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Code of conduct

Interaction with people is at the core of our business. This Code of Conduct provides guidance to all Atos Medical employees, and to our customers, suppliers, board of directors, owners, and all other stakeholders.

The Code of Conduct covers Laws & Regulations, Stakeholder Interactions, Environmental Health & Safety, and Reporting as they apply to our business. It is considered the compliance standard for the entire Atos Medical Group.

Laws & Regulations

Respect the law

At Atos Medical, our employees must adhere to all laws and regulations of the countries
where they do business. Employees are expected to know the required laws and
regulations that apply to their job and position.

Laws and regulations differ from country to country. In case of conflicts between the
principles in this code of conduct and local laws and regulations, the local laws and
regulations shall prevail. If you have questions ask your manager or the Compliance team.

Antitrust and Competition

It is prohibited to have agreements between Atos Medical and our competitors that
can affect prices, terms of conditions of sales, and fair competition. Being responsible
for a business area you may not enter into any agreement that violates free trade.
It is prohibited to contact competitors about pricing, costs, or terms of conditions of
sale. Discussions with distributers or customers that unfairly restrict trade or exclude
competitors from marketplace are not allowed.

We follow all applicable laws and regulations concerning Antitrust and Competition and
we are aware that laws differ from country to country. Therefore, local legal authorities
may be contacted to ensure local compliance .

Bribery, Fraud and Corruption

All business relations shall be according to local laws and regulations and conducted
in a professional and honest way. Atos Medical employees shall never offer or accept
inappropriate items of value, including gifts or entertainment. Any form of bribery, fraud,
corruption or wrongdoings, such as for example extra payments or financial benefits, are
strictly forbidden.

We will not offer, or make illegal payments to government officials or any business
partners, directly or through intermediaries.

Stakeholder Interaction

Business relations

Atos Medical’s business relations shall be handled with respect for all parties such as
patients, healthcare professionals, governments, regulatory entities, customers, hospitals,
suppliers, and other stakeholders. We will be honest and fair in all our business dealings.

All employees within the group must act in a professional, ethical way and according to
local laws and regulations for the business in each country. We will gather and handle all
customer data and business intelligence appropriately following local laws.

People and Employment

We abide by all working regulations, laws, and union agreements (when applicable) in all
countries where we are present. Atos Medical follows strictly the requirements concerning
social taxes, insurances and other mandatory conditions for employments. We treat our
employees and job applicants with respect and fairness.

Discrimination or Harassment

We shall show respect to our colleagues and business partners. The working environment
for all Atos Medical employees must be free of emotional, verbal or physical harassment.
This includes any comments or actions regarding race, color, ethnicity, religion, gender,
sexual orientation, age, mental or physical disability, medical conditions, or any other
characteristics protected by applicable laws.

Environmental Health & Safety

Health and Safety

Atos Medical shall strive for a good and healthy working environment for its employees
and consultants, to minimize health and safety risks in the working place. We comply
with all healthcare laws and regulatory requirements applicable to our industry. We
shall ensure that employees have all the working tools, safety equipment and education
needed for their function. Any abuse of drugs and alcohol can pose serious health and
safety hazards in the workplace or in any business related situation. To secure a safe
working environment it is forbidden to use any drugs or alcohol within the work place and
during working hours. When alcohol is consumed while entertaining and representing the
company it should only be offered and consumed moderately and with responsibility.

Environment

Our environmental policy is the responsibility of all employees and is available to
suppliers, customers and other stakeholders. In collaboration with customers, suppliers,
and partners we develop our business and strive to reduce consumption of energy and
raw materials as well as reducing emissions.

Quality

We are committed to develop, manufacture, maintain and supply high quality products.
To ensure high standards and quality and to meet all requirements for the medical device
industry, Atos Medical has a certified quality system. Our procedures follow all relevant
laws, regulations and applicable guidelines in the markets in which we are represented.

Reporting

Financial reporting and inquiry

All financial reporting, books, records and accounts for the Atos Medical group must be
accurate and correct. We safeguard all business records and we shall fulfill our obligation
to provide accurate financial and other disclosures as stipulated to the local public,
governments, and investors. These include financial statements, invoices, expense reports, payroll and benefits records, and other essential company data.

Reporting a concern

Adherence to the principles in the Code of Conduct is a requirement of being a part of the
Atos Medical group. These principles are not exhaustive, but address the essential areas.
We encourage employees to discuss or address issues of concern with their manager. If
someone appears to violate the law or policy, in the first instance notify your manager.
If you are uncomfortable approaching your manager, you may contact any member of
the Compliance team. It is essential that all staff feel comfortable to raise compliance
concerns. Any concerns that are raised will be anonymous and treated in the strictest
confidence. Retaliation against any colleague who seeks advice, raises a concern, or
reports misconduct is strictly forbidden. All reported concerns will be taken seriously,
investigated, and appropriate action will be taken.