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CODE OF CONDUCT AND BUSINESS ETHICS

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Dear Colleagues,We aim to be a global leader in multiple therapeutic areas—specifically in iron deficiency, nephrology and cardio-renal therapies—and the partner of choice for specialty pharmaceuticals and patient-focused solutions. We strive to commercialise safe, effective and affordable medicines and innovative, patient-focused solutions that help patients around the world with severe and chronic diseases lead better, healthier lives.

With regard to the development and commercialisation of our products and services, we work in close collaboration with other partners, such as healthcare professionals, patient organisations and payors, to understand and meet their needs as well as ensure that we ultimately offer solutions with optimal benefit to patients. To achieve this, we not only commercialise certain specialty pharmaceuticals but also aim for scientific leadership in the respective therapeutic areas and focus on therapeutic solutions based on our strong brands, their combination with other products, or other innovative patient-focused solutions such as treatment algorithms and compliance and adherence tools.

We seek to foster a positive work environment for employees, where they can excel professionally, and to create a culture that supports innovative, agile thinking and decisive actions.

To achieve our goals, we have established guiding values and standards to not only meet our ethical, compliance and legal obligations but also position us for lasting success. Together, these values and standards provide one global identity for the Vifor Pharma Group and its employees.

Equally important, the Code of Conduct and Business Ethics for the Vifor Pharma Group (the “Code”) provides principles to help us select the appropriate path when faced with a difficult decision.

At the Vifor Pharma Group, we rely on our values to guide us in achieving our goals and determining that path:

– Entrepreneurship and passion. As entrepreneurs, we participate with passion coming from within. It is what drives us to change the lives of our patients and contribute to the sustain able, successful further development of our organisation. As entrepreneurs, we challenge and agree on our goals, ensure the appropriate resources and act decisively and in line with our established guiding values and standards. We feel responsible to deliver on our promises.

– Teamwork, trust and respect. Nobody knows everything! As a team, we rely on each individual and his or her competencies and commitment. We build trust by having faith in each other, and we expect everyone to act as entrepreneurs. We are transparent and explain what we are doing and why. We show respect. Showing respect means knowing your own limits and respecting the abilities and opinions of others. This also applies to our competitors and the market. We achieve and celebrate success as one team.

We want to foster a high-performance culture, one in which everyone, regardless of location, level or type of work, feels respected and appreciated. We want to promote a culture in which the right things are done the right way. We want all Vifor Pharma Group employees to be able to identify with this culture and to reflect the Company’s values and standards in everything they do.

We ask all employees to please carefully review the Code, to abide by it and to seek guidance if you are unsure of the best course of action for any given situation. Through our shared commitment, we are confident we will continue to achieve our goal of making a difference in patients’ lives.

Etienne JornodExecutive Chairman of the Board of DirectorsVIFOR PHARMA GROUP*

Stefan SchulzePresident of the Executive Committee and COOVIFOR PHARMA GROUP*

* THE VIFOR PHARMA GROUP CONSISTS OF THE FOLLOWING COMPANIES: VIFOR PHARMA; VIFOR FRESENIUS MEDICAL CARE RENAL PHARMA, A JOINT COMPANY WITH FRESENIUS MEDICAL CARE; RELYPSA; AND OM PHARMA.

/ SectionCODE OF CONDUCT AND BUSINESS ETHICS / 363VIFOR PHARMA GROUP / CODE OF CONDUCT AND BUSINESS ETHICS

CONTENTS

STRIVING FOR EXCELLENCEOUR BUSINESSESPURPOSE AND SCOPEGENERAL STANDARDS OF CONDUCTCOMMITMENT TO COMPLIANCESPEAK UP AND RESPONSIBILITY FOR COMPLIANCE

MAINTAINING PATIENT FOCUSADVERSE EVENTS AND PRODUCT COMPLAINTSINTERACTIONS WITH HEALTHCARE PROFESSIONALSMAINTAINING PATIENT TRUSTMANUFACTURING, QUALITY AND SUPPLY CHAINETHICAL RESEARCH

DOING BUSINESS WITH INTEGRITYANTI-RETALIATIONCOMPLIANCE WITH LAWS AND REGULATIONS PARTNERSHIP WITH GOVERNMENT AUTHORITIES AND REGULATORSBUSINESS PARTNERS AND THE CODEBRIBERY AND CORRUPTIONFAIR COMPETITION CONFLICTS OF INTERESTGIFTS AND ENTERTAINMENT

MANAGING INFORMATIONPRIVACYASSET PROTECTION AND CONFIDENTIALITYRECORD KEEPINGINSIDER TRADINGMEDIA AND INVESTOR RELATIONSSOCIAL MEDIA

SUPPORTING PEOPLE AND COMMUNITIES WORKPLACE SAFETY ENVIRONMENTAL WELFAREPOLITICAL INVOLVEMENT AND CONTRIBUTIONSCHARITABLE INVOLVEMENT AND CONTRIBUTIONS

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STRIVING FOR EXCELLENCE WE UPHOLD THE CODE AS A REFLECTION OF OUR VALUES AND COMMITMENT TO CONDUCTING BUSINESS WITH INTEGRITY.


