GLOBAL CODE OF CONDUCT

Transcription

1 GLOBAL CODE OF CONDUCT

2 TABLE OF CONTENTS 1/ OUR CODE OF CONDUCT: ORIGINS AND OBJECTIVES 4 How we work 4 Our responsibiity for the Code 6 Reaching out 7 2/ WE PRODUCE AND SELL QUALITY PRODUCTS TO IMPROVE PUBLIC HEALTH 9 Targeting quaity and safety 9 Interacting with heathcare providers 10 Promoting and marketing 11 3/ WE TRADE IN ACCORDANCE WITH THE RULES 12 Internationa trade 12 Interacting with our business partners with integrity 13 Respecting fair competition 15 No toerance for corruption 16 Ensuring financia integrity/anti money-aundering 17 Records management 18 4/ WE ENSURE THAT WE PROCESS DATA WITH ETHICS 20 Respect for privacy and persona data protection 20 Bioethics and research compiance 22 Patient data protection 22 5/ WE CARE FOR THE WELL-BEING OF OUR STAFF 23 Commitment to empoyees 23 Respecting human rights 25 Avoiding conficts of interest 26 6/ WE INTERACT THOUGHTFULLY WITH OUR COMMUNITY 27 Protecting the environment 27 Supporting phianthropy and corporate socia responsibiity in ine with our vaues 28 7/ WE COMMUNICATE CAREFULLY 29 Handing confidentia information 29 Ensuring appropriate use of the information system 31 Respecting inteectua property rights 32 Insider information and trading 33 OUR GLOBAL CODE OF CONDUCT 1

3 FOREWORD BY EXECUTIVE COMMITTEE & CHAIRMAN Jean-Luc Beingard Aexandre Mérieux Miche Baguenaut Pierre Bouud Nicoas Cartier Chairman CEO Genera Secretary, Corporate VP, Human Resources and Communications Corporate VP, Asia Pacific Region Corporate VP, Industry Unit, Group Portfoio & Strategic Panning Pierre Charbonnier Caire Giraut François Lacoste Mark Mier Yasha Mitrotti Corporate VP, Manufacturing & Suppy Chain Corporate VP, Chief Financia Officer Corporate VP, Cinica Unit Chief Medica Officer Corporate VP, Europe, Midde East, Africa Region & Goba Commercia Performance A word eader in in vitro diagnostics for more than 50 years, biomérieux is committed to serving pubic heath, in the fight against infectious diseases and antimicrobia resistance. Achieving this objective in the right way is aso paramount to us. biomérieux requires a empoyees, incuding a members of management, to maintain high standards of integrity and to act with fairness and respect in a types of activities. The Goba Code of Conduct provides the baseine expectations for working with others and iustrates our corporate vaues. Corrupt or unethica behavior is not toerated at biomérieux. This document is an indispensabe reference for each and every one of us, to hep make the right decisions, at the right time, in an increasingy compex professiona environment. Respecting this commitment to ethics and integrity is vita to carry out our work and continuousy serve pubic heath, our customers, the patients and a of our stakehoders. We count on the engagement of a empoyees to safeguard our Company s core vaues and cuture. Aain Puquet Randy Rasmussen Kirk Ririe Stefan Wiemsen Corporate VP, CTO & Innovation Corporate VP, Moecuar Bioogy Chief Innovation Officer Corporate VP, Americas Region, Group Chief Lega Officer If you have any questions, your management, your Human Resources partner, the Lega Department and your Compiance Officer are avaiabe to assist you. OUR GLOBAL CODE OF CONDUCT 3

4 ADVANCING HEALTH BEYOND BORDERS The Code appies to everyone at biomérieux The Code appies to a empoyees, subsidiaries, affiiates, officers and directors of biomérieux. We aso seek to appy the same principes expressed in the Code to our suppiers, customers, distributors and third parties. Using the Goba Code of Conduct An interactive document on the intranet provides more detais, incuding questions and answers, inks to interna poicies, and interna contacts. Each empoyee is responsibe for impementing the Code. 1/OUR CODE OF CONDUCT: ORIGINS AND OBJECTIVES HOW WE WORK Our Company has a strong reputation, based on vaues handed down through generations. These roots aow us to continue to grow as eaders in our fied. In order to maintain our eadership position, we must conduct our business activities in accordance with our ethica principes and in compiance with existing aws and reguations. We understand that our expertise in infectious diseases and our internationa presence gives us an obigation to act as a responsibe corporate citizen, serving the patients, the medica community, our customers, sharehoders and a stakehoders of biomérieux. The Goba Code of Conduct is meant to guide our actions and hep us integrate the Group s vaues into our daiy professiona ives. Our Code is pubicay avaiabe in severa anguages. We must a read the Code thoroughy to understand the Company s expectations and refer to it each time we have questions or concerns. What if the rues in my country are different from what is written in the Code? Where oca aws require a higher or additiona standard, the oca aws must be appied. If, by contrast, this Code provides for a higher standard, then the Code wi prevai. However, if there is a confict between oca aws and this Code, pease notify the Ethics & Compiance Department as defined in the "Reaching Out" section. Vioations of the Code This Code is more than words on paper - it must guide our actions as representatives of biomérieux. Unethica or iega behavior is not toerated. Each empoyee in the organization is expected to stricty adhere to this Code. Any empoyee who vioates this Code, or encourages, or authorizes such vioation, wi be subject to discipinary action, up to and incuding termination of empoyment. Through our commitment to the Code, we act on that responsibiity in a tangibe way. 4 OUR GLOBAL CODE OF CONDUCT - 1/ Our code of conduct: Origins and objectives OUR GLOBAL CODE OF CONDUCT - 1/ Our code of conduct: Origins and objectives 5

