MKG Code of Conduct

This Code of Conduct (Code) provides an overview of our commitment to ethical business practices, and it applies universally to all employees, regardless of their employment status (full-time or part-time) or their location within the organization. It also extends to the suppliers of our companies, where specified.

Every employee is obligated to be well-versed in and adhere to the relevant laws, rules, and regulations that pertain to their role, whether they have a local or global scope. While it is not expected that everyone will possess an in-depth knowledge of all laws and regulations, it is expected that they have a sufficient understanding to recognize when it is necessary to seek guidance from appropriate sources, such as managers, Human Resources, the Compliance Committee, or designated internal or external experts.

The objectives of this Code are designed to ensure:
Honesty and Integrity: Employees conduct themselves with honesty and integrity
Compliance: Relevant legal, ethical, and regulatory standards are rigorously followed
Quality of Client Service: Client services are provided in a manner that is appropriate and compliant
Fair Employment Practices: Employment decisions are based solely on qualifications and merit, free from any form of discrimination. This includes refraining from making
decisions based on unlawful factors like age, race, national origin, gender, or other legally protected statuses
Data Integrity and Privacy: Data integrity and privacy standards are effectively implemented

All employees and suppliers must adhere to the following guidelines:
• Demonstrate honesty, respect, integrity, and accountability in their actions
• Adhere to all relevant laws, regulations, industry codes, policies, and procedures related to their respective roles
• Conduct themselves professionally and uphold the reputation of MKG companies
• Familiarize themselves with and adhere to the policies established by MKG companies
• Seek appropriate guidance when uncertainty arises regarding how to proceed in accordance with the Code
• Implement role-specific policies and processes while also complying with geographical requirements
• Foster a respectful and positive workplace environment, devoid of any form of harassment
• Diligently complete assigned training and proactively bring individual or team training needs to the attention of their managers
• Promptly raise any concerns to managers, Human Resources, the Compliance Committee, or the third-party anonymous hotline, RedFlag Reporting

Employees must refrain from:
• Engaging in any activities that are either unlawful or unethical
• Involvement in illegal, fraudulent, defamatory, or malicious behavior

• Anti-Bribery
• Diversity
• Equal Employment Opportunity
• Reasonable Accommodation
• Alcohol and Substance Abuse
• Non-Harassment
• Workplace Violence
• Environmental, Social and Governance Factors
• Quality, Compliance, and Governance
• Information Security
• Use of Medical Knowledge Group IT Assets
• Conflicts of Interest
• Non-Retaliation

It is our policy to conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly, and with integrity in all our dealings wherever we operate. We are also committed to implementing and enforcing effective systems to counter bribery.

A bribe is a financial or other advantage offered or given to anyone to persuade them to or reward them for performing their duties improperly, or to any public official with the intention of influencing the official in the performance of his duties.

This policy does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, in certain circumstances, gifts and hospitality may amount to bribery, and all employees must comply strictly with MKG’s ethics policy with respect to gifts and hospitality. We will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence a public official or political party in the performance of their duties. We do not make and will not accept “kickbacks” of any kind. Kickbacks are typically payments made in return for a business favor or advantage. All employees must avoid any activity that might lead to or suggest that a kickback will be made or accepted by us.

We need diverse minds, ideas, and talent to provide inspired and effective solutions for our clients. Fresh, innovative ideas and perspectives are a competitive necessity in an increasingly varied global marketplace. Our future success depends upon leveraging a diversity of talent to create the very best work in the industry.

Our commitment to diversity goes beyond compliance with laws and regulations that promote equal employment opportunities and prohibit discrimination and harassment. To fully realize the advantages of our diversity, we must collaborate effectively, even when our differences challenge us to explore ideas and approaches that might initially appear impractical or discomforting.

We demonstrate our commitment to diversity by practicing:

Inclusion: Talent isn’t limited to those with a narrow set of industry or academic qualifications. It isn’t always where we expect to find it, and we may not recognize it when we see it. We can’t afford to overlook talent or fail to nurture it to its full potential. We ask that you build diverse teams, invite others to share their perspectives, actively seek a variety of viewpoints in decision-making, question conventional wisdom, and encourage ongoing learning and development.

Respect: Listen attentively to what others have to say, actively seek consensus, engage in constructive and lively debates, challenge each other, and offer feedback in a manner that promotes growth and understanding.

Building trust: Share information and resources, depend on one another to accomplish tasks, and always uphold your promises.

Accommodation: Recognize that some of us may work part-time hours or have other commitments that make after-hours activities challenging. Nevertheless, every employee contributes to our success and should be included on teams and in meetings, events, and activities.

