BAJIR CODE OF ETHICS

(version valid from 1 January 2024)

The company Bajir s.r.o.

Company Reg. No.: 27584615,

of registered address K Jezeru 490/2, Praha 4 – Háje,

recorded in the Commercial Register kept by the Municipal Court in Prague under file no. C 117115 (hereinafter “Bajir“)

hereby issues, in accordance with Section 306 of Act No. 262/2006 Coll., the Labour Code, as amended (hereinafter the “Labour Code”),

This Code of Ethics is binding for Bajir and all its employees, including employees with a work activity agreement, work performance agreement, and temporarily assigned employees; it is also binding on the basis of contractual arrangements for all persons acting on behalf of Bajir or in its name (hereinafter collectively “employees”).

an internal regulation laying down the basic rules of ethics of Bajir for the actions of employees and other persons acting on behalf of Bajir or in its name and in all activities of employees and other persons in connection with performance for Bajir that have an impact on clients of Bajir and other persons (hereinafter the “Code of Ethics”). The purpose of this Code of Ethics is to thereby support the legal, fair and ethical behaviour of Bajir and its employees.

I. FUNDAMENTAL ETHICAL PRINCIPLES

Bajir commits to the highest standards of conduct in all aspects of its business. All commercial activities of Bajir are conducted with integrity and in a lawful and ethical manner in accordance with all applicable legislation and directives, including anti-corruption and personal data protection regulations. It is the strategy of Bajir to conduct its business in an honest and proper manner at all times.
Bajir rejects any form of discrimination and unfair treatment and actively creates an environment with equal and just working conditions for all its employees. We do not tolerate harassment, intimidation, bullying or other forms of inappropriate behaviour.
Employees must always act properly and honourably towards all clients, suppliers, business partners and other employees and must protect the good name and reputation of Bajir and its clients, suppliers and business partners in public.
It is expected of employees that they will avoid actual or potential conflicts of interest that could influence or seem to influence their judgment or actions in performance of their work duties for Bajir.
Employees must always report any suspicion of possible unethical or illegal conduct to their direct superior or a Bajir executive. Bajir will investigate all well-founded suspicions and take appropriate measures. It will also ensure the greatest level of confidentiality and protection of the complainant from any retaliation.
Bajir and its employees may not make use of forced or involuntary labour. Bajir requires the same commitment from its business partners.
Employees have freedom of association in trade unions and other bodies representing employees. Bajir respects the rights of employees to enter or not enter unions and other bodies representing employees in accordance with the Labour Code. Bajir also respects the rights of employee representatives arising from the Labour Code and the rules of collective bargaining.

II. ANTI-CORRUPTION PRINCIPLES

Since it was established, Bajir has had a corporate policy that prohibits employees from providing anyone any payment or benefit if the purpose is to unduly influence an official or acquire unfair business advantages. Bajir requires all its employees to act in accordance with these principles.

1. Bribery

Most countries, including the Czech Republic, have adopted legislation prohibiting direct or indirect provision, offering or approval of providing bribes or any other benefit to an official if the purpose is to influence the actions or decisions of such person in order to acquire or maintain a business contract. Bajir’s corporate policy interprets the term “official” broadly, including the following:

any elected or appointed public official (e.g. an employee of the Ministry of Health);
any employee or person acting on behalf of or in the name of an official of public administration, authority or entity carrying out public administration;
any political party, candidate for public office, official, employee or person acting on behalf of a political part or candidate for public office;
any employee of a public international organisation or person acting on behalf of such an organisation;
the term “public” includes all levels and departments of public administration (i.e. local, regional or national level and judicial, legislative or executive branch). As this definition of “official” is very broad, it is likely that business partners will deal with officials in the course of their normal business activities for Bajir. For example, doctors employed in public hospitals can be considered “officials” according to this company policy.

2. Anti-corruption principles governing relations with authorities and officials

Employees may not directly or indirectly provide or offer bribes to any official in connection with performance for Bajir, nor approve any such provision, if the purpose is to convince such a person to take any official step or decision that would help Bajir obtain or retain a business contract. Employees may not provide or offer an official any payment, gift or advantage regardless of the value if the purpose is to convince such an official to approve, compensate, prescribe or purchase Bajir products or influence the results of clinical trials or take other inappropriate steps to benefit the business activities of Bajir.

Employees are informed by Bajir whether the local legislation and directives or operating procedures (including the requirements laid down by public institutions such as state hospitals or research institutions) impose any limits, restrictions or publishing obligations with regard to provision of compensation, financial aid, contributions or gifts to officials. Employees are obliged to take this under advisement while performing activities for Bajir and comply with any relevant limitations. Should an employee be uncertain of the significance or applicability of any limit, restriction or publishing obligation in connection with dealings with officials, they shall be obliged to consult with the competent contact person at Bajir before taking the step in question.

In connection with performance for Bajir, employees are not entitled to provide “facilitating payments”. These include but are not limited to small informal payments to officials in order to secure or accelerate the performance of routine actions that do not require deliberation. Examples of facilitating payments include payments to expedite the procedure for issuing licences, permits or visas for which the application has been duly submitted. Should an employee receive or learn about a request for a facilitating payment or bribe in connection with performance for Bajir, the business partner shall be obliged to report such a request to the competent Bajir contact person before taking any further steps.

