The Code of Business Conduct and all relevant corporate policies apply to anyone who conducts business on behalf of NC Pharm Logistic, including the management team, and all persons involved in the affairs of the Company.

In exceptional situations where an employee can deviate from the Company’s requirements, this deviation must be approved by an authorized manager.


Each of us is responsible for respecting the values and rules of behavior set out in this Code of Conduct, complying with relevant policies of the Company, and raising questions in the presence of doubts about compliance or non-compliance of standards. Violation of the Code can lead to the adoption of corrective measures, and in some cases, to administrative penalties, including dismissal of an employee.


We believe that all of our stakeholders have the right to learn about our business practices.

This document is publicly available.


No manual – no matter how detailed it is – can foresee all the difficulties that we may face at work. There are additional resources for this purpose that we can use when business ethics-related issues arise.

This document serves as a guideline reflecting our standards, including frequently asked questions, and does not purport to be a complete description of the Company’s policies and standards.

If your questions are not fully covered in this document, you can discuss all the questions with the manager. You also can use other resources, including experts in the law, finance, corporate audit, and HR Department.



Information provided to our consumers about products and services, including their availability and supply, must be useful, accurate, evidence-based as applicable, and presented using honest, fair and appropriate means.


Gift giving

We believe in the completion that is based on the values of our products and services, and we want to avoid even the slightest hint of unethical behavior with our customers. Giving gifts to customers in cash or non-cash form, including services, raises serious questions related to a conflict of interest or apparent manifestation of conflict of interest. Therefore, gist giving is prohibited unless otherwise specified in the specific exceptions below. We recognize that some cultures have a tradition of giving gifts and expect the same from the other party. Decisions regarding such situations must be carefully weighed. Before taking any steps, you need to obtain permission from your manager.

Government officials: Gifts, invitations to restaurants and receptions, or other benefits

Gist giving, invitation to a restaurant or reception, payments of honoraria for attending a congress or symposium, or providing other similar benefits to government officials requires further evaluation to avoid any undue payment or benefit. Moreover, the Company strives to avoid even the semblance of violation of rules.

Therefore, before presenting a gift, making an invitation somewhere or providing any other benefits, consult the managers.

Catering and hospitality

We may provide meals or arrange receptions in the following cases:

• To maintain an honest business relationship,

• As a part of a training or business event,

• If it is legal,

• If it complies with the terms of the industrial codes,

• If it complies with the Company’s policies and procedures,

• If this is not perceived as an attempt to unfairly influence business decisions,

• If this does not place the company in an uncomfortable situation in case of drawing public attention to the event.


We believe that a fair, free and open market is generally beneficial for buyers and society. Therefore, we support competition that is based on the essential values of our products and services, and do not enter into agreements with competitors to “set” prices or, conversely, to restrict trade. Our principles of fair competition require the following:

• We do not negotiate or exchange pricing and bidding information with our competitors. This includes pricing, discounts, promotions, license fees, warranties, and terms and conditions of sale.

If a competitor insists on providing such information, be it a trade and industrial meeting or other case, we should immediately interrupt the conversation and bring the situation to the attention of the Legal Department. Despite the fact that the exchange of information bore no ill will, it can create the semblance of price fixing or bid rigging.

• We are actively competing in every market for every customer. We do not make agreements or share common understandings with competitors regarding buyers, distributors or regions.

• We do not criticize or misrepresent competitors’ products or services. Our rules of fair competition are also consistent with the letter of the law. There are also additional legal requirements that we must comply with. Every supervisor must ensure that marketing, sales and purchasing personnel are aware of the content and spirit of our standards and applicable competition laws.

Collecting information about competitors

We compete fairly and justly. We do not collect market information through misrepresentation, theft, invasion of privacy or by enforcement.

