Der AIRA-Pharm-Kodex und die damit verbundenen Ziele für alle Mitarbeiter:

Als unternehmerisch denkender Spezialist vereinen wir in besonderer Weise herausragende Fähigkeiten und Geschäftssinn. Unser gemeinsames Ziel ist es, führend und beispielhaft im Bereich der mittelständischen Unternehmen zu werden. Wir möchten uns im Markt durch zwei Eigenschaften hervorheben: erstens durch unsere Expertise und zweitens durch unseren außerordentlichen Geschäftssinn. Wir glauben an unsere Mitarbeiter, ihr Pflichtgefühl, ihren Ehrgeiz und ihre Klugheit. Als Kollegen möchten wir uns gegenseitig inspirieren, unterstützen und herausfordern. Der Beitrag jedes Einzelnen zählt und macht einen Unterschied. Jeder von uns beeinflusst unsere Ziele durch seine Entscheidungen und Handlungen und ist in unserem Unternehmen sichtbar. Da uns jede Person wichtig ist, entwickeln wir die Talente unserer Mitarbeiter weiter und bieten ihnen geeignete Karrieremöglichkeiten.
Mit Leidenschaft arbeiten wir daran, einen echten, positiven Einfluss auf das Leben der Patienten zu erreichen. Leidenschaft treibt unsere Arbeit, unser Miteinander und unsere Innovation voran – Innovation, die unsere Patienten wirklich benötigen. Es ist uns ein Anliegen, dass unsere Mitarbeiter und Mitarbeiterinnen stolz auf ihr Unternehmen sein können, auf ihre Kolleginnen und Kollegen und unsere gemeinsam erreichten Ziele. Qualität ist ein Eckpfeiler unseres Erfolgs, sowohl in der Gegenwart als auch in der Zukunft. Die hohe Qualität unserer Leistungen und Prozesse gewährleistet Patientensicherheit, Kundenzufriedenheit und Wettbewerbsvorteile.

1. ABOUT THIS POLICY
The AIRA Pharm Modern Slavery Policy („Policy“) is the anti-slavery Policy as it applies to the complete company and its supply chain. It is derived from the U.K. Modern Slavery Act, 2015, and from the California Transparency in Supply Chain Act, 2012, and other similar requirements such as CSR-Guideline (2014/95/EU). Further, AIRA Pharm adheres to its Code of Conduct, Doc.-No. F.1.4 of the internal Quality System and the Modern Slavery/Human Trafficking Policy. Generally, modern slavery and/or human trafficking is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labor and human trafficking all of which have in common the deprivation of a person‘s liberty by another to exploit them for personal or commercial gain.
1.2 The Company has a zero-tolerance approach to modern slavery, and we are committed to acting ethically, transparently and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
1.3 This Policy applies to our third party supply chain, including hardware manufacturers and suppliers, the logistic fulfilment centers responsible for the distribution of our products, procurement vendors and recruitment and employment agencies from whom AIRA Pharm´s employees may be sourced (each a Supplier and together the AIRA Pharm Supply Chain), and to persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
1.4 This Policy does not form part of any employee‘s contract of employment and we may amend it at any time.

2. RESPONSIBILITY FOR THE POLICY
2.1 The Board of Directors has overall responsibility for this Policy and it is enacted within the Company. Legal and Compliance are accountable for the implementation of the Policy and its cross-functional compliance across the Company.
2.2 Further, the Company’s risk management framework supports the Policy through independent audit, assessment, and objective oversight. This includes monitoring its use and effectiveness, ensuring that managers and employees receive adequate notification and training, and auditing internal control systems and procedures to ensure these procedures are effective in countering modern slavery/human trafficking.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this Policy. Managers will remain alert to indicators of modern slavery/human trafficking and will respond appropriately if they find or are informed of any indication of modern slavery/trafficking.
3. RISKS
3.1 The principal areas in which the Company faces risks related to modern slavery include:

• The AIRA Pharm Supply Chain. Materials used to manufacture AIRA Pharm´s goods or goods to be sold by AIRA Pharm may be sourced in areas of high risk of modern slavery/human trafficking.
• Effective Due Diligence monitoring of Suppliers.
• Recruitment in our own business, and recruitment through agencies.
• Appropriate training to employees.
• Processes to monitor actions undertaken to ensure AIRA Pharm´s compliance with own requirements.