3. Bribery in the private sector

Bribery and corruption can also appear in private business relationships. Most countries, including the Czech Republic, have adopted legislation prohibiting the provision, offering, requesting, receiving or approval of provision of payments or any other benefit in order to obtain an unfair business advantage. Examples of prohibited conduct include, but are not limited to, the provision of unauthorised gifts or hospitality, or the securing of business opportunities with intent to convince a certain person to buy goods or services. Employees are not entitled to offer, provide, request or accept bribes in connection with performance for Bajir and observance of the same principles is expected of Bajir’s business partners and persons acting on their behalf in connection with performance for Bajir. Bajir employees are not entitled to offer, provide, request or accept bribes and we expect that our business partners and persons acting on their behalf in connection with performance for Bajir will follow the same principles.

4. Anti-corruption principles governing relations with private persons and Bajir employees

Employees may not directly or indirectly provide or offer any person bribes or any other benefit in connection with performance for Bajir, nor approve any such provision, if the purpose is to convince such person to provide an illegal business advantage to Bajir.

Employees may not direct or indirectly ask, agree to or accept payment or any other benefit in connection with performance for Bajir if the purpose is undue approval of business activities performed for Bajir.

Employees are not entitled to accept any gifts, services, benefits, entertainment or other performance of more than symbolic or insignificant monetary value from business partners and persons acting on their behalf in connection with performance for Bajir. Gifts of insignificant value are additionally only permitted if they are accepted infrequently and on appropriate occasions.

5. Reporting of potential and actual violations

We expect our business partners and persons acting on their behalf in connection with performance for Bajir to report potential violation of these anti-corruption principles to Bajir. Business partners can submit such reports to the contact person at Bajir, either by email at info@bajir.com or by phone at +420 734 855 974.

III. PHARMACOVIGILANCE (reporting of incidents)

In performing its activities, Bajir abides by the principles for reporting of incidents in connection with the products of its clients.

1. Incident

An incident means any adverse change in the health of a patient or clinical trial subject who is a recipient of a medicinal product, which need not necessarily be causally related to treatment by this product. An incident can be any adverse or unintended effect/symptom (e.g. an abnormal laboratory test result), symptom or illness temporarily associated with use of the product regardless of whether there is an assumed causal relationship with the product. The same approach for reporting incidents applies for all cases of medicinal interactions, exposure to the product during pregnancy (via the mother or father, with or without a result), use of the product during lactation or breastfeeding, ineffectiveness, overdose, abuse or improper use of the product, incorrect administration of the product or accidental exposure to it and errors in product dispensing about which Bajir happens to learn, even if no incident was reported.

2. Obligations of Bajir

If Bajir learns of an incident in a patient using a client’s product or products, it undertakes to report this incident to the client within twenty-four hours of learning of it, regardless of whether Bajir or the person who reported the incident assesses a causal link between the client’s product and the incident. In the case of receiving a report of incidents, Bajir undertakes to obtain and pass along to the client as much information about it as possible.
Bajir shall properly and regularly (at least once a year) train all employees in incident reporting. Bajir shall keep records of such training, which it shall send to the client in electronic form upon request.
Bajir undertakes to keep records on incident reports sent to the client, both during cooperation with the client and for a reasonable period afterwards. At the client’s request, Bajir shall send these records in electronic form.
Upon request, Bajir shall cooperate with clients during regular internal ensuring of compliance between incidents reported by Bajir during a specific period and incidents the client has recorded as received from Bajir. This cooperation can particularly include confirmation of incident reports sent to the client during a specific period.

3. Obligations of employees

It is the employee’s obligation to attend regular training concerning incident reporting.
Employees are obliged to report all incidents to their direct superior or Bajir executive and to cooperate with them in determining as much information as possible on the incidents.
The direct superior or Bajir executive shall ensure reporting of incidents to the client in accordance with Article III.2 of this Code of Ethics.

IV. RESPONSIBLE RESOURCE MANAGEMENT

Bajir observes all valid environmental legislation and in all its activities minimises unfavourable impact on the environment. To the maximum extent possible, it provides services using sustainable resources (i.e. from ecologically labelled, recycled or renewable energy sources). In terms of responsible resource management, Bajir furthermore:

Has rules in place to ensure safe handling, movement, storage, disposal, recycling, reuse or treatment of raw materials, waste and emissions.
Regularly sets out environmental targets with a focus on reducing the impact of provided services on the environment. It continuously assesses the set targets.
Actively applies the established targets and updates them in interaction with its customers and business partners.

V. Final provisions

Bajir checks on an ongoing basis whether its employees are fulfilling their obligations laid down by this Code of Ethics.
Failure to uphold this Code of Ethics by employees is considered a breach of obligations arising from the legislation relating to the work performed with the consequences dealt with by the Labour Code.
Employees shall be acquainted with this Code of Ethics within 15 days of it being issued.
This Code of Ethics takes effect 1 January 2024 and is issued for an indefinite period.

On behalf of Bajir s. r. o.

prof. PhDr. Jiří Suchý, Ph.D.
Executive