Generally, you can obtain competitor information from legitimate sources such as buyers, consultants, and even competitors themselves, under the appropriate conditions. For example, you may collect information about competitors (1) from news or public resources such as financial statements submitted by relevant regulatory authorities, (2) by researching competitor products and policies available in promotional materials, (3) from competitors’ consumers (provided that they have the right to disclose information about competitors), or (4) through the information about competitors presented at conferences and trade shows.

• Do not encourage employees who have previously worked with our customers or competitors to violate contracts or non-disclosure obligations, respecting internal company information. Since it is difficult to know exactly what nondisclosure commitments have been made, we strongly

discourage anyone who has previously worked with competitors to provide information about their former employer.

Do not allow your employees or marketing consultants to misrepresent yourself or your work when collecting competitor information.

• Do not accept pricing or other proprietary information directly from a competitor.


We believe it is extremely important to respect privacy of all people who work with us. This issue, in particular, affects our customers and contractors.

Our personal privacy commitment is based on several core principles of operation, including:

Principle of necessity – We must define the business purpose for which personal information is used and collected, and where possible, use non-identifiable information.

Notification and choice– We must provide appropriate notice before collecting personal information. In addition, we generally must provide these individuals with the right to object or refuse the use of their personal information.

Data reliability – The stored personal information must be true, complete and up-to-date in accordance with the terms of the agreements and guidelines.

Security and transfer of information – We must take reasonable steps to protect personal information from loss, misuse, and unauthorized access, disclosure or alteration. . We must comply with all legal requirements in addition to our own regulations.



We strive to create a positive working environment to attract and retain talented people and unleash their full potential. Each of us has a responsibility to build trust and respect and maintain a productive working environment. We maintain open communication, listen to the ideas and concerns of others, provide and receive feedback in a constructive manner.

Confidentiality of employee data

We respect the personal privacy and dignity of our employees and guarantee the confidentiality of their personal information. The Company collects and stores personal data to perform such functions as providing benefits, compensation and wages, as well as for other purposes in accordance with privacy laws and regulations. We will protect information on the employee’s personal life and will only use it for lawful purposes and within applicable laws. This obligation to maintain the confidentiality of personal information continues after an employee leaves the Company and extends to former employees. Respect for the confidentiality of employee communications, as well as the use of e-mail and the Intranet/Internet, are dictated by relevant business and production needs and local laws. We are responsible for the use of e-mail, the Internet and other communications of the Company and must investigate any misuse in accordance with the laws. We follow the principle of necessity in fulfilling obligations regarding the confidentiality of personal information.


To meet our long-term growth and performance requirements, we must build an organization that is responsive to change and where all employees can reach their full potential. Diverse experience, education, perspectives and talents are a powerful foundation of our Company. We treat each person fairly and recruit, select, promote employees and pay for work depending on their merits, experience and other work criteria. Fair treatment also implies respecting the right of our colleagues to have a different viewpoint or disagree. Likewise, sometimes we are forced to accept a situation when management supervisors do not support our position. We must remember that open communication, including a willingness to “agree or disagree,” is important both for creating a positive working environment and for our overall commercial success.


In our work, we pay great attention to the health and safety of employees and the general population. Each of us must comply with safety rules and take the necessary precautions to protect ourselves and our colleagues. We must report all accidents and work-related injuries, and prevent safety violations, striving to continually improve productivity.

Drug and alcohol abuse

The use of drugs and the abuse of alcohol and legal drugs pose a serious threat to the health and safety of employees at work. It is forbidden to carry, sell, use or be under the influence of drugs during working hours, on the premises of the Company or at events held by the Company. It is also forbidden to be in a state of alcoholic intoxication while performing official duties or at events held by the Company. It is important to immediately inform supervisors about drug and alcohol abuse cases.


We strive to create a harassment-free working environment where all employees are respected. In many cases, workplace harassment takes the form of discrimination, which is usually defined as verbal or physical abuse directed at a person because of certain individual characteristics such as race, gender, age, or religious beliefs. Workplace harassment is usually interpreted as any action that inappropriately creates an environment of intimidation, hostility and aggression.

