DKSH Supplier Code of Conduct

At DKSH, we are committed to excellence in conducting our business, which includes conducting all our activities with the highest degree of integrity. We advocate integrity of the supply chain as part of our business strategy, and we are committed to responsible business practices based on international standards and expect the same of our Business Partners and Vendors (such as suppliers of materials, service providers, contract manufacturers, etc.), herein referred to as “Suppliers”.

DKSH expects Suppliers to meet the standards as described hereinafter in all activities that relate directly or indirectly to DKSH and any of its subsidiaries. Adherence to this Supplier Code of Conduct is one of the criteria applied by DKSH in Supplier evaluation, selection and retention. DKSH shall have the right but no obligation to evaluate Suppliers’ compliance with this Supplier Code of Conduct, herein also referred to as “Code”, in determining whether Suppliers meet DKSH’s expectations. Suppliers that do not conform to these standards may be disqualified from doing business with DKSH and may have their business relationship with DKSH terminated.

This Supplier Code of Conduct is closely aligned with DKSH’s Code of Conduct. It does not replace laws and regulations applicable to the Supplier. DKSH expects that Suppliers operate in compliance with applicable laws and regulations as well as this Code. Where this Code may be conflicting with applicable laws and regulations, the latter must be followed.


1. Lawful and ethical business conduct

DKSH believes in free markets, fair competition and responsible marketing practices. Suppliers shall always act in a lawful and ethically sound manner, and shall not offer, provide or accept any undue favors to obtain or retain DKSH business. No intermediaries, such as agents, consultants or any other business partner shall be used to commit corrupt acts or bribery.

Suppliers shall observe the following requirements:

• DKSH does not do business with Suppliers that do not respect the rule of law and may negatively affect DKSH’s reputation. DKSH expects all its Suppliers to follow all applicable laws and regulations, to apply high ethical standards, and to always act with integrity in all their business dealings.

• Suppliers shall observe the rules of fair competition and shall not adopt any practices that may have an adverse effect on DKSH. All forms of bribery, corruption, extortion or embezzlement are strictly prohibited. Suppliers shall never offer, pay, solicit or accept any bribes or other forms of illegal or unethical inducement in business relationships or especially when dealing with public officials and/or healthcare professionals, and they shall never make use of third parties to do such things on their behalf.

- Gifts and Entertainment: Gifts and/or any form of entertainment shall never be offered, promised or paid on behalf of DKSH or to DKSH employees or intermediaries for obtaining or retaining business. Any gifts or entertainment shall be modest, reasonable and infrequent.

- Facilitation payments: Facilitation payments generally are low value favors (e.g. cash, samples) offered to public officials to accelerate or prevent a non-discretionary routine action. DKSH does not tolerate facilitation payments and expects the same from its Suppliers.

• Suppliers shall disclose any conflict of interest situation prior to entering a relationship with DKSH, or as soon as such a situation arises during an ongoing relationship. All business dealings between the Supplier and DKSH and its employees shall always be open, fair and transparent.

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

• Supplier shall safeguard and make only proper use of confidential information to ensure that company, workers and business partner privacy rights are protected with applicable confidentiality and intellectual property laws and regulations.

• Supplier at all times shall maintain compliance with applicable laws, regulations and rules governing the cross-border exchange of goods, service and data, including but not limited to export controls, embargoes, trade sanctions, customs and anti-boycott laws.

• Supplier shall comply with applicable accounting laws and standards. All transactions must be properly and accurately recorded and supported by proper documentation. Supplier shall never directly or indirectly make any false or misappropriate or unlawful transactions on behalf of DKSH.


2. Labor and human rights

Suppliers shall uphold the human rights of workers and treat workers with dignity and respect.

The above description of personal data is merely a general desciption of the various types of personal data that we collect from various customers. The nature of personal data differs from customers to customers. Depending on the nature of business and circumstances, we may only need to collect and process a more limited form of personal data from them. In other situations, there may be a need to collect more personal data for the nature of transaction and business. We do not believe in collecting excessive personal data and what we collect are the essentials that are required to ensure the efficacy of business and transactions.

2.1 Freely chosen employment

Suppliers shall observe the following requirements:

• The Suppliers’ employees or workers have chosen their employment freely and they are fully paid for the work they do. They are free to leave their jobs after reasonable notice and are paid on time and in full for the work they have done prior to leaving.