Equal Employment Opportunity
We are an equal-opportunity employer, fully committed to providing equal opportunity in all aspects of employment. It is our policy that every employee should experience a workplace devoid of any form of unlawful discrimination, whether it be based on race, religion, national origin, gender, sexual orientation, marital status, disability, age, or any other protected classification under applicable federal, state, or local laws.

It is both illegal and against our Equal Employment Opportunity (EEO) policy for anyone to discriminate against any employee.

In addition, we believe that using the talents of our entire workforce and hiring qualified candidates will enhance the overall success of MKG companies. In pursuit of this objective, we require that:
• All decisions, procedures, policies, and actions related to employment are executed in a completely non-discriminatory manner
• No employee or employment applicant is subjected to discrimination on the basis of any of the protected classifications mentioned above

Reasonable Accommodation
We are committed to providing reasonable accommodations to employees and job applicants who may have disabilities (including temporary disabilities), are pregnant, hold sincere religious beliefs, or have been impacted by domestic violence, in accordance with relevant laws. If any of these circumstances, such as a disability, pregnancy, religious belief, or the aftermath of domestic violence, hinder an employee’s ability to fulfill their job responsibilities, we encourage the employee to reach out to our Human Resources Department. By doing so, we can initiate a dialogue to explore reasonable accommodations that may be both available and suitable given the specific circumstances.

Alcohol and Substance Use
The presence of illegal drugs and/or controlled substances in the workplace and their potential adverse impact on employee productivity, performance, safety, and morale are completely incompatible with our business operations, client responsibilities, and reputation as a leader in our industry.

Employees may not possess any illegal drug or any legal prescription drug that is a controlled substance (unless the prescription has been issued to an employee and is being used in a manner consistent with the prescribed directions for use).
Employees may not possess or consume alcohol during working hours. Moderate alcoholic consumption within legal limits is allowed at team or social activity events organized by MKG companies.

Unlawful harassment includes any conduct based on race, religion, national origin, gender, sexual orientation, marital status, disability, age, or any other legally protected classification that has the purpose or effect of unreasonably interfering with an individual’s work or behavior that creates an intimidating, hostile, or offensive working environment. Harassment may include physical or verbal conduct (such as derogatory comments or offensive literature), computer images, pictures, or cartoons based on one of the protected classifications. It also includes offensive or demeaning conduct of any kind that is either defined in one of the protected classifications or targeted at particular individuals because of their membership in one of the protected classes.

This policy applies to all applicants and employees of MKG companies and prohibits harassment, discrimination, and retaliation whether engaged in by fellow employees, managers, or by someone not directly connected to MKG companies (eg, a vendor). Conduct prohibited by this policy is unacceptable in the workplace and in any work-related setting outside the workplace, such as during business or MKG meetings, or business or MKG-related social events.

Sexual harassment is a form of unlawful harassment and discrimination. Unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct or written communication of a sexual nature constitute sexual harassment when:
• Such conduct has the purpose or effect of unreasonably interfering with an individual’s work or creating an intimidating, hostile, or offensive working environment; or
• Submission to such conduct is made a term or condition of employment; or
• Submission to such conduct is used as the basis for employment decisions affecting such individuals.

Sexual harassment also occurs when a person in authority tries to trade job benefits for sexual favors. This can include hiring, promotion, continued employment, or any terms, conditions, or privileges of employment. This is also called “quid pro quo” harassment.

Gender-based harassment (that is, harassment not involving sexual activity or language, eg, a male manager yells only at female employees and not males) may also constitute discrimination if directed at employees because of their sex.
Each member of management is responsible for creating an atmosphere free of discrimination and harassment. Further, employees are responsible for respecting the rights of their coworkers.

Workplace Violence
We have taken steps to help prevent incidents of violence from occurring in our work environment. We expressly prohibit and will not condone any acts or threats of violence against our employees, former employees, customers, or visitors, whether on or off our premises.

We are committed to:
• Taking prompt remedial action against any employee who engages in any threatening behavior or acts of violence, or who uses any obscene, abusive, or threatening language
or gestures
• Taking appropriate action when dealing with clients, former employees, or visitors who engage in such behavior in our offices. Such action may include notifying the police or
other law enforcement personnel and prosecuting violators of this policy to the maximum extent of the law
• Prohibiting employees, former employees, clients, and visitors from bringing firearms or any other weapons onto our premises
• Establishing effective security measures to ensure our offices are safe and secure to the maximum extent possible, and appropriately handling access to our offices by the
public and former employees

Environmental, Social, and Governance Factors
ESG considerations are fundamental for both our short-term performance and long-term sustainability. We have established a global framework that embodies our commitment to our customers, employees, partners, shareholders, and the communities where we operate.

This framework is centered on ensuring that our operations actively contribute to social progress, equity, and environmental sustainability. It is governed by an approach that involves conducting annual ESG assessments, setting objectives, and measuring progress.