5 OUR RESPONSIBILITY FOR THE CODE OF CONDUCT Ethics & Compiance is the responsibiity of everyone Through our Ethics & Compiance Program, we emphasize that our actions must be based on our core vaues. By foowing this Code, together with the Ethics & Compiance Program, we can avoid the potentiay damaging consequences of non-compiance. Foowing this Code is the responsibiity of everyone at biomérieux. Our actions at work every day have a direct infuence on the Company. The Ethics & Compiance Department provides onine and in-person mandatory training courses on topics that appy to you in the scope of your work at biomérieux. This training is necessary to ensure that you know how to identify and avoid risks that coud hurt biomérieux or its empoyees. If you are a manager, you are responsibe for making sure that your direct reports compete a assigned training. Iega or unethica behavior on the part of even one empoyee can cause significant damage. In many areas, the impact of non-compiance coud resut in costy fines, crimina prosecutions and destroy one of biomérieux s most vauabe assets: its reputation. Managers have specia responsibiity for the Code A cuture of ethics must start from the top. Managers shoud first and foremost mode the vaues of the Code through exempary persona eadership and ethica behavior. Managers are encouraged to promote the importance of compiance by making it a key consideration in decision-making. A managers are responsibe for the organization and supervision of the empoyees who report to them. Managers must ensure that their empoyees are aware of the Code and hep answer any questions their empoyees may have. If there are serious concerns about the Code or behavior that may vioate the Code, managers are expected to escaate those concerns to their management or to the Ethics & Compiance Department. The managers responsibiities do not reieve empoyees of their own responsibiities, but hep to ensure that key messages of compiance are deivered, respected, and foowed throughout their organizations. Loca Compiance Teams have responsibiity for impementing the Goba Code of Conduct in biomérieux s affiiates Our ethica principes extend to every pace we operate. For this reason, we have estabished oca Compiance teams in each site that are responsibe for supporting the deveopment of ethics and compiance. These teams hep ensure that corporate poicies, as we as oca aws and procedures, are understood and appied, and must escaate serious compiance concerns to the Ethics & Compiance Department. Beside a network of data privacy representatives covers a sites. The Code is meant to guide our actions and hep us integrate the Group s vaues into our daiy professiona ives. REACHING OUT biomérieux encourages a cuture of openness where empoyees can fee comfortabe raising concerns. This openness is essentia for an effective Compiance Program. Without it, probems go unreported and uncorrected and may trigger negative consequences. We are counting on you to hep us maintain the best ethics and compiance program possibe. You are "on the ground" and in the best position to prevent actions that are inconsistent with this Code. By expressing your questions and concerns when a potentia issue arises, we can hep you resove probems. How do I contact Ethics & Compiance? You are encouraged to reach out to your Regiona Compiance Officer directy or contact Ethics & Compiance through Compiance_Officer@biomerieux.com. The Goba Data Privacy Officer can be reached at PrivacyOfficer@biomerieux.com. Who shoud I te if I have a serious concern? When you observe a behavior that you beieve vioates our Code, we expect you to report it. Ideay, you shoud bring any concerns forward to your direct manager, or other member of your management team, who wi escaate the concerns to the proper channes. We recognize, however, that there may be circumstances when you are not comfortabe reporting the issue in this manner. You can aways seek hep from the Ethics & Compiance Department directy or report your concerns through the Ethics Line. We encourage you to report confidentiay rather than keep the information to yoursef. 6 OUR GLOBAL CODE OF CONDUCT - 1/ Our code of conduct: Origins and objectives OUR GLOBAL CODE OF CONDUCT - 1/ Our code of conduct: Origins and objectives 7

6 What is the ethics ine and how do I make a report? The Ethics Line is a confidentia reporting too to assist management and empoyees in working together to address corruption, fraud, or other serious misconduct in the workpace. The subject matter that can be reported through the Ethics Line varies by country, depending on oca aws. In most countries, you may express your concerns confidentiay in your own anguage through our Ethics Line. Reports may be made onine or by phone. For more information on the Ethics Line and frequenty asked questions, visit the Ethics & Compiance page on the intranet under Expressing Concerns. JEAN-PAUL Industria ogistic Marcy Étoie, France Wi I get in troube for reporting something? Empoyees who express a genuine concern wi not be subjected to retaiation, retribution, or any form of harassment. No empoyee at any eve is permitted to engage in such retaiation, retribution, or harassment against any other empoyee for expressing a concern in good faith. Managers may not in any way discourage empoyees from taking concerns or compaints to the proper channes, incuding Ethics & Compiance, Human Resources and Lega. 2/ WE PRODUCE AND SELL QUALITY PRODUCTS TO IMPROVE PUBLIC HEALTH TARGETING QUALITY AND SAFETY When it comes to heathcare, accuracy and attention to detai are not ony important, they can mean the difference between ife and death. Preventing misdiagnoses or mistreatment is at the heart of what we do. We produce high-quaity products that are essentia to the heath of those who depend on them. In a of our functions, we have a specia responsibiity to ensure that safety and quaity are cear priorities. 8 OUR GLOBAL CODE OF CONDUCT - 1/ Our code of conduct: Origins and objectives Compy with ega and reguatory requirements, as we as interna poicies and procedures. Ensure that high-quaity standards are appied at each stage of the manufacturing process. Immediatey report any concerns reated to product non-conformity. Immediatey report customer compaints reated to our medica products to the oca Customer Services and Quaity function/department. OUR GLOBAL CODE OF CONDUCT - 2/ We produce and se quaity products to improve pubic heath 9