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tract infections, chronic venous insufficiency, diabetic retinopathy, haemorrhoids and menometrorrhagia.

– Vifor Fresenius Medical Care Renal Pharma is a strategic partnership between Vifor Pharma and Fresenius Medical Care focused on strengthening our position in the global intravenous iron market.

– Relypsa focuses on leading the discovery, development and commercialisation of polymer-based medicines to treat conditions that are often overlooked and undertreated.

OUR BUSINESSES

The Vifor Pharma Group strives for excellence in our fields of expertise to make a difference in patients’ lives. Our or-ganisation consists of the following business groups, each focused on its respective expertise to achieve this goal:

– Vifor Pharma focuses its activities on iron deficiency with or without anaemia, a globally widespread ailment.

– OM Pharma focuses on infectious diseases and OTX products for brain function and development, ear care, abdominal distension, chronic obstructive pulmonary disease, respiratory tract infections, lower urinary


PURPOSE AND SCOPE

Purpose The Vifor Pharma Group aims to make a meaningful difference in the lives of our employees and the patients we serve. To do so, we strive for excellence in all areas of our business operations and not just those focusing on the development, manufacturing and marketing of our products. Our goal remains to be universally recognised as a world-class organisation with a history of sustained success, innovation and responsible business practices.

The Vifor Pharma Group Code of Conduct and Business Ethics (the “Code”) acknowledges our business, environ-mental and social responsibilities and serves as a guide to responsible and ethical decision making. The Code establishes business practices that are not only essential to how we achieve success but also define our Company.

While our Code sets standards that promote compliance with many of the laws impacting our industry, it is not intended to cover every situation we may encounter. Employees must use good judgment and should look to additional Company policies and applicable procedures and other resources available on the Company intranet.

Scope The Code applies to Vifor Pharma and all global affiliates of the Vifor Pharma Group, including Vifor Pharma Ltd., Vifor Fresenius Medical Care Renal Pharma Ltd., Relypsa Inc., OM Pharma Ltd. and their respective affiliates (collectively referred to as the “Vifor Pharma Group” or the “Company”). While the Code is primarily directed toward Company employees, in some circumstances, it may be applicable to the activities of our business partners, vendors and third-party agents. Employees who engage such third parties must seek to ensure that these parties are made aware of the Code and should seek their cooperation in complying with the Code including, where possible, the establishment of a contractual requirement to act in accordance with the Code when working on behalf of the Company.

All employees should ensure their personal decisions and actions comply with the Code in letter and spirit, regardless of their location and the nature of their work. If a difficult situation arises, employees are expected to seek advice from their manager or the Human Resources, Legal or Compliance Departments before acting.

Violations of the Code will not be tolerated and may result in disciplinary action, up to and including termination of employment.


GENERAL STANDARDS OF CONDUCT

harassment of any kind is prohibited. Harassment includes any action that creates an intimidating, hostile or offensive work environment, whether physical, verbal or other.

We welcome diversity and are an equal opportunity employer. The Company prohibits any form of discrimination or harassment and provides fair treatment to all employees regardless of race, colour, origin, citizenship, religion, gender, sexual orientation, gender identity, marital status, pregnancy, age, medical condition or disability. Additionally, we must always respect the privacy of others.

Drugs, alcohol and violenceWe are committed to securing a safe and healthy workplace for our employees free from drugs, alcohol and violence.

Employees must comply with Company policies regarding the use of alcohol and the possession, sale or use of illegal substances. Unless otherwise offered by the Company as part of a Company-sponsored event or activity, alcohol may not be consumed during working hours.

Equally important, we do not tolerate violence or any threats of violence and prohibit the possession of weapons of any kind on Company property or while off-site conducting Company business.

We expect all employees to adhere to general standards of business conduct while performing their job duties.

We believe our values are the foundation for the Code and that the Code guides our behaviour. This section of the Code defines the general standards of conduct expected of all employees. The standards described below provide the minimum behavioural expectations for all employees. Further details covering specific aspects of acceptable or prohibited behaviours and business practices are covered in other sections of the Code and in the Company’s policies and applicable procedures.

In situations where an employee is unsure of what to do or internal guidance is unclear, they should contact their manager or the Human Resources, Legal or Compliance Departments for additional guidance. Similarly, all employees must promptly report any identified or potential violations of the Code or these general standards of conduct to their manager or the Human Resources, Legal or Compliance Departments.

Harassment and discriminationWe value a positive, constructive and ethical work environment free from harassment. Workplace


COMMITMENT TO COMPLIANCE

We are committed to building a culture of compliance that reflects our values and patient focus.

