Code of Business Conduct

1.Purpose

This policy defines and outlines the Code of Business Conduct and shares Linical's commitment to the highest legal, ethical and moral standards in all business activities and operations, globally.
This Code of Conduct applies to everyone who works for Linical, regardless of country, region or position. Third parties to whom Linical outsources its operations are also required to comply with this Code.
Violations of this Code may result in disciplinary action in accordance with local laws, regulations and our policies and SOPs.
This Code of Conduct is not static and is subject to revision in response to changes in the legal and business environment, as well as requests from stakeholders.

2.Description

2.1 Principles

2.1.1 Contributions to Healthcare, and the Pledge of Ethics and Compliance

We carry out business activities fairly and transparently, complying with the laws and regulations of every country, and with the highest level of ethical standards in our leadership of drug development.
In all aspects of drug development, we carry out our responsibilities with patient-centered thinking, contribute to healthcare by striving to ensure the safety and human rights of patients and ensure the reliability and integrity of clinical trial data.
We strive to ensure that clinical trials are conducted properly and with the safety and human rights of trial subjects being our first priority.
We are dedicated to the integrity of clinical trial operations, including secure and accurate data handling and record keeping.
We will never overlook fraud or the unethical actions of others and will act to prevent and respond to such behaviors.
We are committed to providing quality service to our clients and the pharmaceutical industry as a whole, through our professionalism and commitment to excellence and integrity. We recognize that this commitment is an important part of our role in helping patients around the world in their fight against disease.

2.1.2 Commitment to compliance

2.1.2.1 Company

We conduct our business in accordance with our management philosophy of ensuring compliance with all applicable laws, regulations and codes of conduct. We have established a compliance policy for the Linical Group for the purpose of fostering a culture of compliance.
We guide Linical members to always act with integrity and make ethically appropriate decisions in all situations by continually strengthening our compliance system and providing targeted training on the elements of the Linical Code of Conduct.

2.1.2.2 Employees

All Linical employees have read and trained on this Code, as well as any designated compliance trainings, as required by internal procedures or designated by the Compliance Committee.
All Linical Employees are therefore committed to following all applicable laws, regulations, codes of conduct and Linical policies and SOPs.
If an employee is unable to determine the correct course of action, it is expected that they seek the advice of knowledgeable others (e.g. Ethics and Compliance team) and take the appropriate action.
We firmly believe that company Leaders must establish models of ethical behavior through their own actions and these behaviors then promote the expectations of similar actions within working teams. These behaviors must also ensure an environment of trust and open communication within the workplace.

2.1.3 Compliance reporting

If we become aware of (or suspect) illegal or improper conduct under this Code or other standards, such information must immediately be reported to a supervisor and/or the appropriate department (Compliance, Legal, Human Resources, etc.) or through the use of Linical’s compliance reporting (whistleblower) system.
Linical will investigate such reports and take appropriate action to correct such events or conduct and prevent their recurrence.
Retaliation or adverse treatment of any person who reports or participates in an investigation of compliance irregularities or other concerns is absolutely prohibited under Linical policies. The same applies to reporting errors (except in the case of intentional misrepresentation).

2.2 Corporate Activity

2.2.1 Preventing Bribery and Corruption

We do not tolerate bribery or other corrupt practices.
We comply with applicable anti-bribery and anti-corruption laws wherever we do business, globally.
We do not offer or accept money or other forms of payment for the purpose of securing or facilitating business, improperly influencing clinical trials, including obtaining preferential treatment for clinical trial services, clinical trial data or other decisions. This includes prohibition of indirect offers, as well as instructions or verbal promises to third parties.
Even in cases where there are no improper intentions, the giving or receiving of money or other forms of payment may be suspected of being improper activities. Therefore, gifts, meals and entertainment and other offers are limited to those that do not deviate from Company policies or general social customs, in order to avoid the possibility of being improper or illegal in nature.
Similarly, we address and respond in good faith to any concerns about the transparency of relationships between pharmaceutical companies and healthcare professionals, such as those related to inappropriate promotional activities.
Our suppliers, such as external contractors, are also subject to anti-bribery and anti-corruption due diligence as part of the pre-transaction review process.

2.2.2 Fair Transactions

We recognize the importance of antitrust laws and are committed to complying with the laws of all countries in which we operate to promote and protect healthy market competition.
We prohibit collusion, or the appearance of collusion, with competitors on sales strategies, terms or other matters.

2.2.3 Preventing Conflicts of Interest

We ensure that our management and operational decisions reflect the best decisions in the interests of our stakeholders. All Linical employees are expected to comply with applicable laws, rules, and regulations, and will make business decisions and take actions that support the company's interests and integrity and without any apparent or actual personal interests in the decision making process.

