In terms of the Shelys’ Organizational Ethics & Legislative Compliance Policy, the Board is ultimately responsible for overseeing the implementation of organizational ethics and legislative compliance as contemplated in Principle 2 and Principle 13 of King IV, and the associated guidelines, respectively.

In addition to describing management’s responsibilities, the Policy establishes the Shelys’ Ethics & Compliance function (comprising a Group team and Regional Ethics & Compliance Officers) and describes the role, organisational status, authority, and scope of activities performed by the function.

The Policy also outlines the areas overseen by the Social & Ethics Committee, the Audit & Risk Committee, and the role of Internal Audit in providing periodic independent assurance on the effectiveness of the Ethics & Compliance program.

The Shelys’ Executive Committee, supported by the Group Ethics Committee, maintains oversight of transactions or relationships that could give rise to ethical, compliance or reputational concerns.

Our Local Integrity Committee together with the Group Ethics Commitee is responsible for ensuring that allegations of fraud or related material breaches are appropriately investigated and that disciplinary or other corrective actions are applied fairly and consistently across Aspen SSA companies.

The Shelys Pharmaceuticals’ Code of Conduct (Code) describes the standards of honest, ethical and lawful conduct expected of all employees, officers and directors of the Company, who are required to be familiar with the Code, comply with its provisions and follow Aspen’s procedures to report any suspected violations. Employees and directors are required to sign a Code of Conduct Declaration upon commencement of their employment/appointment.

We promote a culture of openness and transparency throughout the Aspen SSA companies and, as such, employees and other stakeholders such as our suppliers and service providers are encouraged to speak up when they have a reasonable belief or suspicion of unethical or unlawful conduct concerning Shelys’ business. We do not tolerate retaliation against anyone who reports ethical concerns in accordance with the Shelys Whistleblowing Policy. An independently monitored whistleblowing hotline – Deloitte’s Tip-Offs Anonymous Hotline – is available to all our employees and other stakeholders to report suspected fraud, bribery, human rights violations or other activities in breach of our Code of Conduct. Our Whistleblowing Policy provides guidance to prospective whistleblowers and details the protections available to them, including protection against retaliation. Training and awareness sessions are conducted periodically to promote the use of this facility for its intended purpose. Key customers, service providers and suppliers are periodically informed of the availability of this line. All reports from this hotline or from other whistleblowing sources received during the year are logged and, where appropriate, reported to the relevant managers timeously after consideration by the Group Ethics Committee. Disciplinary action is taken in instances where employees are found to have transgressed, with corrective actions implemented where necessary to improve controls and to prevent recurrence of the incident. All instances of misconduct, which may also constitute criminal conduct, are reported to local prosecution authorities as may be appropriate. Reports detailing the tip-offs received, how these tip-offs have been investigated and the corrective measures taken, are submitted to the Audit & Risk Committee and Social & Ethics Committee.

Our Group Conflict of Interests Policy prohibits all employees, officers and directors of Shelys from using their position within Shelys, or Shelys’ relationship with its customers, suppliers, contractors and other business partners for private gain, or to obtain benefits for themselves or their family members. Employees and directors are required to sign a Conflict-of-Interest Declaration upon commencement of their employment/appointment, and on an annual basis thereafter. Conflicting interests that are disclosed are reviewed by the Ethics Committee and are either disallowed or approved based on an agreed mitigation plan. Each business unit maintains a Conflicts of Interest Register, which is submitted to the Group Head: Ethics & Compliance on an annual basis.

Our Gifts & Hospitality Policy requires that where employees, officers and directors exchange gifts and hospitality with suppliers, service providers or customers, they must ensure that it is not intended or might be seen to influence business decisions, that there is a legitimate business interest for giving or accepting the gift or hospitality and that it remains once-off or irregular in nature. In addition, any prior approvals based on value thresholds must be strictly adhered to. Shelys maintains a Gifts and Hospitality Register which is submitted to the Group Head: Ethics & Compliance on an annual basis. Employees perform Shelys’ Ethical Business Conduct training at the commencement of their employment with Shelys, and on an annual basis and/or when required thereafter. The training addresses the standards of ethical business conduct set out in the Code and the mechanisms available to report concerns.

We periodically request our employees to participate in an anonymous Ethical Culture Survey to measure and understand our ethical culture and implement measures to address areas of concern.

In executing our business strategy, we engage with an extensive network of material suppliers, service providers, contract manufacturers, distributors and other business partners (collectively our ‘suppliers’). Ensuring our goods and services are ethically and responsibly sourced is paramount to our responsible corporate citizenship philosophy. We aim to only work with suppliers whose values and standards of ethical behaviour are consistent with our own. The Shelys’ Supplier Code of Conduct was developed to articulate the ethical, social and environmental performance standards we require from all suppliers that we have a relationship with. Our approach to maintaining a responsible supply chain includes risk assessment and mitigation, as well as participation in industry collaborations that improve supply chain environmental, social and governance (ESG) practices, such as the Pharmaceutical Supply Chain Initiative (PSCI).

As a participant of the UN Global Compact, we are committed to upholding the principles of respecting and protecting internationally proclaimed human rights, as well as ensuring that we are not complicit in human rights abuses.

Our Human Rights Policy records our commitment to conducting our business in a way that respects the human rights of stakeholders across our value chain and the related procedures and governance structures in place to give effect to this commitment.

Aligned to the requirements of the UK Modern Slavery Act, the Australian Modern Slavery Act and equivalent legislation in the jurisdictions in which we operate, we report annually on the procedures and initiatives we have implemented to embed human rights commitments within our business and supply chain.

Our Policy on Product Promotion and Scientific Engagement sets the standards for ethical interactions with healthcare professionals as part of our promotional and non-promotional activities. Shelys Pharmaceuticals’ relationships with healthcare professionals are intended to benefit patients and to enhance the practice of medicine. Interactions are focused on informing healthcare professionals about medicines, providing scientific and educational information, and supporting medical research, and education.

Our Advocacy and Government Relations Policy sets the standards for ethical engagement with other stakeholders in the healthcare community (government authorities, scientific societies, trade associations, experts, patient organizations and non-governmental organizations) on matters of public policy that affect patients, the pharmaceutical industry, and our business, in the countries in which we conduct business. The Policy also addresses the subject of employing certain former government officials. It requires an assessment of, and where necessary, implementation of a cooling-off period to maintain transparency, avoid conflicts of interest and maintain trust in public sector decision-making.

Information on the financial or other support Shelys Pharmaceuticals provides within the healthcare community is outlined under the section on Corporate Social Investment.

Governance structures and procedures are in place for providing financial resources and in-kind support to external parties. These ensure that all external funding activities align with Shelys’ mission, values, and strategic goals, while promoting transparency, accountability, and ethical stewardship of resources aligned to accepted industry practices.