At the Vifor Pharma Group, we believe that a culture of compliance leads to better business and medical outcomes for our Company and patients, respectively. As part of our commitment, all employees are expected to adhere to the values and standards established in the Code as well as in the Company’s policies and applicable procedures.

We have implemented a comprehensive compliance programme to ensure our operations and activities are always conducted with integrity. Our compliance programme is composed of the following elements to support its effectiveness:

– Compliance officers: The Company maintains Compliance Officers charged with providing broad leadership and strategy for how the Company integrates compliance requirements within its everyday business activities

– Ethics and compliance committees: The Company uses respective bodies, such as Ethics and Compliance Committee(s), composed of cross-functional senior leadership, to both promote and provide oversight over the Company’s compliance initiatives

– Code, policies and procedures: The Company sets standards for acceptable employee behaviour and interactions with other employees, customers and business partners

– Communications and training: The Company regularly communicates with and trains employees on the Company’s policies and applicable procedures to enable them to effectively do their jobs consistent with compliance requirements

– Monitoring and auditing: The Company regularly reviews its business activities to identify potential risks and instances of non-compliance

– Corrective actions: The Company swiftly and consis-tently takes action to uphold compliance requirements, regardless of the identity of the affected employees

While a comprehensive compliance programme serves a critical role in supporting our Company’s efforts, only the day-to-day action and commitment of our employees will result in its effectiveness.


SPEAK UP AND RESPONSIBILITY FOR COMPLIANCE

At times, conditions may exist in which making the right decision may be challenging. We provide multiple resources for employees to ask questions and raise concerns. Employees should contact their manager or the Human Resources, Legal or Compliance Departments if they are unclear about any aspect of this Code or are unsure how to respond to an issue that the Code or the Company’s policies do not address.

We also seek to maintain the confidentiality of employees reporting identified or potential compliance violations, unless disclosure is otherwise required by law or for the conduct of the investigation. Employees may also make reports anonymously as follows:

For more information, please visit your compliance website on our intranet.

We promptly report any identified or potential compliance violations to support the Code.

We are all accountable for the reputation of the Vifor Pharma Group. We expect employees to act ethically and responsibly at all times in accordance with our values and standards, the Code and the Company’s policies and applicable procedures. With this commitment we also have the responsibility to “speak up” and report any identified or potential violations of the Code or the Company’s policies and applicable procedures.

As such, all employees must report any identified or potential violations promptly to their manager or the Human Resources, Legal or Compliance Departments. All reports of potential non-compliance with the Code or the Company’s policies and applicable procedures made in good faith will be reviewed and investigated.

TO REPORT A KNOWN OR POTENTIAL VIOLATION REGARDING EMPLOYEES, BUSINESS PARTNERS OR BUSINESS ACTIVITIES

IN the US, visit: reportlineweb.com/relypsa

OUTSIDE the US, visit: speakupfeedback.eu/web/chup6u

http://reportlineweb.com/relypsa

http://speakupfeedback.eu/web/chup6u

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MAINTAINING PATIENT FOCUS WE ACT IN THE BEST INTERESTS OF OUR PATIENTS, CUSTOMERS AND COMPANY.

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We are all responsible for the timely reporting of safety, quality or performance issues related to our products. We must immediately report (within one business day) any suspected adverse events or product complaints regarding our products to the appropriate Vifor Pharma Group Global Drug Safety or Quality Assurance Departments, respectively.

To report an adverse event or raise a concern, please contact your local affiliate drug safety group or the global drug safety group whose contact details are set out below:

GLOBAL DRUG SAFETY

Phone +41 79 788 03 09

Fax +41 58 851 86 59

E-mail [email protected]

ADVERSE EVENTS AND PRODUCT COMPLAINTS

We believe product safety and quality are critical to our mission.

The Vifor Pharma Group is committed to the safety and well-being of our patients. Our ability to ensure the delivery of safe and effective products to customers depends on our ability to identify potential adverse events and product complaints. An adverse event occurs when a patient has an unintended medical response while using one of our therapies. Potential adverse events may include overexposure, overdose, abuse, misuse, medication error, product defect or a product quality complaint.

We comply with all laws and regulations regarding drug safety and reporting. We have established policies, applicable procedures and controls for tracking, investigating, assessing and reporting adverse events to the appropriate regulatory authorities. In addition, we have a quality system in place to track deviations, complaints and other information potentially related to adverse events.

mailto:safety%40viforpharma.com?subject=


INTERACTIONS WITH HEALTHCARE PROFESSIONALS

We hold ourselves to high ethical standards in our interactions with healthcare professionals to maintain our reputation and credibility.

