Anti Bribery Corruption Policy

1. POLICY STATEMENT

It is Almac’s policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and to implementing and enforcing effective systems to counter bribery. This Third-Party Anti-Corruption and Bribery Policy (the “Policy”) represents the minimum standards that Almac has set. It aligns with the requirements of applicable laws, and suppliers who wish to work with Almac must agree to the terms of this Policy.

2. COMPLIANCE WITH ANTI-CORRUPTION AND BRIBERY LAWS

We take our legal responsibilities very seriously. Almac is bound to comply with the laws of all the places in which it does business, including but not limited to the UK (which includes the Bribery Act 2010) and the US (which includes the Foreign Corrupt Practices Act 1977). Almac may be liable for the third parties we engage to perform services by or on our behalf (“Suppliers”) if they act contrary to these laws. In some cases, local laws and regulations that apply to the activities described in this Policy may be more restrictive than this Policy. Where that is the case, the more restrictive rules must be followed.

3. ENSURING COMPLIANCE BY SUPPLIERS

This Policy applies to any third-party Suppliers who are providing goods and/ or services to Almac. Almac is committed to working only with Suppliers who embrace standards of ethical behaviour that are consistent with its own. All Suppliers who receive a copy of this Policy are required to adhere to its principles.

4. POLICY AND CONTROLS

The Board of Directors of Almac has overall responsibility for the effective operation of this Policy, assisted by Almac’s Corporate & Legal Affairs team (“Almac Legal”). This Policy is reviewed regularly. Suppliers (or those acting on their behalf) must not:

5. INVESTIGATIONS, PROCEEDINGS AND ONGOING TRAINING

Suppliers must implement a process whereby incidents are reported to Almac, investigated and recorded quickly and appropriately. Any recommended remedial actions must be fully implemented. If reasonably requested by Almac, Suppliers should update Almac as to the remedial actions taken in response to any incidents of bribery or corruption (or potential incidents of bribery or corruption) which have been identified. Suppliers must carry out appropriate training in respect of anti-bribery and anti-corruption on an ongoing basis and ensure that those acting on a Supplier’s behalf are aware of such Supplier’s obligations under this Policy. Almac will seek to support Suppliers who raise genuine concerns under this Policy, even if they turn out to be mistaken. Almac is committed to ensuring that no-one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place or may take place. We may terminate our working relationship with Suppliers if they breach this Policy.

If you are unsure whether a particular act constitutes bribery or corruption, or if you have any queries on this Policy, please contact Almac Legal at [email protected] and include the subject line Re: Supplier Anti-Bribery Policy.