Anti-Bribery and Corruption (ABAC) Statement

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Rafarm is committed to upholding the highest ethical standards, recognizing that transparency and accountability are essential for maintaining trust.

We maintain a zero tolerance policy towards corruption and firmly reject all forms of corrupt business behavior, including bribery (public, private, active or passive), embezzlement, fraud, money laundering and other improper payments. To prevent and detect bribery and corruption we implement comprehensive policies, conduct third – party due diligence, perform risk assessments and provide training to enhance employee awareness.

These principles are duly notified and apply globally to all public and private business transactions involving Rafarm.

Supplier Code of Conduct

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This Supplier Code of Conduct defines the basic requirements to meet our standards, placed on any person or entity doing business with Rafarm providing goods/services, whether directly or indirectly, with respect to its responsibilities towards its stakeholders, employees, business partners and the environment.

The Rafarm Supplier Code of Conduct is based upon the principles of the United Nations Global Compact (UNGC), United Nations Guiding Principles on Business and Human Rights, Universal Declaration on Human Rights, Declaration of Elsinki, International Labour Standards drawn up by the International Labour Organisation’s constituents and of other relevant organizations and initiatives.

The principles expressed in this Supplier Code of Conduct comprise an important component of supplier selection and evaluation. Moreover, we expect our suppliers to replicate these standards further down the supply chain. Supplier includes any third party that provides goods/services to us, whether directly or indirectly, and such third party’s agents or subcontractors (we expect that this Supplier Code of Conduct applies in full also to each of their respective agents or subcontractors).

If a supplier is in breach of these principles and cannot agree on an improvement plan or does not implement it, Rafarm reserves the right to redetermine the continuation of the commercial relationship.

ETHICS/ LEGAL COMPLIANCE
Suppliers are required (as applicable):

to comply with applicable laws, regulations, standards, directives, guidelines and relevant customer requirements
to train and educate their employees, so as for them to make ethical decisions, in compliance with such laws and regulations
not to practice or tolerate any form of corruption, extortion, embezzlement or money laundering
not to offer or accept bribes or other unlawful incentives, including financial or other advantages (such as gifts, loans, rewards, ‘facilitation payments” etc.) to or from their business partners (including offering bribes to Rafarm’s employees) or/and government officials
to encourage employees to report concerns or illegal activities in the workplace without threat of reprisal, intimidation or harassment
to disclose to Rafarm any situation that could constitute a conflict of interest. A conflict of interest occurs whenever the prospect of direct or indirect personal gain may influence or appear to influence Supplier’s judgement or actions while conducting Rafarm
to notify Rafarm of legal actions, administrative investigations or prosecutions that may affect their performance of Rafarm’s business or that could potentially harm Supplier’s and Rafarm’s reputation
to conduct their business in line with the principles of fair competition and in accordance with all applicable anti-trust laws
not to offer or provide anything to healthcare professionals (HCPs) and healthcare organisations (HCOs) in a way that has an inappropriate influence on prescribing practice or that could be seen as an inducement to prescribe. Interactions with HCPs and HCOs are intended to enhance the practice of medicine and benefit patients
to conduct clinical trials in accordance with international guidelines, applicable national/ local legislation and international quality and safety standards
to deliver goods and /or services in good faith and in accordance with agreed contractual terms and conditions, as well as industry practices
not to claim to represent, or to operate on behalf of, Rafarm in any way, without prior written approval

CONFIDENTIALITY, PERSONAL DATA & INTELLECTUAL PROPERTY RIGHTS
Suppliers are required:

not to communicate externally about Rafarm’s or Rafarm affiliated companies’ performance, prospects or operations
to refrain from making any public posting of confidential or proprietary information related to any aspect of Rafarm’s or its affiliated companies’ business
to process personal data related to Rafarm or its affiliated companies only for legitimate business purposes in a transparent and secure manner according to applicable legislation and regulations including GDPR (where applicable) and protect it, by implementing security policies (both technical and organizational) and take reasonable steps to stay current. Supplier’s information systems that contain personal data of data subjects connected to Rafarm (workers, patients etc), shall be equipped by systems and procedures in a manner so as such information are protected against unauthorized access, use, disclosure, modification or destruction. Suppliers shall be responsible towards Rafarm for traceability of any such personal data and shall be responsible to ensure the security of any records kept. Any actual or potential data breach shall be reported to Rafarm. If you are interested in how Rafarm treats your personal data please visit https://www.rafarmgroup.gr/business-associates-privacy/
not to use Rafarm’s name or trademarks or that of Rafarm’s affiliated companies or products without Rafarm’s prior written consent
to ensure that any intellectual property rights are not violated and used in accordance with the pre-agreed terms and conditions
to use both technical and organizational measures, in protecting such data, intellectual property and confidential information disclosed to them by Rafarm, against accidental, unauthorized or unlawful, destruction, alteration, disclosure, use or access.

LABOUR
Suppliers are required:

to recognize the right of employees to work freely and by own will
not to use forced, bonded or indentured labour or involuntary prison labour
to comply with minimum working age requirements prescribed by national laws and international agreements
to promote equal opportunities for and treatment of their employees irrespective of gender, age, skin colour, race, nationality, social background, family status, pregnancy, disabilities, sexual orientation, religion, political affiliation, union membership or any unlawful criterion under applicable law
to respect the personal dignity, privacy and rights of each individual
to refuse to tolerate any unacceptable treatment of employees, such as mental or physical cruelty, verbal abuse, sexual harassment, sexual abuse or threat of any such treatment
to provide fair remuneration and guarantee the applicable national statutory minimum wage
to comply with the applicable law and sector-specific labour regulations concerning working time, including overtime laws
to respect the rights of their employees to associate freely, form and join labour unions, seek representation, join work councils and engage in collective bargaining

HEALTH & SAFETY
Suppliers are required:

to make adequate provision for the health and safety of their employees, customers, visitors, contractors, residents of the community and others that may be affected by their activities
to control hazards and take the best reasonably possible precautionary measures against accidents and occupational diseases
to set up or use a reasonable occupational health & safety management system for maintaining all their production processes in accordance with the applicable safety standards
to offer regular and recorded health and safety training to all workers. Safety information relating to hazardous materials- including pharmaceutical compounds and pharmaceutical intermediate materials- shall be available to educate, train and protect workers from hazards

ENVIROMENT
Suppliers are required:

to act in accordance with applicable statutory and international standards regarding environmental protection
to be able to demonstrate compliance with applicable laws on environmental protection and have all the relevant and valid permits
to minimize environmental pollution and make continuous improvements in environmental protection

MANAGEMENT SYSTEMS
Suppliers are required:

to demonstrate commitment to the concepts described in this document by allocating appropriate resources
to maintain documentation necessary to demonstrate conformance with these expectations and compliance with applicable regulations
to have mechanisms to determine and manage risks in all areas addressed by this document
to have a training program that achieves an appropriate level of knowledge, skills and abilities in management and workers to address these expectations
to promote compliance with this CoC among their suppliers/ customers/ business partners, as appropriate

NOTIFICATION OF INCIDENTS

Suppliers must notify Rafarm of identified incidents and violations of this Code of Conduct within 24 hours via confidential reporting to supplier.compliance@rafarm.gr .