The Vifor Pharma Group interacts with healthcare professionals (often called HCPs) for the ultimate benefit of the patients we serve. Some of our core interactions relate to the sale and marketing of our products, research and development and other consulting services. To maintain our reputation and credibility, we are committed to ethical and compliant interactions with healthcare professionals in all of our business activities.

Our Company defines a healthcare professional as any person who is a member of the medical, dental, pharmacy or nursing profession, or who is affiliated with a healthcare organisation, or any other person who, in the course of his or her professional activities, may prescribe, purchase, supply, recommend or administer a medicinal product, including any official or employee of a government agency.

All interactions with healthcare professionals must adhere to the Code and the Company’s policies and applicable procedures, which reflect applicable laws and industry codes. We should always focus on the benefit to patients when interacting with healthcare professionals.

Marketing interactionsWe are committed to ethically promoting our products and services and recognise the importance of providing healthcare professionals with the accurate scientific and medical information they need to make informed prescribing decisions.

Although the laws and regulations governing the promotion of pharmaceutical drugs to healthcare professionals vary by region, our Company has adopted the following global principles for all promotional and marketing-related interactions:

– We promote consistency with the approved product characteristics or indications

– We make truthful, accurate, balanced, fair, objective and complete claims

– We provide relevant product safety information – We do not provide any items or services to

inappropriately influence or induce the use or recommendation of our products

Research interactionsWe are committed to scientific integrity in all of our research activities and recognise the important role healthcare professionals play in the development of new products and services. Research-based interactions with healthcare professionals are structured to maintain the independence and integrity of the research conducted. Moreover, our relationships with healthcare professionals conducting research related to our products and services may not inappropriately influence the design or results of research activities.

Other healthcare professional consultant interactionsWe are committed to only engaging healthcare professionals for consultant services where there is a clearly defined need, legitimate purpose and scope. In such circumstances, healthcare professionals must be paid fair market value for services provided. Consultant interactions and payments may not be used to influence or induce the use or recommendation of our products and services.


MAINTAINING PATIENT TRUST

We must never deceive, mislead or inappropriately induce individuals to participate in our research activities.

Patient organisationsWe interact with patient organisations to improve patient care by advancing education and awareness. All interactions with patient organisations should be consistent with the mission of the patient organisation. While, in some instances, we may provide support to patient organisations in a manner consistent with the Code and the Company’s policies and applicable procedures, any such support should be properly documented and structured to maintain the independence of the organisations.

We always act in the best interest of our patients.

The Vifor Pharma Group interacts with patients for the purposes of conducting clinical research, supporting patient advocacy groups and improving disease awareness. The intent of these activities is to enhance patient education, access to medicines and care. As such, we are committed to always acting with transparency and responsibility in all of our patient interactions.

All activities with patients, including research, must adhere to the Code and the Company’s policies and applicable procedures, which reflect applicable laws and industry codes focusing on patient interactions.

Communications with patientsWe are committed to ensuring our communications with patients focus on providing the information they need to make informed, personal medical decisions. Such communications must be tailored for patient audiences and not healthcare professionals.

Privacy and patient informationWe respect the privacy of every patient. During the course of our business activities, we may come into contact with or obtain patient personal information. We comply with patient privacy laws, which among other things, may require patient consent before patient information may be used for business activities. In instances where patient information may be used by the Company, we are obligated to securely collect and protect personal information to prevent data security breaches. For further information on patient privacy requirements or to report any potential misuse or loss of patient personal information, please contact the Legal or Compliance Departments.

ResearchWe strive to ensure our research activities are conducted to high standards, especially those involving interactions with research subjects. All research subjects must be provided with complete and full disclosure of the purpose and nature of the activity in which they seek to participate.


MANUFACTURING, QUALITY AND SUPPLY CHAIN

Manufacturing Practice (GMP) and Good Distribution Practice (GDP). Furthermore, we require the same level of quality commitment from our suppliers and business partners who provide services for the Company.

Additionally, we understand our role in protecting patients from counterfeit or tampered products. Counterfeit or tampered products present a danger to patients, our reputation and our trust with customers.

Timely reporting of any potential quality concerns is critical to ensuring the integrity of our products. Any potential quality issues or concerns must be reported to the Quality Assurance, Legal or Compliance Departments.

We know that achieving our goal of becoming a leading global pharmaceutical company starts with ensuring the quality of our products.

The Vifor Pharma Group recognises that patients rely on our products to improve their health. We must maintain this trust by adhering to strict quality control standards in the testing, manufacturing, packaging, storage and transport of our products.

We are committed to maintaining a comprehensive quality assurance and control programme to support our compliance with internationally recognised Good Practice quality guidelines (GxP), especially Good Clinical Practice (GCP), Good Laboratory Practice (GLP), Good


ETHICAL RESEARCH

prohibited. We believe in transparency in our research by reporting all results, whether positive or negative.

We respect the rights of individuals involved in our research activities and fully and completely disclose the purpose and nature of the clinical studies in which they participate. We also protect patient privacy by establishing standards and protocols for the use and storage of patient personal information.