7 INTERACTING WITH HEALTHCARE PROVIDERS The utimate purpose of biomérieux s interactions with heathcare providers (HCPs) is to enhance the quaity of patient care and improve pubic heath. HCPs are critica to our mission and provide vauabe assistance in deveoping our products, executing cinica trias, and heping patients with our products. We must never offer or provide anything to an HCP with the intention of inappropriatey infuencing him or her to prescribe, recommend, purchase or suppy our products. There must be a egitimate business reason for a of our interactions with HCPs. Remember that the heathcare industry is highy reguated: what might be considered acceptabe business practices or courtesies in other sectors may not be appropriate when interacting with heathcare providers. We must foow the Corruption Prevention Manua, oca rues and poicies, and industry codes of conduct (such as AdvaMed and MedTech) for guidance on areas such as gifts, hospitaity, and meas. Under the aws of severa countries, any transfer of vaue from our Company to an HCP must be recorded and reported to the government. These transparency aws can require us to report, among other things: gifts, meas, consuting fees, research agreements, and trave expenses. We are responsibe for accuratey recording and reporting any such payment through the reevant process. PROMOTING AND MARKETING Our products provide significant benefits to our customers and their patients. Being informed about our products and services heps our cinica customers to meet the needs of their patients. Providing this information in an accurate, transparent, and fair way is essentia to put our products in the hands of those who need them. Many reguations exist to protect patients from inaccurate or unfair marketing practices that coud utimatey damage their heath. In providing information about our products, you must be sure to respect a appicabe aws, reguations, industry codes and our interna processes and standards. Use ony promotiona or educationa materias that have been approved. Never create your own promotiona materias or ater approved materias without authorization and approva. Promote products ony for their ocay approved uses, as determined by oca reguations. Never offer or provide anything to an HCP with the intention of inappropriatey infuencing an HCP to prescribe, recommend, purchase or suppy our products. Ensure that we foow oca aws and reguations on promoting and marketing to heathcare providers, transparency aws, industry codes of conduct (such as AdvaMed and MedTech), and the Corruption Prevention Manua. Document the business justification for our interactions with HCPs and record payments in accordance with financia poicies and procedures. 10 OUR GLOBAL CODE OF CONDUCT - 2/ We produce and se quaity products to improve pubic heath OUR GLOBAL CODE OF CONDUCT - 2/ We produce and se quaity products to improve pubic heath 11

8 MARINA R&D in moecuar bioogy and microsystems Grenobe, France 3/ WE TRADE IN ACCORDANCE WITH THE RULES INTERNATIONAL TRADE biomérieux has customers and business partners a over the word. In internationa trade, the aws of one country may appy to transactions that occur in another country. Empoyees invoved in internationa trade must be famiiar and compiant with a appicabe aws, reguations and restrictions reating to import, export, boycotts, customs and embargoes. Faiure to foow these restrictions can ead to civi and crimina penaties, as we as the oss of import or export privieges. Export contros The transfer of items from one country to another is subject to aws and reguations referred to as "export contros". Commodities (goods and materias), technoogy (technica data and know-how) and software are a covered by these rues. Export contros aso restrict the re-export of items from one country to another. The aws of a country from which an item originates or is produced may restrict or prohibit exports or re-exports to certain sanctioned countries. Most countries have aws and reguations that restrict or prohibit exports to certain countries, organizations, and individuas. These restrictions are intended to prevent these parties from obtaining knowedge, materias, or technoogy that might be used to harm peope or the environment. Many countries pubish ists of "denied parties" that incude, for exampe, identified terrorist organizations or narcotics traffickers. biomérieux must respect these ists by ensuring that it does not do business with denied parties. Import and customs aws Any tangibe or intangibe item that is brought into one country from another country is an import and is subject to importation and customs rues. As an importer, we are required to exercise reasonabe care in determining the correct cassification, vaue and country of origin for a imports. Understand the Company s poicies and procedures on exports and imports, as we as the reevant trade restrictions. Have a necessary icenses and permissions prior to transferring anything from one country to another. Ensure that any information, such as import and export documentation, provided to governments is truthfu, compete, and timey. Consut designated company experts if there are any questions or errors to address. INTERACTING WITH OUR BUSINESS PARTNERS WITH INTEGRITY Our goba network of suppiers and business partners is a critica asset for biomérieux. Maintaining strong, mutuay beneficia reationships with responsibe suppiers and business partners is integra to serving our customers around the word. Ethica expectations of suppiers and business partners We strive to buid business reationships with suppiers and business partners who share our commitment to ethica business practices. We expect any parties that we do business with to compy with biomérieux s Charter for Responsibe Purchasing. 12 OUR GLOBAL CODE OF CONDUCT - 3/ We trade in accordance with the rues OUR GLOBAL CODE OF CONDUCT - 3/ We trade in accordance with the rues 13

