Code of conduct

AstraZeneca requires all members of the AstraZeneca Group and their directors, officers and employees to observe high standards of integrity and honesty and to act with care, diligence and fairness in all our business activities. All interactions with stakeholders and society should be conducted in an ethical and proper manner. To that end, everyone is required to comply with the AstraZeneca Code of Conduct and all supporting policies, the laws and regulations of all countries in which we operate and with all applicable national and international codes.

During 2007, we reviewed and expanded our Code of Conduct to provide clear direction as to how our high level values are to be translated into consistent actions across all areas of our business. Led by Global Compliance, the Code was developed by a cross-functional team of SET area representatives, including MedImmune, and approved by the AstraZeneca Board and SET.

The new Code unites all members of the AstraZeneca Group, including MedImmune, KuDOS, Arrow Therapeutics, Astra Tech and Aptium Oncology, under a single Code of Conduct. In particular, AstraZeneca in the US no longer has its own Code of Conduct, as the new global Code of Conduct provides appropriate guidance across all areas of activity previously covered by the US code.

Available in over 40 languages (downloadable as PDFs below), the new Code was distributed to all employees in May 2008 and went into effect in July. During the remainder of the year, training was provided for every employee to ensure that the requirements of the Code are understood and people are clear about what is expected of them. For most employees, training took the form of an online, interactive e-learning module, although some parts of the Company elected to use a CD-ROM or paper workbook. Participation was mandatory and registration monitored by Global Compliance. By the end of 2008, all our employees had completed training in the new Code. New starters will be required to complete the on-line training within 30 days of the first day of employment.

PROCEDURES FOR RAISING CONCERNS

Our Code of Conduct includes procedures for employees to raise integrity concerns via various channels, including new AZethics telephone helplines and a new global website – AZethics.com. (MedImmune and Aptium Oncology continue to use their own existing helplines, which were already well known and trusted within their organisations). Information can be provided anonymously if preferred.

Anyone who raises a possible breach in good faith will be supported by management and will not be subject to retaliation. Any act or threat of retaliation will itself be considered a serious violation of the Code.

During 2008, 206 reports of alleged compliance breaches or other ethical concerns were made via the telephone helplines (including MedImmune’s and Aptium Oncology’s), the AZethics.com website or the Global Compliance email or postal addresses described in our new Code of Conduct.  The number of reports via equivalent channels in 2007 was 133 and we believe the increase is due partly to our efforts to enhance these reporting channels and partly to increased awareness following the launch of the new Code and the accompanying training.

All concerns are investigated and appropriate actions taken as required, which can include management counselling, training, disciplinary action or dismissal. No material issues were reported through this route during 2008.

In addition to the helpline, we have local grievance processes in place in all the countries in which we operate, in line with local labour law and our own commitment to best practice. The responsibility for the grievance procedures typically lies with the business leaders and Marketing Company Presidents in each country.

OUR CODE OF CONDUCT

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The content of this page was externally assured by Bureau Veritas, February 2009.