We strictly adhere to applicable animal welfare laws, industry codes and standards relating to the responsible treatment of animals in research. We comply with the principles of the 3Rs (Reduce, Refine, Replace) and are committed to the development of new medicines using scientifically validated alternative testing methods that do not require animals.

In situations that require the use of animals to conduct re-search, it is our responsibility to ensure animals are treated respectfully and with a high level of ethical concern.

We strive to meet ethical and scientific standards in all of our research activities.

The Vifor Pharma Group develops novel, innovative prod-ucts to increase the treatment options available to patients. Ethical research is fundamental to creating safe, effective medicines and maintaining our credibility with customers.

We expect our employees to conduct all research activities in accordance with the Code, the Company’s policies and applicable procedures and recognised international standards for Good Clinical Practices (GCP) and Good Laboratory Practice (GLP). Attempting to unduly influence research results or falsification of research data is strictly


DOING BUSINESS WITH INTEGRITY WE RESPECT AND ADHERE TO ALL LAWS, POLICIES AND REGULATIONS GOVERNING BOTH OUR COMPANY AND INDUSTRY.

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ANTI-RETALIATION

We prohibit retaliation against any employee who raises a compliance concern in good faith. Retaliation includes any employment decisions, intimidation, harassment or other misconduct that has the intent of punishing an employee in response to reporting an identified or potential violation or assisting in a Company investigation.

We take reports of retaliation or harassment against those reporting identified or potential compliance violations seriously and will take appropriate disciplinary action when warranted.

We prohibit retaliation or harassment against anyone who, in good faith, reports an identified or potential violation of the Code or the Company’s policies and applicable procedures and applicable laws.

Our Company seeks to create a workplace that promotes an open and trusting environment.

We value our employees and have established Company policies and applicable procedures to encourage the reporting of potential illegal, unethical or otherwise non-compliant conduct without fear of retaliation.


COMPLIANCE WITH LAWS AND REGULATIONS

fair competition, privacy, labour and employment and environmental protection. While employees are not expected to know the details of every law or regulation, we should remain aware of the core requirements established in this Code and understand when to seek advice.

Each of us is expected to be familiar with the Company’s policies and applicable procedures relevant to the area in which we work. When appropriate, our Company provides training and education relevant to the laws and regulations governing our employees. Situations may arise in which the laws and regulations are not clear. In these cases, employees are expected to contact their manager or the Legal or Compliance Departments for additional guidance.

We respect and adhere to the laws and regulations governing our industry.

At the Vifor Pharma Group, we are committed to following all laws and regulations applicable to our business activities, especially those designed to protect patients and improve the quality of medicines and healthcare services. As a global company, we recognise that the laws and regulatory requirements of one country may apply to our activities taking place in another country.

Furthermore, the laws and regulations governing our Company cover a wide range of business activities, such as clinical research, product marketing, securities trading,


PARTNERSHIP WITH GOVERNMENT AUTHORITIES AND REGULATORS

Similarly, we expect all employees to cooperate with internal Company audits and investigations by providing honest, truthful and complete information without fear of retaliation.

We operate in good faith when interacting with government authorities and regulators.

We cooperate with all government authorities and regulators in connection with Company audits, potential investigations or requests for information. When contacted by government authorities regarding a non-routine request, we expect all employees to immediately contact the Legal Department, who will advise on our rights and obligations as a company. Employees must not lie or in any way obstruct government authorities’ requests for information.


BUSINESS PARTNERS AND THE CODE

As such, the Vifor Pharma Group seeks to work with only qualified and reputable business partners whose values and standards for conducting business are aligned with the Code as well as applicable laws, regulations and industry codes relating to generally accepted ethical standards for the protection of human rights, prohibition of child or forced labour and human trafficking, prohibition of money laundering and prohibition of corruption and bribery.

To ensure this, select business partners undergo regular and comprehensive screenings before entering into a business relationship with the Company. Furthermore, engagements with business partners who do not meet the Company’s values and standards will be terminated. We are all responsible for holding our business partners accountable and employees are encouraged to collaborate with only reliable and ethically sound business partners.

Employees must report any business partner related concerns to their manager or the Legal or Compliance Departments.

We require our business partners to uphold the values and standards of the Vifor Pharma Group when acting on our behalf.

The Vifor Pharma Group expects all employees to promote the values and standards established by the Code. These very same expectations are also applied towards the Company’s business partners such as external consultants, partners, agents, suppliers, vendors or other entities acting on behalf of the Vifor Pharma Group.


BRIBERY AND CORRUPTION

While gifts, meals and hospitality are often part of customary business or professional relations, employees must exercise care to ensure such courtesies do not implicate anti-bribery laws and industry codes. Employees may provide these courtesy items to demonstrate respect, appreciation and good etiquette, in accordance with the Code and the Company’s policies and applicable procedures.