9 This incudes expectations that suppiers and business parties wi: Compy with a aws and reguations in the countries where they operate; Refuse to participate in corruption in any way; Avoid and eiminate anti-competitive practices; Foow internationa trade aws; Take responsibiity for the heath and safety of their empoyees; Respect basic human rights, incuding the prohibition on chid abor, human trafficking, and any other crue, inhumane or demeaning practices; Compy with abor aws; Aow free association of empoyees; Act in accordance with internationa standards and aws reated to environmenta protection. Suppier seection and fair treatment of business partners We endeavor to partner with diverse businesses, aowing them the opportunity to present their products, services and expertise to biomérieux. This incudes sma businesses and those owned by women, minorities, veterans and disabed persons. Suppiers shoud be seected based on price, quaity, deivery, service, diversity and reputation, as we as their commitment to responsibe environmenta and ethica business practices. Conduct business fairy and honesty. Seect business partners and suppiers on the basis of abiity to meet Company interests, vaues and needs, free of persona conficts of interest. Compy with Company poicies and procedures on seection and management of suppiers and other business partners. Ensure that our suppiers understand our ethica expectations. Request remediation if we become aware of a compiance issue, up to and incuding the termination of contracts. RESPECTING FAIR COMPETITION It is in our best interest to promote an industry where business practices are reputabe. Most nationa and regiona economic systems promote free competition as the best way to achieve progress that benefits consumers ives. Fairness in our reationships with our competitors promotes trust from our consumers and makes our work easier. Many business behaviors may be prohibited, depending on the aws of the country where the conduct takes pace. We must refrain from conduct that vioates antitrust and simiar aws reguating competition. Some exampes incude but are not imited to: Price Fixing: Price setting among competitors, directy or indirecty, is a vioation of anti-trust aws and is stricty prohibited. Customer and Market Aocation: It is iega for competitors to agree that they wi not compete for business, which incudes agreements about how to divide up markets, whether by territory, product ine or customers. Empoyees must never discuss or agree to a request or demand from a competitor or two or more distributors to divide up territories, products or customers. Competitive Information: Whie it is a common and permissibe practice to gather information about competitors, it is stricty prohibited under competition aws and genera business ega rues to procure competitive information through iega, or unfair channes (e.g. steaing information or requesting information from competitor s former empoyees currenty in biomérieux empoy). Further, no confidentia information beonging to a third party shoud be obtained or kept in the absence of such third party s express acceptance (e.g. a signed confidentiaity and nondiscosure agreement). Unfair advertising: It is iega to use comparison of biomérieux s products with simiar competitors goods in promotiona or advertisement campaigns, if such comparison is not based on actua objective studies or data. 14 OUR GLOBAL CODE OF CONDUCT - 3/ We trade in accordance with the rues OUR GLOBAL CODE OF CONDUCT - 3/ We trade in accordance with the rues 15

10 NO TOLERANCE FOR CORRUPTION Businesses ike ours have an integra roe in the goba effort to stamp out corruption. Corruption is the wiingness to act dishonesty or frauduenty, directy or indirecty, in return for persona gain. A person in a position of power who is iegay paid to make a decision that favors the payer has participated in corruption - and so has the payer. Corruption increases the cost of doing business, creates unfair competition, damages innovation, and undermines socia structures. In addition it deays, distorts and diverts economic growth and deepens poverty. biomérieux is committed to conducting its activities free from the unfair infuence of bribery and corruption. No bribe or other improper direct or indirect advantage must ever be given. We have zero toerance for corruption in the Organization. In addition, our business partners (such as distributors, contractors, or agents) shoud commit to the same ethica standards that we expect from our empoyees. Improper advantages can be anything of vaue, incuding bribes, kickbacks, iega rebates, under-the-tabe payments, gifts, entertainment, or trave expenses. Reevant poicies We have adopted a Corruption Prevention Program which incudes: A Corruption Prevention Manua; Principes of Business Conduct for Third Parties; A process for seection and working with intermediaries. A empoyees are expected to carefuy foow the Corruption Prevention Program for a business transactions. What about gifts, hospitaity, and trave? You may not provide any benefit (directy or indirecty), incuding gifts, hospitaity or trave to a customer (actua or potentia) or government officia that is intended to, or might be perceived to, unfairy infuence a business decision. In many countries, aws imit or ban the provision of meas, entertainment, or gifts to these individuas. The Corruption Prevention Manua provides you with detaied information on this topic and must be foowed. Keep in mind that perception matters. Something that you give coud ook ike an improper payment regardess of your intention. You must avoid even the appearance of bribery. Refuse to participate in or authorize corruption or bribery of any kind. Foow a appicabe aws and interna rues regarding interacting with the government and heathcare providers, as outined in the Corruption Prevention Manua. Ensure that our third parties are aware of and commit to our ethica standards with regards to corruption and bribery. Aert the Ethics & Compiance Department if there is a question or concern about potentiay corrupt activity. ENSURING FINANCIAL INTEGRITY/ANTI MONEY- LAUNDERING Many peope rey on biomérieux to maintain accurate and honest financia records, incuding our empoyees, our sharehoders, tax authorities, governments, and the pubic. We must ensure that our business operations are propery recorded in accordance with appicabe accounting standards. We have set up financia poicies and procedures to ensure that we compy with those standards, as we as with aws and reguations. 16 OUR GLOBAL CODE OF CONDUCT - 3/ We trade in accordance with the rues OUR GLOBAL CODE OF CONDUCT - 3/ We trade in accordance with the rues 17

