Sustainability Report 2014 Lek d.d.

61 Human rights and antitrust compliance 5. Human rights and antitrust compliance 89 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 Conduct regulates our corporate and environmental responsibility and our compliance with the re- gulations 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 2014 we once again organized online training on the Code of Conduct for all our employees and achieved 99% par- ticipation. Nearly all employees refreshed their knowledge about the fully transparent and clear principles and to con- firm their implementation in daily 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. 90 In order to prevent corruption and to ensure legal complian- ce, 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 eth- nic origin. In particular, the Code of Conduct prohibits any form of discrimination on the basis of personal employee characteristics such as citizenship, gender, age, nationali- ty, religion, sexual orientation or disability. The individual diversity and personal characteristics of our employees con- stitute an asset and the 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, forced or compulsory labour. In 2014, there were no cases of discrimination and no re- quests to remedy any violation in this area in Slovenia. 91 The company was also not involved in any antitrust proce- dure for any violation of antitrust regulations. 92 89 GRI Disclosure G4-56, GRI Indicator G4-DMA 90 GRI Indicator G4-HR2 91 GRI Indicator G4-HR3 92 GRI Indicator G4-SO7 Our Code of Conduct Everyone Everyday Everywhere Our Code of Conduct – At the heart of our performance Take part in our success. Visit www.our code of conduct .novartis.intra GIC005.V2.SI

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