If employees are presented with an offer or demand for a bribe or “kickback” or are in a situation where they are unsure whether a gift may be accepted, they should immediately contact their manager or the Legal or Compliance Departments.

We conduct our business with transparency and prohibit bribery of any kind.

The Vifor Pharma Group is committed to integrity and transparency in all of our business dealings. As such, the Company strictly prohibits any and all forms of bribery and corruption when interacting with healthcare professionals, customers, government officials, suppliers and vendors.

Employees, as well as third parties acting on behalf of the Company, must never offer, promise, provide or authorise payments to improperly influence or gain an unfair business advantage in our business dealings or to illegally advance our business or financial interests. Additionally, we prohibit accepting any offer or demand for a payment that would affect our ability to act in the best interests of the Company. This includes the offering of “facilitating” or “grease” payments to public officials in order to expedite or secure performance of non-discretionary, routine governmental actions (e.g., processing a visa, customs invoice or other governmental paper).


FAIR COMPETITION

Many countries have complex antitrust or fair competition laws. While employees are not expected to understand all the requirements of these laws, we must recognise the intent behind them and know when to contact the Legal Department for guidance.

We are committed to fair and open competition.

The Vifor Pharma Group complies with laws that protect free enterprise and fair competition. We seek to compete in our industry based on the merits of our people and products. We do not participate in unethical business practices such as deceptive marketing, unauthorised use of confidential competitor or customer information or the theft of trade secrets.

Moreover, we prohibit agreements or arrangements between the Company and our competitors that aim to coordinate market behaviour. This includes allocating territories or specific customers as well as fixing or coordinating prices. Employees should keep in mind that any such agreement with a competitor, formal or informal, may have serious legal consequences.


CONFLICTS OF INTEREST

or any number of other activities where an employee’s interests may not align with those of the Company.

Never abuse your position or Company property for your own personal benefit. We must always conduct business in a way that serves the interests of the Company and is not influenced by personal, family or financial interests.

Employees must disclose all potential conflicts of interest to their manager or the Human Resources, Legal or Compliance Departments.

We seek to ensure our decisions and actions are always for the benefit of the Company.

The Vifor Pharma Group recognises and respects the rights of employees to engage in outside activities. As employees, we should avoid situations that present a conflict between our personal interests and the best interests of the Company. Additionally, we should avoid situations that may create even the appearance of a conflict of interest. A conflict of interest may involve internal Company activities, external opportunities or employment, vendor relations, human resource decisions


GIFTS AND ENTERTAINMENT

We must adhere to the following requirements when giving or accepting gifts or entertainment:

– Gifts and entertainment must be of modest value, consistent with customary business practices and cultural norms

– Gifts and entertainment must not be lavish, excessive or based on a quid pro quo understanding

– Requesting or soliciting gifts or entertainment is strictly prohibited

The giving or accepting of gifts and entertainment must adhere to the Code and the Company’s policies and applicable procedures, especially those focusing on anti-bribery, corruption and interactions with healthcare professionals.

For further clarification or guidance, employees should consult their manager or the Human Resources, Legal or Compliance Departments.

We do not give or accept gifts and entertainment that could call into doubt our personal integrity.

The Vifor Pharma Group understands that giving or accepting gifts and entertainment is often associated with customary business practices as well as cultural norms. Under these circumstances, giving or accepting gifts and entertainment may be appropriate, so long as it is done with pure intent and not for the purpose of unduly influencing the recipient, whether it be a third party or Company employee.

Even the appearance or perception of an improper gift or entertainment could compromise the business operations and reputation of the Company. As such, employees must use caution when giving or accepting gifts and entertainment during the course of their interactions with our business partners, vendors, suppliers and other third parties.


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MANAGING INFORMATIONWE USE COMPANY ASSETS AND INFORMATION RESPONSIBLY TO ADVANCE OUR BUSINESS GOALS.


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PRIVACY

Personal information includes any data or details that may be used to identify an individual, such as name, gender, age or date of birth. We take precautions to safeguard personal information from intentional or accidental exposure. Unless permitted by law, we do not use or share employee, patient, business partner or healthcare professional personal information without the prior consent of the affected individuals.

Our Company seeks to promote responsible data protection and security principles for the collection, processing and disclosure of personal information. For information on specific requirements, please contact the Legal Department.

We respect the privacy of our employees, patients, business partners and healthcare professionals and are committed to protecting the integrity of all personal information held by the Vifor Pharma Group.

The Vifor Pharma Group collects, retains and uses employee personal information in order to support everyday business activities related to the management of employee compensation, benefits and other Company administrative purposes. Similarly, from time-to-time, we may collect, retain and use patient or customer-related information during the course of our business activities. We treat and protect all personal information, whether internal or external, in a manner consistent with local legal and regulatory requirements. This often means that the Company must obtain an individual’s consent before receiving or using their personal information.


