Code of Conduct

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1. INTRODUCTION

ANTHEM BIOSCIENCES LIMITED (hereinafter referred to as “Anthem”/“Company”), incorporated in Bangalore on 13th June 2006 under the provisions of Companies Act, 1956, having CIN: L24233KA2006PTC039703, is a Contract Development & Manufacturing Organization (CDMO) providing discovery biology services, synthetic chemical research and analysis, chemical synthesis, manufacturing of specialty chemical products, analytical method development, and related services. Over the years, Company has forward integrated into contract manufacturing with a view to benefit from the synergies arising out of its involvement in the development of the product.

Anthem offers a whole gamut of services, independently as well as collaboratively, dedicated to enabling and sustaining global research efforts in the discovery of new compounds by pharmaceutical, biotechnology, specialty chemicals, agriculture chemicals and material science companies worldwide.

2. OBJECTIVE

Anthem business culture rests on a bedrock of purpose, ethics, and equity. We have implemented the highest standards of governance to build an environment of trust, transparency, and accountability. By applying global best practices in corporate governance and business responsibility, we have ensured that we consistently preserve and enhance value. To uphold our commitment to doing business with integrity, we have adopted the “Code of Conduct,” which will assist us in navigating the ethical decisions that arise while doing business. This is a practical guide to ethical behavior for all our employees and board members. The Anthem Code of Conduct is one of the ways we put the company’s vision and mission into practice. We rely on all our employees and board members to follow the Code, which has been developed to assist us in navigating the ethical decisions that arise while doing business. Although the Code does not cover every possible ethical dilemma you might come across, it offers guidance on a broad range of topics. Ethics in business is the moral mirror that reflects ethics in personal life. The Code addresses parameters and expectations for workplace behavior that can help us make the best choices to foster a culture of respect, fairness, and equity

3. APPLICABILITY

The Anthem Code of Conduct and Ethics (“Code”) is applicable to all employees of Anthem Biosciences Pvt. Ltd., including part-time, temporary, and contractual employees, trainees, consultants, volunteers, and members of the Board of Directors, also referred to as “Covered Persons.” This code is only a reference tool. Respective policy documents, standing orders, and directives of the company should be referred to for detailed guidance. Failure to comply with the Code and other policy documents shall attract disciplinary action up to termination of employment. Human resource representatives should be contacted for clarification, if any. The Business Partner/Supplier Code of Conduct will be applicable to all third parties doing business with Anthem, including manufacturers, distributors, vendors, and service providers.

4. ETHICAL CONDUCT, DISCIPLINE AND DECORUM

Every employee of Anthem is expected to be professional, honest, and possess high moral and ethical standards. Such conduct will be exhibited in all dealings by employees at all times, whether in or out of the company.

Every employee is responsible for the implementation of and compliance with the company’s ethical conduct in his or her professional environment. Any act of moral turpitude or lack of integrity will be viewed seriously.

All employees are expected to maintain office discipline and decorum. This includes the following:

  1. Conduct oneself in a professional and decent manner while interacting with office colleagues and outsiders.
  2. Refrain from communicating in colloquial or vernacular languages during official interactions; all official business will be conducted in English.
  3. Be sensitive while discussing issues regarding race, color, religion, and gender.
  4. Refrain from shouting and making noise in public during office hours and within office premises.
  5. Maintain time and commitments.

5. BUSINESS INTEGRITY AND FAIR COMPETITION

Business associates, employees, partners, or suppliers shall not pay or accept bribes or participate in others.

Anthem employees are obliged to comply with all applicable provisions of the Anthem Code of Conduct, including the following concepts related to its business relationships:

  1. Illegal inducements in business or government relationships are not allowed.
  2. Employees shall deal with all suppliers, customers, and all other persons doing business with Anthem in a completely fair and objective manner, without favoritism or preference based on personal financial considerations or personal relationships.
  3. The employee shall not accept or provide (directly or indirectly) gifts, prejudicial discounts, payments, fees, loans, entertainment, favors, or services from any person or firm that may influence or give the appearance of influencing purchasing decisions.
  4. No employee shall do business on behalf of Anthem with a close relative or own financial interest in any business where the Anthem employee has the appearance or ability to affect the business relationship with Anthem. Such relationships must be disclosed as per Anthem policies.

Anthem shall fully support the development and operation of competitive open markets and shall promote the liberalization of trade and the markets in which it operates. Specifically, no Anthem company or employee shall engage in restrictive trade practices, abuse of market dominance, or similar unfair trade activities.

6. PERSONAL INFORMATION AND COMMUNICATION

  1. On joining Anthem,  every employee will complete the joining report containing personal information.
  2. It is important that personnel records are kept accurate at all times. In order to avoid information gaps or compromise benefit eligibility for employees, employees are expected to promptly notify changes in personal data such as name, home address, telephone number, marital status, number of dependents, or any other pertinent information.

