Third Party Code of Conduct

Third Party Code of Conduct, published January 2019 (pdf)

Orion Corporation (‘Orion) is a Finnish pharmaceutical company — a globally operating builder of well-being. We develop, manufacture and market human and veterinary pharmaceuticals and active pharmaceutical ingredients.

Orion is committed to sustainability in all its operations. Through the Orion’s internal Code of Conduct and Our Management Approaches of Corporate Responsibility (www.orion.fi/en/sustainability) Orion has established company standards that include ethical business practices, labour, health and safety, environment and related management systems. These standards apply to all Orion personnel. We are committed to high standards ourselves thus we regard ourselves entitled to expect the same from our Third Parties that supply goods and services for us. ‘Third Parties’ typically refers to suppliers of products and services, but can also include agents, distributors, wholesalers, licensors, licensees and sales entities. All of Orion’s Third Parties are obligated to implement the principles of the Third Party Code of Conduct across their whole business involved in the manufacturing of goods and services for Orion. Third Party shall show continued effort to improve their performance with the expectations of this Third Party Code of Conduct.

To demonstrate conformance with these expectations and compliance with applicable regulations, Orion is reserved the right to conduct, or have conducted on our behalf, on-site audits to check compliance upon the giving of reasonable notice. Third Party shall maintain documentation necessary to demonstrate conformance with these expectations and compliance with applicable regulations.

If you have any questions, please do not hesitate to contact us at Orion.

Regulatory compliance

Orion’s general rule is that our Third Party must, at a minimum, operate in full compliance with all applicable laws, rules and regulations in the countries in which they operate. Orion’s requirements may exceed the requirements set out in national law.

Ethical business practices

Third Party shall conduct their business ethically and act with integrity. Third Party shall commit to and respect the principles and values of the United Nations Universal Declaration of Human Rights.

Business integrity and Fair Competition

The highest standards of integrity are to be expected in all business interactions. All forms of bribery, corruption, extortion and embezzlement are prohibited. Third Party shall not pay or accept bribes or participate in other illegal inducements in business or government relationships. Third Party shall conduct business in full compliance with the applicable competition laws that govern the jurisdictions in which they conduct business.

Identification of Concerns

All workers should be encouraged to report concerns or illegal activities in the workplace without threat of reprisal, intimidation or harassment. Third Party shall investigate and take corrective action if needed.

Animal Welfare

Animals shall be treated respectfully with pain and stress minimized. Animal testing should be performed after consideration to replace animals, to reduce the numbers of animals used, or to refine procedures to minimize distress. Alternatives should be used wherever these are scientifically valid and acceptable to regulatory authorities.

Privacy

Third Party shall ensure that company, worker, and patient privacy rights are protected as provided by the applicable laws.

Labour

Third Party shall be committed to uphold the human rights of workers and to treat them with dignity and respect. Third Party shall commit to and respect the principles of International Labor Organization (ILO) Conventions.

Freely Chosen Employment

Third Party shall not use forced, bonded or indentured labour, trafficked or non voluntary labour.

Child Labour and Young Workers

Third Party shall not, under any condition, employ children who are below the minimum legal age for employment. The employment of young workers below the age of 18 shall only occur in non hazardous work and when young workers are above a country’s legal age for employment or the age established for completing compulsory education.

Non-Discrimination

Third Party shall provide a workplace free of harassment and discrimination. Discrimination on the basis of race, colour, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership, marital status or any other discriminating factor is not condoned.

Fair Treatment

Third Party shall provide a workplace free of harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers and no threat of any such treatment.

Wages, Benefits and Working Hours

Third Party shall pay workers at least the applicable minimum wages, overtime hours and mandated benefits required by local laws. Local legislation and collective bargaining agreements regulating hours of work shall be followed.

Freedom of Association

Open communication and direct engagement with workers to resolve workplace and compensation issues is encouraged. Third Party shall respect the rights of workers, as set forth in local laws, to associate freely, join or not join labour unions, seek representation, join workers’ councils and bargain collectively.

Health and Safety

Third Party shall provide a safe and healthy working environment, including for any company provided living quarters, for workers at all levels. Appropriate health and safety information, training and equipment shall be provided to workers.

Third Party shall fully comply with all safety and health laws and regulations including those applicable to the areas of occupational safety, emergency preparedness, occupational illness, industrial hygiene, physically demanding work, machine safeguarding, sanitation, food and housing.

Worker Protection

Third Party shall protect workers from over exposure to chemical, biological, physical hazards and physically demanding tasks in the work place and in any company provided living quarters.

Environment

Third Party should support a precautionary approach to environmental challenges. Third Party shall operate in an environmentally responsible and efficient manner to minimize adverse impacts on the environment. Third Party shall undertake initiatives to promote greater environmental responsibility and are encouraged for the development and diffusion of environmentally friendly technologies.

Environmental Authorizations

Third Party shall comply with all applicable environmental laws and regulations. All required environmental permits, licenses, information registrations and restrictions shall be obtained and their operational and reporting requirements followed.

Waste and Emissions

Third Party shall have systems in place to ensure the safe handling, movement, storage, recycling, reuse, or management of waste, air emissions and wastewater discharges. Any waste, wastewater or emissions with the potential to adversely impact human or environmental health shall be appropriately managed, controlled and treated prior to release into the environment.

Spills and Releases

Third Party shall have systems in place to prevent and mitigate accidental spills and releases to the environment.