ASSET PROTECTION AND CONFIDENTIALITY

Tangible Company assets should primarily be used for the advancement of our business interests. We expect employees to limit their personal use of Company assets such as phone, email, computers and office supplies to a reasonable amount. The Company reserves the right to regularly review and monitor Company property to ensure its use is consistent with the Code and the Company’s policies and applicable procedures. Upon termination of employment, all Company property should be returned in accordance with Human Resources policies and applicable procedures.

We also provide and use a wide variety of intangible Company assets, such as patents, customer data, non-public information and other intellectual property, during the course of our business activities. These assets must also be protected from misuse or loss by adhering to the Company’s policies and applicable procedures on information security. Employees must maintain the confidentiality of Company business information, even after their employment with the Company ends.

Employees must report any suspected misuse of Company assets, whether tangible or intangible, to their manager or the Human Resources, Legal or Compliance Departments.

We use Company assets responsibly to advance our business goals.

The Vifor Pharma Group provides employees with access to a variety of Company assets, both tangible and intangible, for use in the course of carrying out their job responsibilities. We expect all employees to properly use and protect Company property and confidential data from loss, damage, misuse or theft.


RECORD KEEPING

Additionally, all Company records must be maintained, stored and, when appropriate, destroyed in accordance with Company records retention policies and applicable procedures. In certain instances, such as those involving legal proceedings or government authorities, we may be required to maintain records for periods longer than those described in Company records retention policies. To understand which records must be preserved, or if a question arises as to the interpretation of a Records and Information Retention Policy, please contact the Legal Department.

We maintain accurate records of our business activities to sustain our operations as well as satisfy legal and regulatory requirements.

Maintaining accurate business records is essential not only to sustaining our day-to-day business operations but also preserving our credibility with customers, regulators and vendors. The Vifor Pharma Group is committed to maintaining accurate records for all of our Company’s activities. Records include all documents created in the course of business, reports for our own management and reports made available to our customers, regulators, vendors and other stakeholders.

We adhere to Generally Accepted Accounting Principles (GAAP), research practice guidelines and quality requirements for the recording and reporting of financial reports, scientific data and quality records, respectively. All reports, including the underlying books and records, must be complete, accurate and reliable. The Company maintains internal controls designed to promote effective and efficient record keeping and reporting consistent with applicable legal requirements.


INSIDER TRADING

others, including friends or family members. Inside information, if disclosed or used, may have a significant impact on the Company and its employees, including criminal penalties.

Securities laws and Company policy restrict us from disclosing or using any inside information gained, either intentionally or by mistake, while employed at the Company. Only authorised Company employees are allowed to make previously confidential Company information public in accordance with the principles of ad hoc publicity and the requirements of the Swiss stock exchange, SIX Swiss Exchange (SIX), or regulation of any other relevant stock exchange.

We must not use or disclose confidential Company information.

During the course of performing our job responsibilities, we may learn of confidential, non-public information regarding the Company’s business, including planned activities or transactions with business partners. We must respect and maintain the confidentiality of such “inside” information. It is illegal and unethical to use inside information or provide inside information to others for use in trading securities, also known as insider trading.

Employees may never take advantage of confidential information about the Company or its business partners for personal financial gain or pass that information to


MEDIA AND INVESTOR RELATIONS

responsible for handling all external communications with the media and investors, respectively. Only authorised spokespeople are allowed to make public statements on behalf of the Company related to our products or corporate developments.

We are committed to delivering timely and reliable information to the public. All communications to the media and investors must be approved in accordance with Global Communications & Public Affairs and Investor Relations policies and applicable procedures. Company employees other than designated spokespeople are not authorised to answer questions from the media or investors. Employees must direct all media and financial inquiries to the Global Communications & Public Affairs and Investor Relations Departments, respectively.

We are committed to delivering accurate and timely material information to the public, including the media and our shareholders.

The Vifor Pharma Group operates in a global environment where many stakeholders, including individual and institutional investors, may be impacted by our business operations and the decisions we make. External communications with these stakeholders must be carefully managed in order to preserve the Company’s reputation as well as fulfill securities laws relating to the disclosure of material information to the public by publicly traded companies.

The Vifor Pharma Group Global Communications & Public Affairs and Investor Relations Departments are


SOCIAL MEDIA

Employees may not share or communicate the Company’s business, including information related to our products, research programmes, business development activities and other potential confidential information.

While it is impractical to provide specific guidance on every form of acceptable use of social media, employees should use caution when posting any information online that may relate to the Company. We expect employees to communicate appropriately on all platforms and adhere to the employee standards of conduct described in this Code. For further guidance on the Company’s Social Media policies, please consult the internal Social Media Guidelines or contact the Global Communications & Public Affairs Department.