11 biomérieux prohibits any participation in money aundering. Money aundering is the process of disguising the nature and source of money connected with crimina activities (such as corruption, terrorism, or drug trafficking) as egitimate commerce where the true source cannot be identified. Any irreguarity that is detected regarding the country of origin or the financia institution invoved in a particuar transaction shoud be investigated and reported to interna resources (such as Ethics & Compiance, Interna Audit, Export Contro). Foow interna financia poicies and procedures. Never make fase, miseading or deceptive entries. Provide fair estimates, anaysis, or information to appropriate representatives so that assets and iabiities can be propery vaued. Ensure that we are working with egitimate business partners who do not participate in crimina activities. Cooperate with our interna and externa auditors. To avoid externa fraud schemes, aways check that a request for sensitive information is vaid by confirming the source of the request. RECORDS MANAGEMENT Our commitment to integrity is bostered by the proper creation, maintenance, and disposa of accurate business records. These records are vauabe assets for biomérieux and shoud be carefuy managed and protected. Proper recordkeeping is an essentia part of compiance. Contracts and other ega agreements Vaid and enforceabe ega documentation strongy supports the Company in achieving its business objectives and protects it from serious business, ega, and ethica risks. Without ega documentation, it can be difficut to enforce a business arrangement if there is a dispute or itigation. It can aso be difficut or even impossibe to recognize revenue in accordance with accounting standards, or hod another party accountabe to our standards. We must be particuary carefu to document services provided to biomérieux by intermediaries such as consutants, advisors, agents, speciaists, or distributors. Payments to such parties shoud be carefuy set to correspond fairy to the services provided and must be propery entered in the Company s books. Compiance and ethica obigations must be documented to ensure that the intermediaries are fuy accountabe with our Company s standards. Ensure a commitments between biomérieux and third parties (individuas or companies) are documented in a written agreement, purchase order or other reevant appropriate ega document. Ensure the review, vaidation and fina approva and signature of ega documents conform to Company processes and procedures. Ensure compiance and ethica obigations of both the Company and the reevant third parties are ceary stated. Record retention and destruction We are required by the aws in the countries where we do business to maintain certain types of records for specified periods of time. Faiing to compy with goba and oca rues coud subject the Company to penaties, fines and other sanctions or put us at a serious disadvantage in any future ega proceedings (e.g. itigation, reguatory audits). In addition, we must remember that our records are our responsibiity - we must be abe to defend any documents that we create. Maintain and destroy documents according to the oca ega requirements and interna record retention poicy. Consider carefuy whether a record is necessary (such as an emai) before writing. Remember that we must take responsibiity for any documents that we create. Record information that is factua and objective, not miseading or exaggerated. Think about the audience who may read a record, both intended and unintended (such as the media, the government, or sharehoders). 18 OUR GLOBAL CODE OF CONDUCT - 3/ We trade in accordance with the rues OUR GLOBAL CODE OF CONDUCT - 3/ We trade in accordance with the rues 19

12 "Persona data" means any information reating to an identified or identifiabe natura person; an identifiabe person is one who can be identified, directy or indirecty in particuar by reference to an identification number or to one or more factors specific to his physica, physioogica, menta, economic, cutura or socia identity. 4/ WE ENSURE THAT WE PROCESS DATA WITH ETHICS Data must be: Processed awfuy, fairy and in a transparent manner in reation to the data subject (individua). Coected for specified, expicit and egitimate purposes and not further processed in a manner that is incompatibe with those purposes. Adequate, reevant and imited to what is necessary in reation to the purposes for which they are processed (`Data minimization ). Accurate and, where necessary, kept up to date. Kept in a form which permits identification of data subjects for no onger than is necessary for the purposes for which the persona data are processed. Processed in a manner that ensures appropriate security of the persona data. Transfer RESPECT FOR PRIVACY AND PERSONAL DATA PROTECTION Privacy is a fundamenta right under Artice 12 of the Universa Decaration of Human Rights of 1948 and biomérieux is committed to maintaining the confidentiaity of persona data. Many countries have stringent reguations that restrict the use of persona information. Such aws require that companies take adequate measures to ensure the confidentiaity, integrity, and avaiabiity of persona information. Any empoyee with access to persona information must agree to adhere to the persona data protection rues and coect, use and discose persona information ony in accordance with the interna biomérieux rues and the oca aws. 20 OUR GLOBAL CODE OF CONDUCT - 4/ We ensure that we process data with ethics persona data from one country to another ony after seeking ega or compiance advice. When required, data subjects must: Be informed of the existence and the purpose of any processing invoving their persona data. Have the right to access, rectify, and object to his/her data. Prompty report to Goba Data Privacy Officer any potentia misuse or oss of persona data. OUR GLOBAL CODE OF CONDUCT- 4/ We ensure that we process data with ethics 21

