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Operating to the highest ethical standards

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Operating to the highest ethical standards

 
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Following ethical business practices is essential to the success of our organisation and to ensuring that we continue to be regarded as a trusted business partner. This commitment to ethical business is firmly embedded within our organisation’s culture, is endorsed by our Board of Directors and Senior Executive Leadership Team and flows throughout our organisation.

The robust policies and procedures which we have in place ensure that we maintain the highest ethical standards in our day-to-day business activities. These policies cover matters such as antibribery and corruption, human rights, anti-slavery and human trafficking, conflicts of interest, fraud prevention, money laundering, fair competition, trade compliance and global data privacy.

Our Employee Code of Ethics signposts our employees to the relevant policies which are in place, as well as underlining our commitment to doing business ethically. It provides guidance to help employees make good ethical decisions and ensures that we act responsibly when engaging with our customers, suppliers and other stakeholders.

Ethics Training

To help ensure that our policies operate effectively, we provide relevant training for our employees. Training on ethics forms part of the induction process for all new staff members. Training on topics which are relevant to specific business functions or business roles is provided on an ongoing basis.

Training on our Employee Code of Ethics helps our employees to understand the importance of doing business ethically, explains how employees can raise concerns when they arise and outlines the consequences of potential misconduct.

Ethics Training

Speaking up

As part of our commitment to doing business the right way, we believe it is important that our employees are able to speak up and raise issues concerning any potentially unethical or illegal conduct. This gives us an opportunity to work to resolve any such issues, which we believe ultimately protects our employees and organisation from harm.

Employees are encouraged to raise concerns with their line manager and, in addition, we have implemented a whistleblowing policy which explains how employees can use our dedicated whistleblowing line to raise concerns confidentially and, if they wish, anonymously. Any concerns raised are taken seriously and investigated in a professional and fair manner. We recognise that it takes courage to speak up and we are committed to ensuring that anyone who raises a concern is adequately protected.

Speaking up

Responsible Sourcing

Our supply chain plays a critical role in ensuring we can deliver on the expectations of our customers to the highest possible standards and we will only work with suppliers who share our values and commitments. Our sustainable procurement programme outlines how we will engage and monitor our supply base. The key objectives of our programme are as follows:

  • To align the procurement strategy with Almac’s overall sustainability goals and vision.
  • To reduce the environmental, social, and economic impacts of Almac’s procurement activities.
  • To ensure fair and ethical practices in the supply chain, such as respecting human rights, labour standards, and diversity.
  • To create value by improving operational efficiency, reducing costs, enhancing reputation, and mitigating risks.

We adopt a whole life cycle cost modelling approach to our sourcing activity and sustainability is an input factor, addressing ethical, environmental and social considerations to underpin commercial and quality requirements.

Sustainability training is currently being rolled out throughout all Procurement Departments within Almac Business Units. All procurement staff actively work with their suppliers to educate and set expectations that are aligned with Almac’s sustainability goals.

As well as our environmental engagement with our suppliers outlined in the ‘planet’ section, Almac’s sustainable procurement programme is built on a further two pillars:

Social

Our Supplier Diversity programme has evolved this year with the establishment of a baseline position regarding the current diversity status of our US based supply chain. Following our initial reach-out to a proportion of our US suppliers on their diversity status, we will continue to engage with those suppliers that have not responded to us as well as extending the questionnaire to the remainder of our US supply base.

Governance

As a part of our approach, we have introduced a robust Supplier Code of Conduct which sets out our expectations in terms of:

  • Business integrity.
  • Labour and human rights.
  • Environmental and health and safety practices.
  • Management systems.
  • Transparency and reporting.

The Code of Conduct is a mandatory requirement for all existing and new suppliers. This code has been integrated into supplier agreements and suppliers are responsible for ensuring that they comply with the principles, and that any third parties engaged by them also apply the same principles. Our Vendor Registration Form incorporates our Supplier Code of Conduct and other Almac policies and no supplier will be approved by Almac unless they are fully aligned to our Code.