7. CONFIDENTIALITY

  1. Company policies, research data, research book, methodologies and practices, company initiatives, salary details, and future plans will be treated as confidential information.
  2. All employees will read and sign an Employee Non-Disclosure and Confidentiality Agreement at the time of signing that covers the following: 
  • Personal records of employees are confidential, and such information will not be shared with anyone other than the concerned individuals.
  • Policies, procedures, and guidelines of the company are confidential, private, or restricted. Disclosure of such information will damage the interests of the company and should not be shared with an unauthorized person.
  • Other areas where confidentiality is to be maintained are company future plans, financial documents, software details, passwords, network information, and background information of employees and prospective employees.

8. REPORTING CONCERNS OF HARASSMENT, MISCONDUCT OR INAPPROPRIATE BEHAVIOR

Anthem encourages the reporting of complaints of harassment or inappropriate behaviors, and an investigation will be conducted to address the concerns. Where there has been a violation of policy, Anthem will take appropriate action to try to avoid future violations. In appropriate cases, Anthem may take disciplinary action (up to and including immediate termination) against those violating Anthem’s code of conduct.

To respect the privacy and confidentiality of all people involved, Anthem might not share specific details of the disciplinary action or any other action taken.

9. ORGANIZATION CREDO

  1. Honesty: the organization believes in honest work and expects the same from its employees. All work done by the company will be presented and discussed in an open environment.
  2. Commitment and Dedication: The company is committed to producing high-quality work content and, at the same time, would like to percolate the same commitment and dedication to work from the employee’s point of view.
  3. Collaborative working: people will be treated as the most important resource of the company, and teamwork is a valuable asset for higher efficiency and effectiveness. The team/organization position will stand higher than individual achievement.
  4. Create Goodwill: The company aims to build excellent goodwill among its clients and customers as an asset for its long-standing relationships with clients and customers.
  5. Fair and Equitable Treatment: All employees are treated equally. Irrespective of status, position, gender, caste, education, wages, religion, region, and working hours, every employee will be treated fairly without any discrimination.
  6. Transparent Approach: dealings, performance of the company and employees, and other work done by the company will be presented clearly without any hidden details to all concerned.
  7. Wages, Benefits, and Working Hours: Anthem shall ensure that all workers are paid according to the labor and wage laws, including minimum wages and other wages wherever applicable.
  8. Consistency and Reliability: The Company believes in doing good work all the time and would like to build an aura of reliability with outsiders as well as with employees.
  9. Work on Trust: All policies, procedures, guidelines, and processes in the Company are completely based on employee trust and an endeavor to forge relationships based on trust.s
  10. Empowerment: People are empowered; all employees of the company have the power to question, seek clarification, and take relevant decisions in lieu of their respective positions and authorities.
  11. Open Door Culture: All employees are approachable, irrespective of position and designation. Hierarchy is built to help with reporting and ease of working, but high approachability and flat hierarchy exist to encourage teamwork and collaboration. Employees are encouraged to communicate openly with the management regarding working conditions or any other concern without any threat of reprisal.
  12. All employees’ rights are respected at Anthem, and they are free to associate with, join, or not join any labor union.

10. ETHICAL MANAGEMENT AND SUPPLY CHAIN

Anthem’s business associates, employees, partners/suppliers shall not use or disclose Anthem’s confidential information other than with the express consent of and for the benefit of Anthem.In particular, suppliers shall not exchange or otherwise disclose Anthem confidential information with any competitor or other supplier.

Any information or data regarding Anthem operations shall be treated as confidential at all times, unless that information is in the public domain.

11. FIGHTING CORRUPTION

Anthem’s employees or any other persons acting on behalf of Anthem are supposed to not offer, give, or accept bribes. Representatives of authorities shall not be offered any inappropriate economic benefit for the purpose of promoting Anthem’s business or pursuing the company’s interests.

Bribery in all possible forms is forbidden, meaning money or a comparable other valuable advantage given or received suggests decision-making in favor of Anthem or a third party’s business.

Typical potential objects of bribery are persons representing public institutions, authorities, healthcare professionals, healthcare, and other service providers and suppliers, among others.

12. ANTI-SLAVERY AND ANTI-HUMAN TRAFFICKING

Modern slavery is a criminal offense under the Modern Slavery Act 2015 (the “Act”). Modern slavery occurs in various forms, including servitude, forced or compulsory labor, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Anthem is committed to ensuring that neither its employees, contractors, or suppliers use slave labor or engage in human trafficking.

Anthem will not continue to purchase goods or services from any supplier that is found to be engaging in human trafficking.

Anthem will not continue to purchase goods or services from any supplier that is found to be engaging in human trafficking or using slave labor.

13. CHILD LABOUR

As a good corporate citizen, Anthem is committed to the principles of protecting children from child labor exploitation. Anthem ensures that no person under the age of 18 is employed with us directly or under contracted manpower and strictly complies with the Child Labour (Prohibition and Regulation) Act, 1986.

14. REGULATORY AND LEGAL COMPLIANCE

Employees of Anthem, in their business conduct, shall comply with all applicable laws and regulations, in letter and spirit, in the areas in which they operate.

Anthem shall comply with government regulations and shall be transparent in all its dealings with government agencies.

Anthem will comply with all applicable business conduct, regulatory, and health and safety guidelines or regulations established by any relevant government authority.