13 BIOETHICS AND RESEARCH COMPLIANCE Bioethics is the study of ethica issues raised by advances in bioogy and medicine. It provides pathways for resoving ethica questions that arise in a types of cinica situations. biomérieux is committed to protecting the heath of individuas and the pubic by activey considering bioethica impications whenever engaging in biomedica research. DANIELLE VITEK reagent manufacturing St Louis, Missouri PATIENT DATA PROTECTION As a heathcare company, biomérieux has access to persona data in a heathcare context, known as patient data which is very sensitive information. biomérieux is committed to the protection of patient heath information and compiance with appicabe reguations concerning their use and discosure. Patient identifiers, incuding but not imited to, name, socia security number, teephone number, posta code or medica record number are considered Protected Heath Information (PHI). PHI cannot be processed for purposes other than patient treatment, payment or heathcare operations. Discosures of PHI must be imited to the minimum necessary to achieve the permitted purpose. Authorized empoyees must commit to maintain the privacy and the confidentiaity of any patient data/phi. Ensure adherence to internationa bioethics standards. Provide accurate information to patients and vounteers regarding the use of their sampes and data for research purposes. Maintain confidentiaity regarding patients and vounteers. As an exampe, we must not use the names of individuas who take part in our research (notaby via their sampes or their data) as identification. Communicate resuts of research in accordance with internationa standards. Ensure our partners in research, such as bioogists, physicians, and sampe providers, share our vaues. 5/ WE CARE FOR THE WELL-BEING OF OUR STAFF COMMITMENT TO EMPLOYEES Rooted in a forward-thinking, humanist tradition, biomérieux seeks to attract and deveop taent that is innovative and rich in professiona and cutura diversity. We are committed to fostering an incusive, safe work environment where empoyees can reach their fu potentia. biomérieux has made a commitment to the aws and severa internationa conventions, incuding the Universa Decaration of Human Rights of 1948 and the United Nations Guiding Principes on Business and Human Rights of Since 2003, biomérieux has been a member of the UN Goba Compact, an internationa initiative under the auspices of the United Nations that aims to address the probems generated by gobaization. We aso respect the Fundamenta Conventions of the Internationa Labor Organization (prohibition of chid abor and forced abor, respect of the freedom of association), promotion of diversity, women s rights, respect for the rights of peope to use their natura resources and the right to heath. 22 OUR GLOBAL CODE OF CONDUCT - 4/ We ensure that we process data with ethics OUR GLOBAL CODE OF CONDUCT- 5/ We care for the we-being of our staff 23

14 Maintaining a heathy and safe work environment We a have a right to a heathy and safe working environment. Every empoyee has a responsibiity to take reasonabe precautions to prevent harm to peope by maintaining a secure work environment, incuding being compiant with heath, safety, and environmenta requirements. Substance use and abuse biomérieux is committed to maintaining a heathy and drug free work environment. Possession or use of a substance (other than prescribed medication) that coud create a hazardous condition is stricty prohibited in the workpace. Impairment from drugs or acoho wi not be toerated. An empoyee who is taking a prescription drug that may interfere with their workpace responsibiities shoud consut its oca Human Resources contact for guidance. Any empoyee who handes substances that have a potentia for abuse or misuse, must compy with biomérieux s poices and oca reguations regarding the proper handing and storage of these substances to prevent diversion for iicit use. Prohibition on workpace vioence The safety of empoyees is a cear priority. biomérieux stricty prohibits empoyees from making threats or engaging in vioent acts against feow empoyees or any individua conducting business with the Company. Any act or threat of vioence in the workpace by or against an empoyee is forbidden. Empoyees must not bring a weapon or any other potentiay harmfu item or substance into the workpace or onto the premises. Conduct our work in a safe manner. Consider our actions carefuy, so that we are not putting ourseves or others at risk. Know and compy with the aw and reated company poicies in areas that are subject to safety and environmenta reguations. Strive to continuay improve occupationa heath, safety and environmenta performance. Ensure that any substances that can be abused or misused are propery handed. Report dangerous conditions, and other heath, safety or environmenta conditions immediatey. RESPECTING HUMAN RIGHTS Diversity, non-discrimination and harassment biomérieux is committed to an environment of equa empoyment and advancement opportunity for a quaified individuas. The diversity of our empoyees is a strength that is promoted and supported throughout the Company. Our commitment to diversity incudes making reasonabe accommodations to assist those with disabiities and socia needs. biomérieux prohibits behavior that singes out an empoyee or group of empoyees in a negative way because of their gender, age, race, ethnicity, nationa origin, reigion, marita status, sexua orientation or identification, disabiity, iness, genetic information or any other characteristics protected under appicabe aws. A aspects of the empoyment reationship, such as hiring, assignments, promotion, compensation, discipine and termination must be made without regard to these characteristics. biomérieux supports and promotes a work environment that is free of harassment in any form. biomérieux wi not toerate offensive or abusive behavior in the workpace that creates an intimidating or hostie environment. The Company wi not toerate harassment of an individua for any reason. In particuar, biomérieux prohibits sexua harassment, incuding unwecome sexua advances, requests for sexua favors, and other verba or physica conduct that is sexuay discriminatory. Human rights As a Goba Compact member, biomérieux promotes and uphods internationa aw on Human rights. biomérieux condemns the use of forced abor and expoitative chid abor. We compy with a aws regarding savery and human trafficking. Support and promote biomérieux s commitment to incusivity and diversity. Never discriminate against or harass anyone because of any characteristics protected under appicabe aws. Never engage in any act or threat of vioence against another empoyee. Ensure fundamenta human rights and compiance with abor aws. 24 OUR GLOBAL CODE OF CONDUCT - 5/ We care for the we-being of our staff OUR GLOBAL CODE OF CONDUCT- 5/ We care for the we-being of our staff 25

