Our commitments

Our Global Code of Conduct outlines the principles that guide our conduct, help us navigate complex situations, and reinforce our commitment to ethical business practices, compliance, and responsible corporate citizenship.

Here is what we stand for:

• We act with integrity
• We comply with applicable laws, industry standards and company policies
• We engage with stakeholders ethically
• We foster psychological safety

Global Code of Conduct

The Alfasigma Global Code of Conduct is also available in the following languages:

Italian - French - Spanish - Catalan - Portuguese - German - Dutch - Polish - Czech - Slovak - Romanian - Russian - Chinese

Trust depends on people feeling able to speak up about conduct, situations or practices that may be or seem inconsistent with our standards. Everyone is encouraged to speak up. Whether a concern relates to actual or perceived misconduct, safety concerns or conduct that may be in breach of our Code of Conduct, the law or industry standards, we are committed to listening, reviewing it carefully, and responding appropriately.

EthicsALine, our primary reporting channel, provides a secure channel for reporting concerns, by name or anonymously where permitted by Whistleblowing Laws.

All reporting channels at Alfasigma ensure the confidentiality of anyone involved in the process and of the information reported.

Reports must be made in good faith and relate to verifiable facts.

Following matters are reported through other channels:

• Adverse reactions related to the intake of drugs marketed by the Alfasigma Group - For this purpose click here to report an adverse event.
• Emergency situations requiring immediate response - Reports submitted through this service may not receive an immediate response. If you require emergency assistance, please contact your public emergency services.

Access the Global Speak Up Policy

Access the Local Speak Up Addendum for Italy

Access EthicsALine

We respect human rights

Alfasigma is committed to:

• Protecting and promoting human rights, operating with the utmost respect for the dignity of the person, and requiring the same commitment from those we work with
• Contributing to the creation of the socioeconomic conditions necessary for the effective enjoyment of human rights recognised by the highest international standards
• Condemning all forms of child and forced labour, modern slavery and human trafficking
• Opposing any form of exploitation, abuse or coercion against all our co-workers.

Building meaningful partnerships with patient communities means taking time and care, and being prepared to listen. We are constantly evolving our approach with our patient community partners.

We conduct our business in line with recognised principles of responsible business conduct in compliance with environmental, social and governance laws.

We seek to operate by identifying, preventing and addressing potential adverse impacts connected to our operations.

We aim to contribute positively to communities in which we operate, safeguard the environment and uphold transparent and accountable governance.

Our Impact - Corporate Social Responsibility

The 2030 Agenda for Sustainable Development includes 17 Sustainable Development Goals (SDGs).

We reference these as guidance on how we can positively contribute through our business operations and corporate responsibility agenda.

THE 17 GOALS | Sustainable Development

We believe reciprocity begins with transparency. Through open, honest, and responsible exchange with healthcare professionals, organisations, and other stakeholders, we build trusted relationships that strengthen innovation.

Transfers of Value to HCPs, HCOs, PAs and Patient Experts

Pharmaceutical companies in Italy have chosen to ensure full transparency in their collaborations with Healthcare Professionals (HCPs), Healthcare Organisations (HCOs) and Patient Organisations (POs) in line with the Farmindustria Code of Ethics and the EFPIA Transparency Code (European Federation of Pharmaceutical Industries and Associations).

In accordance with these Codes, each Farmindustria member company publishes on its website, by 30 June of the following year, the Transfers of Value made during the previous year to Healthcare Professionals (HCPs), Healthcare Organisations (HCOs), Patient Organisations (POs) and Patient Experts.

This page provides the data regarding the following transfers of value:

• Expenses incurred annually for research and development (R&D) activities in aggregate form.
• Transfers of Value to HCPs related to:

1. 1. transfers of value related to participation in conferences and congresses (registration fees, travel and accommodation, excluding meals and beverages)
   2. fees paid for consultancy and other professional services provided under a specific contract.
   3. HCPs data are published on an individual basis only when the HCP has provided consent to individual disclosure; otherwise, data are published in aggregate form in line with applicable privacy legislation. Alfasigma requests consent for each initiative.

• Transfers of Value to HCOs and Patient Organisations individually, related to:

1. 1. donations and contributions (including free loans) both in cash and in kind
   2. direct or indirect funding for congress and other scientific/educational events (e.g. sponsorship and organisational support)
   3. fees for professional advice and services provided under a specific contract.

Alfasigma also publishes in the “Transparency & Reporting” section (Who we are / Our commitments):

• a list of Patient Organisations with which service contracts were concluded in the previous year
• a list of Patient Organisations supported in the previous year, including the purpose of the support and the economic value provided to each association
• a list of Transfers of Value to Patient Experts, including the names of the individuals involved (subject to specific consent) and the total amount of transfers of value made.

The publication on the company website takes place in the manner provided by the Guarantor Authority for the protection of personal data, in the matter of unavailability of data through external search engines and the adoption of suitable measures to hinder massive duplication operations.

Methodological note on accounting aspects

All published figures are recorded in accordance with current VAT regulations. Alfasigma data are exclusive of VAT and on accrual basis. Foreign currencies have been converted into Euros at the exchange rate on the day of recording.

The Transfers of Value published in the "Travel and Hospitality" section consist of the cost of hotel accommodation and airfare, train fare or car reimbursement according to ACI rates (reimbursement not exceeding the cost incurred for other guests).

Other countries reporting

The Transfers of Value data included on this site refer to the parent company, Alfasigma SpA, headquartered in Italy.  For other subsidiaries, disclosure of such information may vary based on local regulations; where applicable, please consult the respective webpage of each affiliate.