Expressions of violence at work

We strive to maintain respect for the dignity, safety and security of all our employees in the working environment, to make it fit for a fair job and free from all forms of violence. . We will not tolerate violence, threats, violent behavior, intimidation or any other form of workplace violence from anyone. By workplace violence we mean bullying and harassment with the intention of scaring a particular person and creating an environment of hostility and intimidation for them.

Sexual harassment

Sexual harassment is a form of workplace harassment that affects the self-esteem of men and women. Sexual harassment includes, but is not limited to, sexual demands in exchange for employment benefits, threats and behaviors that result in loss of benefits at work if sexual services are not provided or physical contact is denied. If you are harassed, tell the abuser that their actions are inappropriate. If you are uncomfortable with taking a direct approach, or if the problem is not resolved, discuss the matter with your supervisor.


We strive to employ people who can contribute to the Company’s success. We employ relatives and friends of our employees and welcome their recommendations. However, we do not favor candidates who are family members or friends of our employees. We recruit an employee for a vacant position based on his or her qualifications. Senior managers in particular should be aware that recommendations from family members or friends can be perceived as abuse of influence over the employment process, and should take appropriate action to avoid favoring a friend or relative as a candidate or influencing the employment process. To ensure objectivity and to prevent conflicts of interest, employees who are family members should not have direct or indirect reporting relationships. In rare cases where special circumstances require an exception to this policy, it is required to obtain prior approval from management.



We are responsible to our stakeholders for making decisions in strict accordance with the interests of the Company, regardless of personal problems. . A potential conflict of interest arises when we, directly or indirectly, engage in extraneous activities that could affect our manufacturing decisions. We must avoid situations where our commitment is divided or appears to be divided. Here are examples of real or potential conflicts of interest:

• Personal financial interest in a supplier, customer or competitor,

• An immediate family member (for example, a husband or a wife, civil partner, parent, parent of a husband or a wife, foster parent, brother or sister, brother or sister of a husband or a wife, stepbrother or sister, natural or adopted children of a husband or a wife or parent, brother, sister, or child of a civil partner) or any other person you consider to be a family member (such as a fiancé) working for a supplier, competitor or distributor,

• Receiving remuneration in any form from a supplier, competitor or distributor,

• Personal interest or opportunity to benefit from any transaction of the Company,

  • Working for the advisory board and/or board of directors of an association or company operating in the same market,
  • Employment of an employee/consultant through family ties with government decision-makers,
  • Secondary employment (paid or unpaid) in an organization competing with our Company.

The full disclosure of conflicts of interest is the key to their resolution. Very often, disclosing a potential conflict within a company is the only action required. . If you think you might have a potential conflict of interest, you should discuss the situation with your supervisor.


Our stakeholders have the right to expect proper management of company assets and their economical and efficient use. The general rule for everyone is to prohibit the use of the Company’s equipment and resources (with the exception of communications, see below) for personal purposes. However, sometimes it is allowed to use corporate resources for personal purposes. However, sometimes it is allowed to use corporate resources for personal purposes.


The Company encourages the rational and efficient use of communications such as e-mail, Internet and Intranet, voice mail, telephones, photocopiers and fax machines for production purposes. These tools also enable efficient personal activities; their use for this purpose is usually permitted, provided that the Company does not incur additional costs or that productivity in the workplace is not compromised.


The use of social media in business is becoming increasingly important, so we strive to maximize the opportunities provided by the new form of communication, while minimizing the risks and problems they pose. Blogs, social media (e.g. Twitter, Facebook, LinkedIn), editable Wiki pages, and YouTube are just a few examples of social media. We respect the right of our employees for using Internet, but we still need to remember to be liable for damage to our business or our reputation as a result of such activities, whether they occur during business or non-business hours.