15 AVOIDING CONFLICTS OF INTEREST Doing what s right is very important at biomérieux. We must a work together to ensure that we buid a company that makes decisions based on the merits, not persona interest. Any reationship or persona interest that coud keep an empoyee from making a fair, impartia business decision is a confict of interest and must be avoided. Empoyees must not use their position to gain any direct or indirect profits for themseves or for friends or reatives. This incudes taking advantage of any opportunity offered to biomérieux for the empoyee s own persona benefit. Receiving gifts, gratuities, fees, commissions or payments of more than a nomina vaue presents a confict of interest for biomérieux empoyees. If you are offered anything from a suppier, customer or any other business partner that coud keep you from making a fair, impartia business decision, you shoud not accept it. Empoyees shoud not accept or remain in any situation in which a reationship with friends or reatives coud impact his or her abiity to make objective judgments. The use of biomérieux s property and services shoud be ony for biomérieux s egitimate business purposes, not for an empoyee s persona benefit and never for any iega or unethica purposes. The persona use of Enterprise Information Technoogy resources (emai, internet, phone, etc.) shoud not interfere with work productivity and not exceed a nomina cost to the Company. These toos are the property of biomérieux. Use of these, for purposes that are not job reated, other than infrequent incidenta persona use or for purposes that woud vioate any of biomérieux s poicies, incuding the poicy against harassment, is stricty prohibited. Outside empoyment that coud potentiay affect the performance of an empoyee s work at biomérieux shoud be avoided. An empoyee must not serve any organization which might suppy goods or services to biomérieux, buy goods or services from biomérieux or compete with biomérieux without prior approva from the Compiance Officer. 26 Understand and foow biomérieux s Conficts of Interest Poicy. Avoid situation where our persona interests confict with those of biomérieux. Discose any potentia confict of interest to your Manager and Ethics & Compiance Department. OUR GLOBAL CODE OF CONDUCT - 5/ We care for the we-being of our staff Grenobe, France 6/ WE INTERACT THOUGHTFULLY WITH OUR COMMUNITY PROTECTING THE ENVIRONMENT biomérieux s dedication to sustainabe deveopment reinforces our socia commitment. In addition to foowing environmenta aws and reguations, we impement programs and initiatives to minimize our environmenta impact. Compy with a environmenta aws and reguations, incuding proper permitting and registrations. Strive to continuay deveop and improve our environmenta management system to minimize our environmenta impact. Identify, abe and manage chemicas and hazardous materias that present a danger to the environment to ensure their safe handing, movement, storage, recycing or reuse and disposa. Estabish interna systems for the eary detection and assessment of potentia environmenta risks and take measures to mitigate or eiminate such risks whenever possibe. OUR GLOBAL CODE OF CONDUCT- 6/ We interact thoughtfuy with our community 27

16 SUPPORTING PHILANTHROPY AND CORPORATE SOCIAL RESPONSIBILITY IN LINE WITH OUR VALUES As a pubic heath eader with a goba presence, we pace patients and, more broady, peope, at the heart of our activities. We uphod our corporate socia responsibiity through support of a variety of initiatives. As part of the Institut Mérieux Group, biomérieux is strongy committed to pubic heath. In the particuar phianthropy activity, we dedicate most of our charitabe giving to support the actions of the Fondation Mérieux and the Fondation Christophe et Rodophe Mérieux. biomérieux aso supports initiatives in the countries where we have sites and subsidiaries. We typicay seect projects reated to: Our Company s business or fieds of expertise: in vitro diagnostics, the fight against infectious diseases, antimicrobia resistance, cancers and cardiovascuar diseases; Our Company s mission, improving pubic heath and contributing to access to heathcare, especiay in emerging countries. We give priority to projects that enabe biomérieux to be a corporate citizen in the communities where its sites and subsidiaries are ocated and to requests from organizations with recognized pubic interest status. These donations are given vountariy, as refections of our vaues, without any expectation of favorabe treatment by the recipient in return. biomérieux never makes a contribution in exchange for a business favor or business advantage. Aways foow the guidance found in the Corruption Prevention Manua when determining if a charitabe contribution is permitted. 28 Compy with the Code when representing biomérieux in any outside activities. Never donate or promise to donate to a cause, either personay or on biomérieux s behaf, with the intention of gaining a business advantage for biomérieux. Remember that donations made at the request of heathcare providers or government officias are subject to specia scrutiny. Never obigate any empoyee or business partner to support a particuar phianthropic initiative. OUR GLOBAL CODE OF CONDUCT - 6/ We interact thoughtfuy with our community Grenobe, France 7/ WE COMMUNICATE CAREFULLY HANDLING CONFIDENTIAL INFORMATION Empoyees must aways strive to protect and preserve the assets of the Company against theft, oss, damage, careessness, waste and misuse. This incudes our confidentia information, whether in ora, paper, or eectronic form. Confidentia information can incude, among other things: A information reated to the invention, patent appication, deveopment or manufacture of any product, incuding drawings, performance statistics, manufacturing processes and data, test data or specifications; A information about empoyees, incuding compensation or benefits, personne fie (empoyee records); Company poicies, procedures, work instructions and standards; Schedues of product reeases; Information about the market for our products, customers, prices, contract terms and saes or marketing strategies and tactics, as we as information concerning our suppiers and competitive activities; Non-pubic financia information about the Company; Non-pubic information about Company transactions, incuding transactions with customers, financia providers and vendors, or mergers & acquisitions and divestitures. OUR GLOBAL CODE OF CONDUCT - 7/ We communicate carefuy 29