4. PROCEDURES
Under section 54 (9) of the UK Modern Slavery Act 2015 and Required Disclosures within the California Transparency in Supply Chains Act the following points address the procedures carried out by the Company to meet designated requirements.
4.1 AIRA Pharm ensures to provide consumers with information (disclosure) regarding their efforts to eradicate slavery and human trafficking from their supply chains. This statement/ disclosure must set out the steps (if any) that the organisation has taken during the fiscal year to ensure that modern slavery is not taking place in any of its supply chains and in any part of its own business. The statement must be signed by a Director. The Company’s Annual Modern Slavery Statement will set out the actions that it has taken to prevent slavery/trafficking in its operations.
4.2 Supply Chains: we take one or more of the following actions in respect to each Supplier:

• We ensure that we can account for each step of manufacturing processes and that we know who is providing the raw-materials needed for our business/products that we (re-)sell.
• Annual completion of a risk assessments to validate actions undertaken by the Supplier to ensure compliance with the code of conduct.
• We inform our Suppliers that we are not prepared to accept any form of exploitation in their business or any part of their supply chain by publishing our Policy on our website;
• We ensure all Direct Suppliers are aware of the AIRA Pharm´s Modern Slavery/Human Trafficking Policy and our Code of Conduct.
• We complete Monitoring on all companies in AIRA Pharm´s Supply Chain, and any anti-bribery or modern slavery changes for a specific Supplier will trigger an immediate review and business assessment / investigation.
• Our standard supply chain contract templates and contracts that we negotiate with high-risk Suppliers contain anti-slavery provisions which prohibit suppliers and their employees and sub-suppliers from engaging in modern slavery.
• We conduct regular risk assessments of our Supply Chain. In cases of high-risk, we audit the Supplier and, as appropriate, we require them to take specific measures to ensure that the risk of modern slavery/human trafficking is significantly reduced; and
• In cases where modern slavery is identified, or alleged, in our business or in the AIRA Pharm Supply Chain, immediate action is taken to address it; this takes the form of a comprehensive investigation. Should abuse be identified immediate action will be taken. In the event of failure to resolve the situation with a Supplier rapidly and satisfactorily, we will terminate the contract.
• Monitoring of suppliers through the Human Trafficking Risk Index (HTRI). The HTRI uses external corporate databases – the world’s largest with more than 250 million records and incorporates data from the International Labor Affairs Bureau and the U.S. Department of State. The HTRI creates an automated, repeatable, closed-loop process to proactively monitor the AIRA Pharm Supply Chain for potential human trafficking violations.•

4.3 Recruitment: we take the following actions:

• We always ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work;
• We always ensure staff are legally able to work in the country in which they are recruited;
• We check the names and addresses of our staff (e.g., many people listing the same address may indicate high shared occupancy, often a factor for those being exploited);
• We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to;
• If, through our recruitment process, we suspect someone is being exploited, the HR department will follow our reporting procedures; and
• We conduct due diligence checks on any recruitment agency that we use to ensure that it is reputable and conducts appropriate checks on all staff that they supply to us.

5. COMPLIANCE WITH THE POLICY
5.1 Employees must ensure that they read, understand and comply with this Policy.
5.2 The prevention, detection and reporting of modern slavery/human trafficking in any part of our business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this Policy.
5.3 Employees and third parties are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the business or supply chains of any supplier at the earliest possible stage. (Via www.airapharm.de) There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support.
The following key signs could indicate that someone may be a slavery or trafficking victim.
This list is not exhaustive:

• The person is not in possession of their own passport, identification, travel documents or bank account;
• The person is acting as though they are being instructed or coached by someone else;
• They allow others to speak for them when spoken to directly;
• They are dropped off and collected from work;
• The person is withdrawn, or they appear frightened;
• The person does not seem to be able to contact friends or family freely; and
• The person has limited social interaction or contact with people outside their immediate environment.