• Suppliers shall not use any form of forced or involuntary labor, including bonded labor, prison labor or indentured labor

• Supplier shall not engage in or support any other form of modern slavery or human trafficking

• Workers are not required to hand over their identity papers to secure employment unless required under local law. If so, workers shall have access to their identity papers immediately upon request.

• Workers do not have to pay deposits or similar, to secure work or accommodation provided by the Supplier, or to obtain tools, training or equipment necessary to carry out their work

2.2 Child labor

Suppliers shall observe the following requirements:

• The Suppliers’ employees or workers have chosen their employment freely and they are fully paid for the work they do. They are free to leave their jobs after reasonable notice and are paid on time and in full for the work they have done prior to leaving.

• Suppliers shall not use any form of forced or involuntary labor, including bonded labor, prison labor or indentured labor

• Supplier shall not engage in or support any other form of modern slavery or human trafficking

2.3 Remuneration and working hours

Suppliers shall observe the following requirements:

• Workers shall be paid according to applicable wage laws, including minimum wages, overtime hours and mandatory benefits; basis upon which workers are paid (including benefits) and whether overtime will be required and the wages to be paid for such overtime must be communicated timely

• Working days and hours (incl. overtime), and rest time (breaks, time off) are aligned with local laws

• All legally required benefits are paid to workers on time and in full; workers shall not be required to do unpaid work

• Workers receive payment slips that provide transparency how wages were computed; deductions shall only be made according to local laws

2.4 Non-discrimination

Suppliers shall observe the following requirements:

• Workers shall not suffer from harassment or discrimination at any time during recruitment and whilst in employment for any reasons such as race, color, age, gender, sexual orientation, ethnicity, religion, disability, political affiliation, union membership, pregnancy or marital status, or any other form of harassment or discrimination.

• Supplier shall respect individuals in a manner consistent with the rights to privacy and data protection.

2.5 Freedom of association and collective bargaining

Suppliers shall observe the following requirements:

• Suppliers shall respect workers’ rights under local laws to join or form trade unions or worker committees without fear of reprisal or discrimination

2.6 Fair treatment

Suppliers shall observe the following requirements:

• Suppliers shall apply fair employment practices and provide workplace free of any harsh or inhumane treatment, including sexual harassment or abuse, corporal punishment, mental or physical coercion or verbal abuse

• Suppliers shall ensure that workers understand disciplinary and grievance procedures, and any fines or similar imposed on workers are legal and fair


3. Health, Safety and Environment

DKSH expects Suppliers to offer safe workplaces for workers and to care about their health and well-being by protecting them against occupational hazards. Suppliers shall respect the environment and shall take adequate measures to protect the environment and to minimize adverse impacts.

Suppliers shall observe the following requirements:

• Suppliers shall have an appropriate management system in place to identify and mitigate workplace hazards, and to prevent injuries and illnesses. Workers shall be equipped with adequate safety equipment.

• Suppliers shall comply with all applicable laws and regulations and shall obtain and maintain all applicable permits, licenses, approvals, registrations and the like required for the operation of their business and shall follow any related reporting requirements

• Suppliers shall have an appropriate management system in place to prevent spills and to handle waste in an environmentally responsible manner (recycle, safe destruction), to preserve water resources and to minimize emissions. Waste or emissions with potential adverse effects on humans or the environment shall be appropriately treated before releasing.


4. Management system

• Supplier must establish and maintain a management system reasonably designed to ensure compliance and to facilitate continuous improvement with respect to this Code. Supplier must ensure that this Code is appropriately communicated to all its directors, officers, employees, representatives, agents and subcontractors that cater to DKSH’s business whilst being a Supplier to DKSH (“Supplier Associates”).

• Supplier must maintain all documentation necessary to demonstrate compliance with this Code and compliance with applicable regulations and will provide DKSH, its subsidiaries or representatives with access to such documentation upon request of DKSH. Supplier understands and agrees that DKSH or its representatives may engage in monitoring activities to assess compliance with this Code, including visits to Supplier’s facilities and review of books and records pertaining to DKSH’s business with the Supplier. Supplier furthermore understands that DKSH has no obligation to monitor Supplier and Supplier is solely responsible to ensure compliance with this Code by Supplier Associates.

• Supplier must immediately report to DKSH (through notification to my.compliance@dksh.com) any known or suspected improper behavior under this Code, including such behavior by Supplier Associates or by employees of DKSH and its subsidiaries.