Purpose
Abacus Medicine is a distributor of original medicine. We operate in a life-critical business where trust is non-negotiable. Our success relies on the confidence our stakeholders have in us, and each and every one of us has a critical role in building and maintaining this trust.

We hold all the relevant licenses to buy and sell medicines throughout the EU and increasingly across the globe. Our business is built on a comprehensive, validated quality system throughout the entire supply chain. This provides the strongest assurance that products from Abacus Medicine meet the strict requirements imposed by authorities and the pristine quality necessary for wholesalers, hospitals, pharmacies, and consumers.

We further recognize that our responsibilities may extend even beyond the letter of the law. We wish to be recognized as a company that acts in a fair and ethical manner.

The Code of Conduct defines how we want to conduct our business in relation to society as a whole, to our customers and business partners, and to our fellow colleagues. It sets the standards for how we conduct ourselves on a daily basis.

Not every situation that may arise is covered by the code. Guidance in uncertain situations can often be found in internal SOPs, policies and rules, but not always. In situations of uncertainty, we take pride in asking managers or relevant specialists for advice.

Basis of the Code
The Code reflects the relevant legal requirements and internationally agreed upon standards, including the UN Sustainable Development Goals and the ten principles of the United Nations’ Global Compact that spring from international agreements: the UN’s Universal Declaration of Human Rights, the International Labour Organization’s Conventions and the UN Convention against Corruption.

Scope
All employees of the Abacus Medicine group including the group’s Board are applicable to the Code, regardless of permanent or temporary employment, or volunteering. This Code of Conduct does not apply to suppliers.

Responsibilities
The Code of Conduct is an annex to all new contracts of employment and is introduced to all new employees as part of the onboarding program.

It is the responsibility of each manager to ensure that the code is understood and followed by all employees within his/her respective area of responsibility. Managers and employees are advised to revisit the code together at least annually.

The Abacus Medicine Code of Conduct is based on three highly interdependent areas:

• Society
• External Relations
• Internal Relations

The three areas highlight our different types of responsibilities towards different stakeholder groups. We do not, however, prioritize between the areas or groups. If a business practice or suggested course of action in one area is deemed to be in conflict with another, we should seek to find a different solution altogether.

Society

Environment
We consider how to avoid adverse impacts on the environment and we carry out environmental risk assessments of relevant activities and projects. We use environmentally friendly technologies and services to contribute to an ongoing sustainable development.

As the company grows, we will strive to reduce our relative environmental footprint. The environment is a priority in the Abacus Medicine CSR policy.

Good health and wellbeing
Abacus Medicine helps to make original medicines available at a lower cost, benefitting patients and the public budgets. As a supplier of medicines for clinical trials we are a link in the long chain supporting R&D.

We constantly improve our efficient ordering, repackaging and delivery systems to improve access to many medicines, including medicines that in some countries might not otherwise be available at all.

Decent work and economic growth
Throughout its existence, Abacus Medicine has achieved significant growth while remaining profitable. This allows us to pay taxes and provide hundreds of jobs with attractive remuneration, thus securing livelihoods for families in several countries. We are happy to fulfil our tax obligations and have a formulated transfer price policy.

We have job opportunities for people of all levels of education and skill, including people with disabilities. We provide internal training and support for necessary education.

As an employer, we are proud of our tradition of hiring young people and empowering them from the onset. We offer a working environment where talented people can challenge themselves and grow, and this makes Abacus Medicine able to regularly attract candidates from the leading institutions of higher education.

External relations

Authorities and audits
As a distributor of pharmaceutical products, Abacus Medicine is subject to strict rules and we are regularly inspected by authorities and business partners. We carry out detailed quality assurance, and we always welcome and collaborate in audits to show authorities and business partners how we are in compliance with the rules.

We maintain positive working relations with regulators and policy makers. We regularly serve as a well-informed conversation partner regarding the market conditions shaping our industry.

Supplier relations
We work with a large number of suppliers – more than 250 for medicines alone. Our suppliers are vital to our business, just as Abacus Medicine is vital to the business of many of our suppliers.

We seek loyal, long-term partnerships with our business partners. We believe in the principle of growing together, and we will do our utmost to offer a steady, continuous order flow in a market where prices may fluctuate.

Customer relations
Customer relations hold a unique position in the parallel distribution industry where demand always exceeds supply. At Abacus Medicine, we seek to be not just a supplier of products, but a business partner for long-term growth.

We value a high level of openness and transparency in discussions with our customers, and we share relevant price data or market information as much as possible. Because we operate in multiple European countries, we are often able to offer our customers a wider perspective with insights and best practices from other markets.

Corruption, bribery and gifts
We disassociate ourselves from corruption, bribery and money laundering in any and all forms. We wish to compete and do business on fair and equal conditions, and we expect the same from our business partners. We do not have any unrecorded money.

Abacus Medicine’s anti-corruption policy describes our guidelines to avoid corruption and bribery and how to handle gifts from business partners. The policy will be implemented in 2018.

Internal relations: Colleagues and co-workers

Health and safety
The well-being of people is an important asset at Abacus Medicine. We seek to provide a safe, healthy and productive work environment, and we work according to strict labour laws. We evaluate risks in our daily work environment and take necessary precautions to prevent accidents or injuries.

We often work hard. Long hours are not uncommon, but no one should work around the clock. Managers and employees have a shared responsibility in ensuring a sound balance between work and leisure in order to be able to continuously perform on a healthy, high level.

A culture of ambitious cooperation
At our core, Abacus Medicine is a respectful, diverse and business casual working environment, free of discrimination and with great opportunities for all to prosper. We are ambitious and to attract the most talented people we offer attractive and competitive terms.

Quality and Compliance
Abacus Medicine is a young company with a young workforce. We praise an entrepreneurial mindset and the courage to do things differently. This ethos, however, is never in conflict with our dedication to quality and compliance.

At Abacus Medicine, we are subject to the strict regulations of the pharmaceutical supply chain. We welcome this and work with the highest level of quality assurance throughout our processes.

We are serious about confidentiality and every employee is subjected to it. We do not distribute sensitive information about employees, job applicants, business agreements or business partners.

Ethics questions to consider
If an employee has doubts over whether a decision is a good idea, he or she should consider the questions below and eventually consult his or her team leader:

• Is it against Abacus Medicine’s standards or rules?
• Is it in compliance with statutory law?
• Is there a risk of a negative impact on you or Abacus Medicine?
• Could anyone else be affected by this (employees in Abacus Medicine, customers, suppliers, etc.) ?
• Would you be embarrassed if anyone else knew that you took this course of action?
• Is there an alternative action that does not pose an ethical conflict?
• What would it look like in the media?
• What would a reasonable person think?
• Does it feel right?

Violation of the Code
In Abacus Medicine we follow our values and our Code of Conduct. Appropriate actions are taken against employees who violate the code, other internal rules, laws or regulation. Breaches may result in for instance reprimands and warnings, and in severe cases dismissal.

Monitoring
Abacus Medicine expects all its employees to respect and conduct themselves in accordance with the Code of Conduct and to do their utmost to achieve its standards.