We use social media responsibly in a manner that reflects the values of our organisation.

The Vifor Pharma Group interacts with customers, patients, business partners, media and investors through various social media platforms. Additionally, employees may use social media for personal reasons outside of the scope of their job responsibilities.

Social media includes all internet-based communication tools that enable interacting, sharing and the management of information with others. Examples of social media platforms include, but are not limited to, Facebook, YouTube, Instagram, Twitter, Reddit and LinkedIn.

Only authorised employees may post information on the internet or social media platforms on behalf of the Company. All such social media communications created or shared must adhere to the Company’s policies and applicable procedures relating to the review, approval and dissemination of external information.

Employees utilising social media for personal use should understand that their views may be attributed to the Company and that they should exercise sound judgment.


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SUPPORTING PEOPLE AND COMMUNITIES WE VALUE OUR EMPLOYEES, OUR COMMUNITIES AND THE ENVIRONMENT AROUND THE GLOBE.


CODE OF CONDUCT AND BUSINESS ETHICS / SUPPORTING PEOPLE AND COMMUNITIES / 3633

WORKPLACE SAFETY

manufacturing or field-based setting. We adhere to all laws, regulations and industry standards relating to workplace safety and employee well-being. Additionally, our Company has implemented workplace safety best practices, Company safety policies and applicable procedures and employee training, where appropriate, in order to reduce the risk of workplace injury or harm.

We rely on employees to exercise care and caution in their workplace activities and promptly report any potential safety concerns to the local safety officer at the relevant site, their manager or the Human Resources Department. For safety relating to our manufacturing operations, please report potential concerns to the manufacturing site’s Safety Officer.

We are committed to the well-being of our employees and aim to provide a safe, healthy and secure workplace.

The Vifor Pharma Group recognises the importance of treating employees with respect and creating a positive work environment. We recognise that our employees are our greatest asset and have a choice in working for the Company. Thus, we strive to offer employees the tools and resources to not only achieve our organisational goals, but also their own development objectives in a safe and healthy work environment.

Employees have the right to safety while working on behalf of the Company, whether in an office, clinical,


ENVIRONMENTAL WELFARE

daily tasks. Additionally, we must strive to conserve resources and reduce waste and emissions through recycling and other energy conservation measures to protect the communities in which we live and work.

We respect and care for the environment through responsible business practices.

The Vifor Pharma Group values the environment and seeks to minimise the impact of our business operations. We recognise that long-term commercial success is achieved through sustainable business practices and compliance with environmental laws, regulations and industry standards.

Employees should use due care and diligence when conducting activities or handling materials that may pose harm to the environment. To this end, we have established Company policies and applicable procedures for employees to follow. We are responsible for promptly reporting potential environmental accidents to Company management and, in some cases, environmental reg-ulatory agencies. We are committed to correcting any environmentally unsafe conditions or practices in our


POLITICAL INVOLVEMENT AND CONTRIBUTIONS

Employees should direct all requests for political contributions or support to the Global Communications & Public Affairs Department.

We respect employees’ rights as private individuals to express their political beliefs.

The Vifor Pharma Group supports employees’ rights as private individuals to express their beliefs through participation in the political arena. However, on behalf of the Company, we have established standards for political engagement to ensure our actions best impact the interests of the Company and the communities in which we operate.

Employees may not support their private political causes in the course of their job responsibilities or on behalf of the Company. However, we respect employees’ rights to do so as private individuals using their own personal time and resources. Additionally, employees may not solicit or request other employees, customers or vendors for political contributions or support.


CHARITABLE INVOLVEMENT AND CONTRIBUTIONS

monetary support and in-kind donations of goods or services. We encourage employees, as private individuals, to support causes that improve our communities or are of personal interest.

However, for all Company-requested support, employees should direct requests to the Global Communications & Public Affairs Department and may not promise or otherwise commit the Company’s support for a charitable request. All Company charitable support must be reviewed, approved and funded in a manner consistent with the Company’s policies and applicable procedures. For questions or details on the types of charitable organisations and causes supported by our Company, please contact the Global Communications & Public Affairs Department.

We support charitable causes that align with the Company’s values and mission.

We recognise the visibility of our Company and our ability to improve the world in which we live. Supporting charitable and philanthropic causes helps further our mission of making a meaningful difference in patients’ lives. We have established standards for contributing to charitable causes to ensure the Company’s resources are maximised for the greatest benefit.

Although there are many charitable organisations and causes the Company could support, the Company focuses its resources on those that align with our values and mission. Support for charitable organisations or causes may come in the form of Company sponsorships,

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Vifor Pharma Group Vifor Pharma Management Ltd. Flughofstrasse 61 CH-8152 Glattbrugg

Phone +41 58 851 80 00 Fax +41 58 851 80 01 E-Mail [email protected] Web www.viforpharma.com

Vifor Pharma Group © 2017

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