2.2.4 Selection and management of appropriate suppliers

We conduct fair business practices with all suppliers and require high ethical standards in these relationships.
Due diligence is conducted during the supplier review process to ensure that there are no concerns about ethical and compliant behavior in the supplier’s business practices.
We clearly state the terms of the transaction in our contracts with suppliers and ensure that both parties have a clear understanding of the scope and nature of the work to be performed before engaging in business.
Linical requires its suppliers to comply with all relevant laws, regulations and contracts and carefully oversees the conduct and quality of delivery of all suppliers.

2.3 Information Management

2.3.1 Confidential Information

Information we handle in the course of our business may be considered as confidential information. Specifically, all non-public information must be treated as strictly confidential.
We must ensure the proper use, storage and disposal of information from third parties, such as customers, partners and vendors, in accordance with laws, regulations, nondisclosure agreements or similar agreements.
We must never use information for a purpose other than its original intended purpose or accept information obtained through fraud or deception.
We must never knowingly disclose confidential information and must also take all preventative measures to avoid inadvertent disclosure of such information. Improper disclosure of confidential information may occur through any means, including through documents, data, conversations and social media postings.

2.3.2 Personal Information

Personal information generally refers to information that, by itself or in combination with other information, can be used to identify a specific individual.
We are committed to handling personal information appropriately and in accordance with the laws and regulations of each country in which we operate and company internal policies and procedures.
The matters described in the previous paragraph regarding confidential information also apply to the handling of personal information.

2.3.3 Information Systems and Devices

In addition to internal company information, we work with customers, partners, suppliers and others who entrust us with their valuable information. As a result, the proper use of information systems and equipment is essential to ensuring the quality of the services we provide and maintaining their trust in Linical’s operations.
We have established an Information Security Management System ("ISMS") in accordance with the requirements of ISO/IEC 27001:2022, which Linical maintains and continuously improves upon as a data security standard.
We strive to continuously strengthen security measures for all electronic systems, electronic devices and email used in handling information to prevent unauthorized access, use or misuse.
As a matter of policy, the use of company information systems and equipment is limited to business purposes only, and use for illegal or inappropriate purposes is not permitted.

2.3.4 Inside information and prevention of insider trading

We are responsible for maintaining the confidentiality of our company's and our business partners' non-public material information and must properly manage such information in accordance with the laws, regulations and our procedures in each country.
While in possession of non-public information, we are prohibited from buying or selling the company's stock or other securities. We also do not permit others to buy or sell the company's stock or other securities while such information is in our possession.
This non-public information includes not only clinical trial information, but also trade secret information such as mergers, acquisitions and business alliances.

2.3.5 Appropriate financial reporting

We comply with the laws, regulations and internal procedures of each country in which we operate and report our financial accounts in a factual and honest manner.
We maintain accurate and timely records of all transactions and never make false or misleading statements.
We appropriately identify, address, evaluate and mitigate risks through internal control activities. We do not engage in fraudulent activities involving company assets, including all financial crimes such as embezzlement, tax evasion, money laundering, etc., as well as sham transactions.
We prepare our financial reports with accurate and sufficient information so that investors and other stakeholders can make a correct assessment of our company's situation.
We ensure disclosure of accurate and timely financial information to the public and appropriate stakeholders.

2.4 Human Resources and Work Environment

2.4.1 Respect for Human Rights

We respect the human rights of all people.
We comply with national labor laws and act in accordance with Principles 1-6 on human rights and labor of the United Nations Global Compact.
We prohibit child and forced labor and do not tolerate discrimination in the workplace wherever we operate.
We require all of our business partners to respect fundamental human rights.

2.4.2 Employment and working environment

We are committed to providing a healthy and comfortable work environment in which our employees can work safely.
We practice equal employment opportunity. We also provide opportunities for employees to develop their skills and abilities.
We treat everyone fairly and base hiring, performance evaluations and promotions on appropriate criteria (e.g., skills, abilities, experience and aptitude).
We foster a vibrant culture of mutual respect, free from harassment and discrimination on any legally protected basis (e.g., age, gender, gender identity, disability, race, religion, etc.), both of which are not tolerated in any case.
The prohibition of harassment and discrimination also applies to our relationships with all business partners.
We are also committed to supporting work-life balance so that our employees can lead richer lives by balancing their work and personal lives.

2.5 Relations with Society

2.5.1 Corporate Social Responsibility

As a partner to healthcare companies and medical institutions around the world, we support the creation and growth of new technologies to prevent and treat disease, including new medicines, and contribute to the health and well-being of people around the world.
As part of our "Contributing to People Around the World," we are actively involved in contributing to society through charitable activities such as donations and volunteer work. In providing financial and in-kind support for these community activities, we adhere to the highest ethical standards and comply with laws, regulations and internal procedures.
With respect to global social and environmental issues, we are actively developing actions that will contribute to global solutions from our position as an international service provider.

2.5.2 Elimination of Antisocial Forces

We have no relationship with anti-social forces (whether individuals, groups, or organizations). We resolutely reject any illegal or unjust demands or pressures and protect the company and our employees. This includes those who have close ties with antisocial forces.