Information is one of the important assets of the Company that must be protected. Leakage of confidential information can cause great damage to our competitive position. We do not disclose any confidential information of the Company without a grounded business reason and appropriate management permission. Each of us is responsible for protecting the confidential information of the Company.

General rules for the protection of confidential information of the Company:

• Do not openly discuss classified information of the Company,

• Use a password for computer files (and do not share it with other employees),

• Store sensitive information in lockable folders and cabinets,

• Store classified information in laptops during business trips,

• Take precautions when using a loudspeaker and a mobile phone,

• Finally, if you are unsure about the confidential nature of the information, consider it confidential.

Even after leaving the company, we are obliged to maintain the confidentiality of information and return all documents and files (including electronic ones).


We make decisions based on information that is kept at all levels. Incomplete or inaccurate information can lead to bad decisions and negative consequences, for example:

• Incorrect recording of income and expenses distorts the financial position of the Company and is illegal.

• Incomplete or inaccurate manufacturing documents can jeopardize product delivery and lead to violations of rules.


We are responsible for providing investors with information that reflects the true state of affairs. Therefore, all information provided to government authorities or made public must be complete, accurate, timely and understandable. This obligation applies to all employees, including financial executives, who are responsible for preparing reports, from preparing their drafts, checking and signing them to certifying the accuracy of any information they contain. We must speak openly about our activities, without compromising confidential information or information that belongs to the Company.



We select products and services that would contribute to the long-term prosperity of the Company. We select suppliers based on price, quality, supply, service, diversity, environmental practices and business practices. Our suppliers must meet key labor standards set by the International Labor Organization against child and forced labor.


Our supplier relationship is built on the basis of honesty and fairness. We adhere to the terms of supplier agreements and fulfill our obligations. We strive to pay on time and carefully guard confidential information and information owned by our suppliers. To enable all of our suppliers to compete, we accept competitive bids wherever possible.

Gift reception

To maintain good business etiquette, we may sometimes accept gifts, provided that:

• The gift has a nominal value (for example, pens, notebooks, calendars, etc.),

• Gift giving is legal,

• The gift is not intended or perceived by others as an attempt to influence our business decisions.

Sometimes there are situations when it would be impractical or difficult to refuse a gift. On such rare occasions, when a gift is of significant value, accept it on behalf of the Company, report it to your supervisor, and pass it on to your supervisor, the director, who will set its purpose.

Accepting invitations to a restaurant and other receptions

Our rules for accepting invitations to restaurants and various receptions are similar to our rules for granting them.

Sometimes it is allowed to accept invitations to a restaurant and other receptions in the following cases:

• To maintain an honest business relationship,

• As a part to a training or business event,

• If it is legal,

• If it complies with the terms of the industrial codes,

• If it complies with the Company’s policies and procedures,

• If this is not perceived as an attempt to unfairly influence business decisions,

• If this does not place the company in an uncomfortable situation in case of drawing public attention to the event.


Human rights

We believe in the dignity of every person and respect for individual rights. We are committed to the principles of respect for human rights as proclaimed by the United Nations Global Compact and as defined in the UN Universal Declaration of Human Rights and its Supplements, the International Covenant on Economic, Social and Cultural Rights, the International Covenant on Civil and Political Rights, the OECD Guidelines for Multinational Enterprises and core labor standards of the International Labor Organization, which we apply both in the workplace and more widely in our sphere of influence. We have adopted policies and management systems to comply with these principles.

When performing any kind of activity:

• We condemn forced labor and exploitation of child labor, and we expect our suppliers to respect this principle equally,

• We respect employees’ legal freedom of association,

• We pay our employees to meet their basic needs and provide them with opportunities to improve their skills and abilities,

• We make no distinction based on race, gender, age, religion or any other characteristic protected by law at all levels of the organization,

• We create a safe and healthy working environment.

These standards require respect for all people and the interests of all parties involved in our business. We also create a working environment that welcomes free discussion, respects the views of all employees, and encourages creativity and innovation.