5.4 If you believe or suspect a breach of this Policy has occurred or that it may occur, you can raise an altert under info@airapharm.de as soon as possible.
5.5 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any part of our business or tier of the AIRA Pharm Supply Chain constitutes any of the various forms of modern slavery, you can raise an alert using info@airapharm.de as soon as possible.
5.6 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in the AIRA Pharm Supply Chain. All notifications received, together with the identity of the notifier, will be treated as confidential.

6. COMMUNICATION AND AWARENESS OF THIS POLICY
6.1 Training regarding the risk our business faces from modern slavery/human trafficking within the AIRA Pharm Supply Chain, will be provided to new and existing employees in relevant departments; regular training updates or refreshers will be provided as necessary.
6.2 Our zero-tolerance approach to modern slavery/human trafficking will be communicated to Suppliers at the outset of our business relationship with them and reinforced as appropriate thereafter.
7. BREACHES OF THIS POLICY
7.1 Any employee who breaches this Policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
7.2 We may terminate our relationship with Suppliers and other third parties if they breach this Policy, details of actions undertaken with regard to remediation and outcomes will be published in the Company’s Annual Modern Slavery Statement, and take any action required by the UK Modern Slavery Act 2015.
8. REVIEWING THIS POLICY
This Policy is reviewed periodically by Compliance, as required.
REFERENCES
California Transparency in Supply Chains Act
UK Modern Slavery Act 2015
CSR-Guideline (2014/95/EU)

The definitions of these terms are as follows:
Slavery: Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Forced or compulsory labor: Forced or compulsory labour is defined in international law by the ILO’s Forced Labour Convention 29 and Protocol. It involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements are that work or service is exacted from any person under the menace of any penalty and for which the person has not offered him/her self voluntarily. Human trafficking: An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. “Transparency in Supply Chains etc. A practical guide” Guidance issued under section 54(9) of the Modern Slavery Act 2015 Annex A page 17.

1. Background and Purpose
AIRA Pharm is committed to conducting business in compliance with the law, including all applicable anti-bribery and anti-corruption laws in all countries in which AIRA Pharm operates. Bribery is illegal and exposes both the Company and its Personnel to fines and other penalties including imprisonment.
To the extent that laws and regulations in any countries are more rigorous or restrictive than this Policy, those laws and regulations should be followed by any subsidiary or Personnel operating in that country. AIRA Pharm may, from time to time, provide country-specific directions for subsidiaries or employees operating in countries outside of Europe.
This AIRA Pharm Anti-Bribery and Anti-Corruption Policy, (the “Policy”) sets out the Company’s requirements in relation to interactions with Officials and Third Parties. This Policy does not prohibit interactions with Officials, rather it forbids corrupt interactions with those individuals.
The Company strives to maintain high ethical standards and has adopted this Policy to promote full compliance with Anti-Corruption Legislation, as well as any other anti-bribery and anti-corruption laws and regulations that operate in the specific regions where the Company does business.

2. Definitions
In this Policy the following words or phrases mean the following:
Anti-Corruption Legislation means the United States Foreign Corrupt Practices Act (the “FCPA”), the Criminal Code Act 1995 (Commonwealth of Australia), current EU Compliance Guideline and the Bribery Act 2010 (United Kingdom).
Bribery means the offering or providing (or authorising the offer or provision) of any loan, gift, lavish trip or entertainment, donation, payment, or any other thing of value directly or indirectly, in cash or in kind, to or for the benefit of any Official or Third Party to obtain or retain business or to secure any improper advantage for AIRA Pharm.
Business Associates means the third party companies and individuals (such as joint venture partners, consultants and agents) acting on behalf of AIRA Pharm, whether directly or indirectly, by representing the Company’s interests in relation to business development or retention of business opportunities.
Facilitation Payment means payments of nominal amounts to persons in order to ensure or speed up the performance of a Government Official’s routine governmental duties or actions.