15. EQUAL OPPORTUNITIES

Anthem shall provide equal opportunities to all its employees and all qualified applicants for employment without regard to their race, caste, region, religion, color, ancestry, marital status, gender, sexual orientation, age, nationality, or ethnic origin.

Policies shall promote diversity and equality in the workplace, as well as compliance with all local labor laws, while encouraging the adoption of international best practices.

Employees of Anthem shall be treated with dignity and in accordance with the policy of maintaining a work environment free of all forms of harassment, whether physical, verbal, or psychological

16. PROTECTING COMPANY ASSETS

The company shall provide each employee with the necessary workstation, facilities, and equipment to perform their specific task. Such equipment may not be utilized for personal use or removed from the physical confines of the company. Equipment like computers, fax machines, and photocopying machines is not for personal use. Floppies, CDs, and printers cannot be used to copy and print personal material.

The assets of Anthem shall not be misused. They shall be employed primarily and judiciously for the purpose of conducting the business for which they are duly authorized.

These include tangible assets such as equipment and machinery, systems, facilities, materials, and resources, as well as intangible assets such as information technology and systems, proprietary information, intellectual property, and relationships with customers and suppliers.

17. ANIMAL CARE AND WELFARE

Animal testing should be performed only after consideration is given to non-animal test methods, reducing the number of animals used, or refining procedures to minimize distress in the animals being tested. Alternatives should be used that are scientifically valid and acceptable to regulators.

Anthem conducts animal experiments only after alternate methods are explored and found to be unfeasible. Animals are treated humanely, minimizing pain and stress, and all experiences are carried out only after approval from the IAEC (Institutional Animal Ethics Committee).

Animals will be housed in the AAALAC-accredited facility in compliance with committee guidelines for the purpose of care and supervision of experiments in animals (CPCSEA).

Treatment of animals will be in accordance with the study protocol, which adheres to the regulations outlined in the CPCSEA and the conditions specified in the “Guide for the Care and Use of Laboratory Animals”.

18. HEALTH AND SAFETY GUIDELINES

  1. Worker Protection: Anthem has systems in place to protect its workers from exposure to physical, chemical and biological hazards and other company-provided facilities, like transportation vehicles.
  2. Process Safety: Standard Operating procedure is available for Process Safety Evaluation. Detailed Process safety evaluation for the process developed in R&D and scaled up in the Chemical Synthesis Plant is documented.
  3. Emergency Preparedness and Response: Documented On site emergency plan is available and accessible to all employees. Anthem identifies and assess emergency situations affecting the workplace in order to  minimize potential adverse consequences by implementing and maintaining effective emergency plans and response procedures.
  4. Hazard Information: Hazard Information is available through process safety evaluation and through periodic trainings. Primary Hazard of the material is reflected on the Material Identification Label. Material safety data sheet is available.

19. ENVIRONMENT GUIDELINES

  1. Environmental Authorization: We obtain all required environmental permits, licenses, and approvals and comply with all applicable legislations 
  2. Waste management / Emissions : We have systems in place to ensure segregation of waste at source and its disposal. Waste, wastewater, or emission with the potential to adversely impact human or environmental health shall be appropriately managed, controlled, and treated prior to its release into the environment.
  3. Spills and Releases: We have systems in place to prevent and quickly respond to accident spills and releases into the environment.

20. POLITICAL NON-ALIGNMENT

Anthem shall be committed to and support the constitution and governance systems of the country in which it operates.

Anthem, as a company, shall not support any specific political party or candidate for political office. The company’s conduct shall preclude any activity that could be interpreted as mutual dependence or favor with any political body or person, and it shall not offer or give any company funds or property as a donation to any political party, candidate, or campaign.

21. REVIEW

Anthem shall be committed to and support the constitution and governance systems of the country in which it operates.

Anthem, as a company, shall not support any specific political party or candidate for political office. The company’s conduct shall preclude any activity that could be interpreted as mutual dependence or favor with any political body or person, and it shall not offer or give any company funds or property as a donation to any political party, candidate, or campaign.

22. PUBLICATION OF THE POLICY

Anthem shall be committed to and support the constitution and governance systems of the country in which it operates.

Anthem, as a company, shall not support any specific political party or candidate for political office. The company’s conduct shall preclude any activity that could be interpreted as mutual dependence or favor with any political body or person, and it shall not offer or give any company funds or property as a donation to any political party, candidate, or campaign.

23. DISCLAIMER AND IMPORTANT NOTICE

In case of any ambiguity on the interpretation of any of the provisions contained herein, the interpretation given by such authorized officers of the Company shall be final and binding.

24. EFFECTIVE DATE

This policy shall come into force on the date of its approval by the board of the company. This policy shall revoke and replace any and all previous policies and understandings that are inconsistent with those contained herein. The Committee shall amend this policy as necessary or appropriate with the approval of the Board. Once approved by the Board, the Committee shall thereafter apprise all the major stakeholders and provide them with a copy of the approved new version.

VERSION HISTORY

This policy has been approved by the Management of the Company on 7th Feb, 2024 and shall be effective from 7th Feb, 2024.