Public relations

All public relations are potentially important and affect the image and activities of the Company. It is important that the information coming from the Company is consistent and that all regulatory and legal obligations are properly complied with. Any transferred information must be accurate, reliable and compliant with the Company’s policy in medical and legal matters. All communications from the mass media and the public should be directed and coordinated by management personnel.


To ensure the proper management, as well as the fair and impartial enforcement of laws, we must not promise, offer, or make monetary or any other material reward to any government officials or political parties with the intent of gaining or maintaining business opportunities, gaining unfair competitive advantage, or unduly influencing government decisions.

Compliance with laws, rules and regulations

Being a good corporate citizen means that we strive to comply with applicable laws, rules and regulations governing all aspects of our business. We work with all relevant regulatory authorities and comply with all regulatory requirements wherever we do business.

Political activity

As a corporate citizen, we undertake not to unfairly or illegally influence the political process in the communities where we operate.

We may participate in the political process as individuals, including assisting the candidates or parties chosen by us. However, we cannot use the time, property or resources of the Company for our personal political purposes.


We hire employees with outstanding personalities and judgments, in whose responsibility we are confident. However, there are times when we have to raise questions about behavior that we believe violates the values and standards of the Company. If you notice such behavior, it is your responsibility to discuss it with the relevant parties. This will enable the Company to review and resolve the problem. The reporting process is flexible, which makes it possible to report problems through a variety of channels. In many situations, your main resource is your supervisor.


The Company takes all allegations of illegal actions seriously. We will confidentially investigate all reports of suspected illegal actions to determine if there may have been a violation of any law, regulation, policy or procedure.


Employees who report problems help the Company resolve problems before they worsen. We will not tolerate mistreatment of any employee who reports a work problem in good faith. Reporting a problem “in good faith” means that you have made a sincere attempt to provide truthful and accurate information, even if later it turns out that you were wrong. The fact that an employee has raised concerns or provided information in good faith during an investigation cannot be grounds for denial of benefits, dismissal, demotion, suspension, threats, harassment or discrimination. In addition, employees who work with people who report problems must continue to treat them with courtesy and respect and must not behave in a manner that alienates or intimidates colleagues. This protection also extends to any person providing information relevant to an investigation. If any act of retaliation is taken against you or others, you must report the behavior to your supervisor. The Company takes allegations of acts of retaliation seriously and we will address all acts of retaliation complaints, threats, failed and actual acts of retaliation. Please note that the Company reserves the right to punish those who knowingly make false accusations, provide false information to the Company, or act inappropriately.


Fear of punishment is one of the most frequently cited reasons why employees do not report inappropriate behavior. Each of us has a responsibility to create an atmosphere that fosters open discussion of issues that could affect the Company’s reputation and makes it easy to report possible illegal actions. In particular, managers need to provide possibilities for free discussion of situations where employees suspect violations of the Company’s standards or applicable laws. Open communication between managers and employees is essential to create a culture of “safe expression”. Managers can take the following steps to help create an open communication environment:

• Regularly discuss the values and standards of the Company in group meetings.

• Be accessible to employees and “keep doors open”.

• Periodically remind employees of the opportunity to report concerns to you as a manager or to other company resource.

• Support employees who decide to turn to other company resources instead of contacting you directly.


Your reaction to an employee’s report of a problem is extremely important. It will either foster an open communication environment where employees feel safe and can discuss important issues, or it will have negative consequences for future communication and morale in the workplace.

Please note that many employees who report problems are particularly sensitive to explicit neglect or perceived acts of retaliation following a report of illegal actions. It is imperative that you continue to treat employees with dignity and respect, including:

• Assess them taking into account their actual performance.

• Assign meaningful tasks.

• Communicate the information needed to get the job done.

• Involve them in community events.

• Treat them politely and in the same way as before.

• Encourage fair handling at the next certification.