In terms of ethics, it is our expectation that anyone who provides services to Almac shares our values and our commitment to the highest ethical standards. We require our suppliers to strictly adhere to all applicable laws and regulations in the jurisdictions in which they are based, including laws addressing anti-corruption and bribery. We plan to roll this out across our wider supply base in due course and it will ultimately form part of our supplier qualification and onboarding process.

Code of Conduct and Due Diligence

As a key part of our approach, we have introduced a robust Supplier Code of Conduct which sets out our expectations in terms of:  

  • Business integrity  
  • Labour and human rights  
  • Environmental and health and safety practices
  • Management systems  
  • Transparency and reporting. 

The Code of Conduct is a mandatory requirement for all new suppliers. 

This code has been integrated into supplier agreements and suppliers are responsible for ensuring that they comply with the principles, and that any third parties engaged by them also apply the same principles. Our New Vendor Registration Form incorporates our Supplier Code of Conduct and other key Almac policies and no supplier will be approved in Almac unless they are fully aligned to our Code. 

This year , alongside our Code of Conduct, we issued a Supplier Due Diligence Questionnaire in the form of a Request for Information – approaching our key strategic suppliers initially. This questionnaire will provide data on key topics such as ethics, net zero targets, decarbonisation and supplier diversity. In terms of ethics, it is our expectation that anyone who provides services to Almac shares our values and our commitment to the highest ethical standards. We require our suppliers to strictly adhere to all applicable laws and regulations in the jurisdictions in which they are based, including laws addressing Anti-Corruption and Bribery. We plan to roll this out across our wider supply base in due course and it will ultimately form part of our supplier qualification & onboarding process. 

We are currently establishing a baseline measurement of our Scope 3 emissions and will continue regularly engaging with our supply chain on our expectations for reductions, transparency and reporting going forward. For further detail on our Scope 3 approach please see the planet section of this report.  

Code of Conduct and Due Diligence

Cybersecurity

At Almac, we prioritise the protection of our business, customers, and the highly sensitive information entrusted to us through a comprehensive cybersecurity programme. We are proud to have successfully achieved the ISO/IEC 27001:2022 standard – an internationally recognised framework for managing information security risks. This certification covers enhanced controls for cloud security, threat intelligence, and business continuity readiness, aligning our Information Security Management System (ISMS) with the latest global best practices.

Our ISMS is designed to encompass people, processes, and technology, and is governed by a robust policy framework that ensures the confidentiality, integrity, and availability of our systems and data. Independent audits validate our ongoing compliance with ISO 27001.

We require all employees, third-party data processors, and suppliers to comply with our cybersecurity policies and procedures. In 2025, all Almac staff members were provided with refresher training in data security awareness, reinforcing our commitment to a security-aware culture.

Our cybersecurity strategy focuses on three key pillars:

  • Prevent, Detect, and Respond: We partner with a leading security services provider to deliver 24/7/365 monitoring, detection, and automated response capabilities. Advanced tools and techniques are used to prevent, contain, and isolate potential cyber threats.
  • Advise and Inform: We implement robust policies, a secure software development lifecycle, and system designs that reflect the latest cybersecurity approaches. Regular internal assessments and audits help us identify and address vulnerabilities.
  • Assure: Our Information Services team works closely with all employees to ensure continuous compliance and improvement. We invest significantly in end-user data security awareness training, which is refreshed annually and reinforced through phishing simulations and ongoing communications.

Our cybersecurity programme reflects our commitment to safeguarding the trust and confidence of our customers. We continuously strive to improve our programme through strategic infrastructure investment and identifying opportunities to protect and enhance Almac’s systems, staying ahead of the ever-evolving cyber landscape.

Artificial Intelligence governance

Almac has implemented a comprehensive AI governance framework to ensure the ethical, secure, and compliant use of artificial intelligence across its global operations. Governance is overseen by the Board of Directors and a cross-functional AI Council. The framework includes strict acceptable use policies, mandatory training, and continuous monitoring to safeguard against misuse. This governance model reflects Almac’s commitment to responsible innovation, operational excellence, and trust.

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