17 If it is necessary to discose confidentia information to outside parties, the appropriate parties must sign a Confidentia Discosure Agreement (CDA) before sharing any information. CDAs do not reieve empoyees of the responsibiity to use care in deciding what information to discose. When a CDA is in pace, we must respect the provisions as the Company may ose protection of its information or be exposed to damage caims if exchanges of information are not documented or other apses occur. Share confidentia information ony with interna empoyees who have a egitimate "need to know". Avoid discussing or dispaying confidentia information in areas where it may be obtained by individuas without a "need to know". Compy with a interna and externa rues for security regarding information technoogy and site access. Propery hande such information and prevent any misuse or destruction of it. Ensure that CDAs are in pace and foowed if we need to discuss information with third parties. Be aware that the data we create on the Company systems remains the property of biomérieux except information protected by oca privacy reguations. Immediatey report any incident that may compromise the confidentiaity of sensitive information. ENSURING APPROPRIATE USE OF THE INFORMATION SYSTEM The biomérieux Information System is part of biomérieux s assets. Its growing importance makes it essentia to support our daiy activities and its protection is a key objective for everyone. Each user of the information system must be aware of the expected practices, mosty based on common sense, in order to be an active contributor to the security of the information system. Secure our Information Systems access codes, incuding passwords, cards, and tokens by never sharing them. Connect ony biomérieux information technoogy hardware to the biomérieux corporate network, uness we have Information System authorization or are using preauthorized remote connections. Avoid the introduction of maicious, pirated or non-approved software into the biomérieux Group Information Systems. Never participate in security breaches or disruptions of Information Systems components. Ony send or store confidentia information outside of the biomérieux Group network if it compies with confidentiaity rues. Never use biomérieux Group information systems to activey engage in procuring or transmitting information or materia that is in vioation of countries oca reguations and aws. Never oan your aptop to anybody without physica presence and contro. 30 OUR GLOBAL CODE OF CONDUCT- 7/ We communicate carefuy OUR GLOBAL CODE OF CONDUCT - 7/ We communicate carefuy 31

18 RESPECTING INTELLECTUAL PROPERTY RIGHTS To remain a eader in in vitro diagnostics, biomérieux dedicates significant human and financia resources to create innovative products, processes or ideas in the technica, scientific, financia or business fieds. Such information represents vauabe assets for biomérieux that must be protected with utmost care, physicay and egay. Physica protection incudes such measures as password protection and encryption for eectronic data or ocked storage for paper documentation, care of eectronic or paper mai, refraining from discussing confidentia information in pubic paces. Empoyees must maintain the confidentiaity of biomérieux trade secrets and confidentia information. Trade secrets may incude information regarding the deveopment of systems, processes, products, know-how and technoogy. A biomérieux empoyees are stricty prohibited from appropriating any information earned from a third party whie in the conduct of their professiona activities when it can reasonaby be considered as confidentia, pagiarized, or as an infringement of any inteectua property rights (incuding patents, copyrights, trademarks, domain names or trade secrets) of a third party. Protect biomérieux s inteectua property rights. Respect the confidentiaity and rights of third parties. INSIDER INFORMATION AND TRADING Insider trading reates to using non-pubic information as a factor in making an investment decision. Because the information is not avaiabe to other investors, a person using such information may gain an unfair advantage over the rest of the market. Empoyees are not restricted from making persona investments, incuding purchases of Company stock, which do not vioate Company poicies incuding our Code for Market Traiding. However, we must a be aware that using price-sensitive, non-pubic information as a part of an investment decision is prohibited by securities and stock market aws and reguations. Inside information is any information directy or indirecty concerning biomérieux, that has not yet been made pubic by biomérieux in an officia press reease, and that if it were made pubic, woud be ikey to have an infuence on the price of the biomérieux share or on the price of financia instruments associated with it. To compy with securities aws, we must not: Buy or se shares based on any information that becomes known to us through our professiona activities with biomérieux and is not avaiabe to the pubic. Share such inside information with any person. 32 OUR GLOBAL CODE OF CONDUCT- 7/ We communicate carefuy OUR GLOBAL CODE OF CONDUCT - 7/ We communicate carefuy 33

19 10-16 / GB A / This document and / or pictures are not egay binding; modifications can be made by biomérieux without prior notice / BIOMERIEUX, the bue ogo, are used, pending and/or registered trademarks beonging to biomérieux S.A., to one of its subsidiaries or companies / Any other name or trademark mentioned in this document is the property of its respective owner / Photos: N. Bouchut, C. Ganet, Getty Images, GraphicObsession, JP. Mesguen, N. Robin / biomérieux S.A RCS Lyon / théra RCS Lyon B PIONEERING DIAGNOSTICS A word eader in the fied of in vitro diagnostics for more than 50 years, biomérieux is present in more than 150 countries through 42 subsidiaries and a arge network of distributors. In 2015, revenues reached 1,965 miion with 90% of internationa saes. biomérieux provides diagnostic soutions (reagents, instruments, software) which determine the source of disease and contamination to improve patient heath and ensure consumer safety. Its products are mainy used for diagnosing infectious diseases. They are aso used for detecting microorganisms in agrifood, pharmaceutica and cosmetic products. Photos 9, 12 & 23 taken in biomérieux s bio-industria sites and research & deveopment centers. We thank the biomérieux coeagues who took part in this photo project from Jean-Phiippe Mesguen. biomérieux S.A Marcy Étoie France Te.: +33 (0) Fax: +33 (0) V 02.A