek d.d.

Sustainability Report 2013 – Lek d.d. Products / Human rights and antitrust compliance 58 5. Human rights and antitrust compliance 90 The business operations of Lek, a Sandoz company, are significantly characterized by the Code of Conduct, which defines the principles of ethical and accountable decision-making. The Code of Conducts regulates our corporate and environmental responsibility and our com- pliance with the regulations and Good Business Practice. It provides a basis for the trust of our key stakeholders (patients,employees, shareholders, healthcare partners and society at large. In the area of compliance of our operations, much attention is paid to regular and ongoing training of our employees. In 2013 we once again organized online training on the Code of Conduct for all our employees and achieved 99.7% participa- tion. Nearly all employees refreshed their knowledge about 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. 91 In order to prevent corruption and to ensure legal compli- ance, we follow Novartis' global policy regulating this area, and our internal rules. Standards apply also in relations with Third Parties. Based on the Third-Party Guidelines, we establish and maintain business relations with our business partners who comply with and implement the same ethical business standards and compliance principles that are binding on the Novartis employees. 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. In particular, the Code of Conduct prohibits any form of discrimination on the basis of personal employee charac- teristics such as citizenship, gender, age, nationality, religion, sexual orientation or disability. The individual diversity and personal characteristics of our employees constitute an as- set and strength of our company, and are the source of our teams' creativity. The highly inclusive working environment is also created through the implementation of the Diversity and Inclusion initiative which has significantly outgrown Novartis' original female inclusion initiative. Lek, a Sandoz company, refuses any form of child, bonded or forced labour. In 2013, there were no cases of discrimination and no re- quests to remedy any violation in this area in Slovenia. 92 In 2013, the company was not involved in any antitrust procedure for any violation of antitrust regulations. 93 89 GRI Indicator G4-PR7 90 GRI Disclosure G4-56, G4-DMA 91 GRI Indicator G4-HR2 92 GRI Indicator G4-HR3 93 GRI Indicator G4-SO7 Adherence to laws, standards, and voluntary codes related tomarketingcommunications, includingadvertis- ing, promotion, and sponsorship 89 In drug advertising we act in accordance with the Rules on Advertising of Medicines (OG., RS 105/ 2008, 105/ 2010, consolidated text, effective from 8 January 2011) and with the internal SP3 – Promotional Practices Policy. Conformity of conduct is verified on a daily basis by previous approval of all promotional activities. In 2013, there were no cases of violations of marketing com- munication rules, standards and non-binding codes, including those related to advertising, promotion and sponsorship. The JAZMP instituted no procedures for any drug advertising in violation of the Promotional Practices Rules. There was no sponsorship involving drug promotion. In corporate sponsor- ship, there were no non-compliance cases. Lek stars Also in 2013 we selected the best associates who in the previous year stood out due to their values, conduct, knowl- edge transfer and driving diversity and inclusion. 17 indivi- duals received this acknowledgement this year, 6 awards were given for outstanding business achievements and innovation, leading breakthrough, leading solution and for the first time also for the leading manager. The community of Lek`s Stars has increased by 40 excep- tional associates. Associates who are an example to others, awarded The supply launching team was awarded in the Outstanding Business Achievements category.