All employees are expected to adhere to the guidance provided regarding our sustainability initiatives. They are also encouraged to identify opportunities for contributing to the well-being of our local communities and to provide regular feedback.

Quality, Compliance, and Governance
We are committed to establishing robust governance standards for quality and compliance in all biopharmaceutical-regulated activities and pharmaceutical marketing and communications. This commitment to quality and compliance extends across all jurisdictions and encompasses strict adherence to relevant laws and regulations.

The MKG companies follow the Office of the Inspector General’s Compliance Program Guidance, which includes the following components:
• Written policies, procedures, and standards of conduct
• Compliance officer and committee
• Effective training and education
• Effective lines of communication (including anonymous reporting and nonretaliation)
• Well-published disciplinary guidelines
• Auditing and monitoring
• Responding to detected deficiencies and corrective action plans

Information Security
MKG companies handle confidential or proprietary data for a variety of purposes, encompassing both our employees and third parties. Confidential or proprietary information includes, but is not limited to, employee information, computer programs, source codes, spreadsheets, databases, data files, and information regarding our business plans, investments, or activities.

It is imperative that our employees and suppliers understand their individual responsibilities in ensuring data security. These responsibilities include but are not limited to the following:
• All employees must uphold the security of company data in all work locations and at all times. Compliance with Medical Knowledge Group’s Information Security Policy is
• It is essential to take all possible measures to physically secure devices against loss, theft, or unauthorized usage
• All employees must utilize robust passwords
• Files should only be stored or backed up using approved MKG applications or storage centers
• Employees must adhere to the Electronic Communications and Systems policy when sending confidential or proprietary information within or outside of MKG companies
• Employees must promptly report any instances of misdirected communications containing confidential information, personal data, or inadvertent disclosures to their manager
and Human Resources

Use of MKG IT Assets
MKG’s computer and communications systems are the property of the company and must be used for approved business purposes only. At all times users have the responsibility to use the computer system in a professional, ethical, and lawful manner. Use of computer systems is a privilege that may be revoked at any time.

Employees may use specific IT assets as described by their managers to perform daily responsibilities. Any use counter to this, or that interferes with authorized use by others, is unacceptable.

Use of IT assets should not entail the following:
• Violating any company policy, code, or procedure
• Using, disseminating, and storing any commercial or personal advertisements, solicitations, promotions, destructive programs (such as viruses, worms, or Trojan horses), political material, or otherwise engaging in activities other than those expressly permitted by company management
• Exploiting vulnerabilities or deficiencies in information systems security to damage systems or information, to obtain resources beyond those they have been authorized to obtain, to take resources away from other users, or to gain access to other systems for which proper authorization has not been granted

Conflicts of Interest
MKG companies uphold the rights of our employees to engage in activities outside the scope of their roles within the organization, provided these activities do not present conflicts with their work duties. Examples of these conflicts may include:
Financial Conflicts of Interest: This involves holding a financial interest in any customer, potential customer, supplier/vendor, or competitor of MKG companies
Employment Conflicts: This pertains to being employed, serving as an officer, or being a director of any supplier, customer, or competitor of MKG companies
Relative Conflicts: This concerns supervising or exerting influence on the performance evaluation or compensation of a relative (such as a spouse, domestic partner, child, or
sibling) who is also an employee of an MKG company

• When delivering services related to research and other agency and communications services, we are dedicated to managing potential conflicts with clients in a professional and
ethical manner
• All employees are obliged to follow established processes for managing actual or potential conflicts
• Managers should be consulted for guidance, and any potential conflict situations should be promptly brought to the attention of Human Resources
• Employees are prohibited from leveraging confidential or proprietary information or intellectual property of MKG companies or our customers for
personal gain
• It is mandatory for employees and suppliers to disclose any actual or potential conflicts of interest as soon as they arise. Such disclosures should be made to their respective
manager (for employees) or the designated contact (for suppliers)

Non-Retaliation Policy:
It is against the law to retaliate against individuals for reporting unlawful discrimination, including sexual harassment or other forms of harassment. We will not retaliate in any way against any employee who makes a bona fide report of discrimination or harassment and will not permit or tolerate retaliation by anyone against such employee.

Retaliation is a serious violation of company policy, and any employee who is found culpable of retaliation against another for making a bona fide complaint of discrimination or harassment may be subject to discipline, including termination of employment, where appropriate.

Ethics Helpline Reporting:
If any member of our employees wishes to raise a concern or pose a query, they are encouraged to contact the Head of Compliance or Human Resources, which will handle the matter with the appropriate care and sensitivity. Additionally, we have established RedFlag Reporting allowing employees to confidentially discuss their concerns with an independent third party.