Government Official means anyone regardless of rank or title who is:

• engaged in public duty in a government agency whether elected or appointed, and at any level of government including national, state or local government entities;
• a member of any legislative, administrative or judicial body;
• an employee of a government agency, regardless of rank including an administrative and/or office worker;
• an officer or employee of a government-owned or government-controlled entity, including state-owned entities that operate in the commercial sector;
• an officer or employee of a public international organisation (such as the United Nations, the World Bank or the International Monetary Fund); or
• acting in an official capacity for a government, government agency, or state-owned enterprise.

Item of Value or anything of value includes cash, travel, meals, gifts, and other tangible or intangible benefits.
Official means a Government Official, political party, official or officer of a political party or candidate for political office.
Personnel means all persons acting on behalf of AIRA Pharm at all levels, including officers, directors, employees, temporary staff and contractors of the Company.
Secure an improper advantage includes obtaining any improper commercial or financial benefit.
Third Party means any individual or organisation other than Officials, with whom Personnel come into contact during the course of their employment or business relationships associated with the Company.

Scope and Authority
AIRA Pharm requires all Personnel to comply with this Policy as well as the Anti-Corruption Legislation and any applicable anti-corruption laws and regulations specific to the location in which they operate.
This Policy applies to all Personnel, including directors, temporary staff and contractors, and Business Associates of the Company.
4. Responsibility for Policy Compliance, Training and Review
The Company´s Quality Manager is the Compliance Officer for AiRA Pharm and is responsible for the overall administration of this Policy. The AIRA Pharm Compliance Officer will monitor the implementation of this Policy and will review on an ongoing basis the Policy‘s suitability and effectiveness. Internal control systems and procedures will be audited regularly to ensure that they are effective in minimising the risk of non-compliance with this Policy.
All Personnel are required to understand and comply with this Policy and to follow the reporting requirements set out in this Policy. To this end, training on how to comply with this Policy will be provided.
The prevention, detection and reporting of Bribery and other improper conduct addressed by this Policy are the responsibility of all those working for or engaged by the Company. All Personnel should be vigilant and immediately report any breaches or suspicious activity in accordance with section 6(G) below.
5. Consequences of Breaching this Policy
Bribery and the related improper conduct addressed by this Policy are very serious offences.If AIRA Pharm or one of its subsidiaries is found to have taken part in Bribery or any other related improper conduct addressed by this Policy it could face a fine and suffer reputational harm. An individual may be subject to penalties or lengthy terms of imprisonment.Breach of this Policy by Personnel will be regarded as serious misconduct, leading to disciplinary action which may include termination of employment.Breach of this Policy by a Business Associate will be regarded as a material breach for the purposes of termination of the agreement with the Business Associate.
6. Policy
A. Prohibition against Bribery and Corruption
AIRA Pharm strictly prohibits Personnel engaging in or tolerating Bribery or any other form of corruption.
The Company´s corporate values require that in all aspects of business all Personnel act honestly, adhere to thehighest ethical standards, and act in compliance with all relevant legal requirements. In this respect Personnelmust not engage in Bribery or any other form of corruption.
The prohibition of Bribery under this Policy includes the provision or conveying of anything of value to any ThirdParty, Official or family members of Officials, whether directly or indirectly, to secure any improper advantage or toobtain or retain business. This means that Personnel must not:

• Offer, promise or give an Item of Value with the intention of influencing an Official or Third Party who isotherwise expected to act in good faith or in an impartial manner, to do or omit to do anything in theperformance of their role or function, in order to provide the Company with business or an improperadvantage; or
• Authorize the provision of an Item of Value to any other person, if it is known, or reasonably should havebeen known, that any portion of that Item of Value will be passed onto an Official or Third Party to secure animproper advantage or obtain or retain business; or
• Engage, or procure, another party to provide an Item of Value to an Official or Third Party, (or to procure another person to make such provision), in order to secure an improper advantage or obtain or retain business.

