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2. Audit Per the Arxada Sourcing and Purchasing Policy, Arxada reserves the right to ask for a written confirmation of a supplier’s compliance with the Supplier Code of Conduct and to audit its suppliers accordingly. 3. Certification Suppliers that execute Arxada’s supply agreements warrant that they will comply with Arxada’s Supplier Code of Conduct, which, in addition to the principles outlined in Section 1 above, also states that Arxada follows the Principles of the United Nations Global Compact, the International Labour Organization’s Forced Labour Standards, as well as the Pharmaceutical Industry Principles for Responsible Supply Chain Management. In the event that Arxada becomes aware of any actions or conditions not in compliance with its Supplier Code of Conduct, Arxada reserves the right to request corrective actions and the right to terminate any agreement with a non-compliant supplier unless its supplier agreement provides otherwise. 4. Internal Accountability Arxada’s internal Code of Conduct defines the professional standards Arxada aspires to in all of its activities and the standards it expects of its employees. In keeping with the fundamental Arxada values of openness, loyalty, fair dealing, integrity, mutual respect and honesty, Arxada sees the Code of Conduct as a key element of its relationships with employees and third parties. The Arxada Code of Conduct includes a prohibition on discrimination, which states in part that “Arxada does not tolerate any discrimination, harassment or bullying on the basis of ethnicity, national origin, color, religion, sexual orientation, creed, age, sex, disability or any similar characteristic. Nor will Arxada engage in or support, directly or indirectly, child labor, or bonded or forced labor of any kind.” The Arxada Code of Conduct is issued as part of the terms of employment of all Arxada companies, and the Board of Directors insists on full compliance by all employees, regardless of their position. Moreover, Arxada’s ethics and compliance hotline provides a mechanism for employees and others to report potential violations of the Code of Conduct, any Arxada policies or procedures (including those related to ethical sourcing), or applicable laws. Such reports may be made anonymously where allowable by law. Those found responsible for any violations may face disciplinary action, to include termination of employment. 5. Training Arxada provides periodic training to all its employees regarding compliance with its Code of Conduct, which includes a prohibition on engaging in or supporting the use of forced labor. Arxada also provides additional training to its purchasing employees on the Supplier’s Code of Conduct.

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