Siegfried’s Board of Directors and the ExeCom are firmly convinced that (i) strict adherence to all applicable laws and (ii) strict rejection of all forms of unfair and unethical business behavior are essential and central elements of Siegfried’s business conduct.
For this reason, Siegfried employees as well as Siegfried agents and suppliers must avoid legal breaches under all circumstances and must implement highest ethical standards in all day-to-day business dealings as set forth in the Code of Business Conduct and/or the underlying Legal Compliance Manual.
As a pharmaceutical supplier and globally operational group, Siegfried endorses stringent legal and ethical standards in all its business relationships. Within the context of these standards, Siegfried undertakes to ensure that its employees and its agents and suppliers adhere to all applicable laws when performing business activities.
Siegfried’s Code of Business Conduct provides Siegfried employees as well as Siegfried agents and suppliers with a frame of reference and awareness of the most important critical legal fields and applicable laws:
Bribery and Corruption
Siegfried prohibits any form of corrupt business behavior, in particular the active and passive bribery of public and private officials and decision-makers. Siegfried employees and Siegfried agents and suppliers must adhere to all applicable laws concerning bribery and corruption, in particular to (i) the OECD Anti-Bribery Convention, (ii) the US Foreign Corruption Practices Act 1977, (iii) the UK Bribery Act 2010, and (iv) the relevant provisions of national law, in particular the Swiss Criminal Code on bribery of public officials and the Federal Act against Unfair Competition in conjunction with Private Bribery, in their respective valid and current versions.
Siegfried prohibits its employees, agents and suppliers from having any involvement in conducts in breach of supranational and/or national applicable laws that protect free and fair competition. Siegfried employees as well as Siegfried agents and suppliers must perform their activities for Siegfried within the boundaries of European competition law, of US antitrust law, of Chinese anti-monopoly law, as well as all other applicable competition regulations.
Siegfried prohibits any (direct and indirect) purchase or sale of Siegfried shares and other financial instruments whose value is significantly dependent upon the performance of the business of Siegfried (i) on the basis of insider information that has not yet been made public, as well as (ii) during defined or temporarily imposed no-trading periods (“blackout periods”), for example before the publication of financial data. Siegfried employees and Siegfried agents and suppliers shall handle insider information that has not yet been made public strictly confidential and shall not disclose or make otherwise such information accessible to any other person.
Fraud, Offenses against Property and Data Integrity
Siegfried prohibits its employees, agents and suppliers from acting in a fraudulent manner within the context of their business activities for Siegfried, embezzling tangible or financial assets of Siegfried or of its business partners, falsifying financial data, reports and other documents, or committing other financial and other offenses against property.
Confidentiality and Data Protection
All Siegfried employees as well as Siegfried agents and suppliers must keep trade secrets and other sensitive business related data or information of Siegfried or its business partners confidential at all times and must not disclose any such secrets or information to third parties or misuse any secrets or information for unlawful purposes. Personal data must at all times be collected, processed or otherwise used only in strict adherence to the applicable local laws.
Conflicts of Interest
Siegfried prohibits its employees and its agents and suppliers from entering into business transactions and taking decisions, or allowing themselves to be correspondingly influenced, on the basis of personal considerations or relationships for their own benefit or the benefit of third parties with whom they are closely associated. Siegfried employees and Siegfried agents and suppliers shall avoid situations in which personal or financial interests or activities could potentially or actually conflict with the interests of Siegfried.
Trade Controls and Embargoes
Siegfried employees and Siegfried agents and suppliers must comply with all export control laws and further applicable laws concerning trade controls and embargoes. Furthermore, Siegfried is keen to ensure that its products are used only for approved ethical purposes and are not misused.
Discrimination and Harassment
Siegfried employees and Siegfried agents and suppliers must adhere to the applicable human rights, employment laws, in particular concerning adherence to laws prohibiting child labor and/or human trafficking and codes of behavior, and shall respect the personal dignity, private sphere and personal rights of each individual. In addition, Siegfried prohibits all forms of discrimination, harassment or other attacks on the personal integrity of the employees of Siegfried or its business partners.
Please contact the Legal Compliance Officer of Siegfried by email (email@example.com) or by mail (Siegfried AG, Legal Compliance Officer, Untere Bruehlstrasse 4, 4800 Zofingen, Switzerland).