The prohibition of Bribery under this Policy also includes the request or acceptance by any Personnel of (or the agreement to accept) anything of value from an Official or Third Party either:

• intending that, in consequence, a function or activity should be performed improperly
  (whether by the requestor/acceptor or another person); or
• where the request, agreement or acceptance itself constitutes the recipient‘s improper performance of a function or activity; or
• as a reward for the improper performance of a function or activity (whether by the recipient or another person).

B. Interactions with Officials and Third Parties must be Compliant
All interactions with Officials and Third Parties must comply with this Policy, and AIRA Pharm and Personnel must not take any actions, whether direct or indirect, which create the appearance of impropriety regardless of whether there is any improper intent behind their actions.
Personnel have separately been provided with the AIRA Pharm Gifts and Entertainment Guidelines applicable to their business. A copy of the Company´s Gifts and Entertainment Guidelines can also be obtained from the Local Compliance Officer.
If, after considering the Gifts and Entertainment Guideline and applicable Guidelines, you are still in any doubt as to the appropriateness of any gift or entertainment, you should consult your Local Compliance Officer before it is given or accepted or otherwise as soon as possible.
The prohibitions under this Policy include a prohibition on Personnel using personal funds to undertake any interaction or transaction that is prohibited under this Policy.
C. Documentation and Recordkeeping
As part of AIRA Pharm’s commitment to open and honest business practice AIRA Pharm requires all of its businesses to maintain accurate books of account and records.
AIRA Pharm and its employees must keep accurate and complete records of all business transactions:

• in accordance with the law and generally accepted accounting principles and practices,
• in accordance with the Company’s accounting and finance policies, and
• in a manner that reasonably reflects the underlying transactions and events.

It is the responsibility of all Personnel to ensure that all business transactions are recorded honestly and accurately and that any errors or falsification of documents are promptly reported to the appropriate member of the senior management team of the relevant business, and corrected.

D. Prohibition on Facilitation Payments
AIRA Pharm does not condone the making of Facilitation Payments and the making of Facilitation Payments by any Personnel is prohibited.
E. Political Contributions and Charitable Donations
Political Contributions
AIRA Pharm prohibits Personnel from making political contributions to candidates for any political office on behalf of AIRA Pharm.
This Policy does not seek to curtail an individual‘s freedom to make political contributions in their personal capacity.
The context of any other political contributions is key in determining their appropriateness. For instance, it is permissible for AIRA Pharm to make a payment to attend a political function in circumstances where such payment could not be construed as an attempt to influence the political party.
If you are in any doubt as to the appropriateness of any political contribution, you should consult your Local Compliance Officer before it is given or accepted or otherwise as soon as possible.
Charitable Donations
The Company is committed to the communities in which it does business and encourages and supports employees participating in local community development initiatives, making donations and undertaking volunteer work. Personnel should only make donations on behalf of AIRA Pharm with the prior approval of a member of the Executive team of AIRA Pharm.
This Policy does not seek to curtail an individual‘s freedom to make donations or undertake volunteer work in their personal capacity.
F. Compliance with Local Laws Required
If local laws, codes of conduct, or other regulations in a particular country or region are more restrictive than this Policy, then any Personnel, including any Business Associates operating in that country or region must fully comply with the more restrictive requirements.
G. Reporting Violations and Suspected Misconduct
Any Personnel or stakeholder who believes that a violation of this Policy or any laws has been committed, is being committed, or is being planned, should report the matter immediately to the Local Compliance Officer.
If anyone is unsure whether a particular act constitutes Bribery or a Facilitation Payment, or has any other queries, they should ask their Local Compliance Officer.
H. Protection
AIRA Pharm prohibits retaliation against anyone reporting such suspicions.
Personnel who wish to raise a concern or report another‘s wrongdoing, or who have refused pressure to either accept or offer a bribe, should not be worried about possible repercussions. AIRA Pharm encourages openness and will support any Personnel who raises genuine concerns in good faith under this Policy.
I. AIRA Pharm Compliance Policies

• Anti Bribery and Anti-Corruption Policy
• Gifts & Entertainment Policy
• Code of Conduct
• Policy on Modern Slavery and Human Trafficking