Code of conduct

Code of Conduct for Moberg Pharma AB (publ), 556697-7426

Adopted by the Board of Directors of Moberg Pharma AB (publ) on May 17, 2021

Background
Moberg Pharma’s Code of Conduct has been prepared on assignment of the company’s
Board of Directors and is a document governing the ethical standards and the principles that
everyone in the company, both employees and Board members, is expected comply with.

Purpose
The purpose of the Code of Conduct is to ensure that Moberg Pharma is a company that
takes its social responsibility seriously, whereby considerable focus is placed on people,
relations and the environment. Moberg Pharma is also to be a company that represents
integrity and reliability.

Guidelines
Everyone in the company has a responsibility to comply with laws, regulations and internal
policies. If anything in this policy should contravene legislation, it is the prevailing law in the
particular country of operation that applies ahead of the principles stipulated in Moberg
Pharma’s Code of Conduct.

Core values and guiding principles
Management and employees at Moberg Pharma have agreed on the following core values to
guide behavior and company culture:

Core Values

• Fairness, honesty, integrity
• Individual commitment and commitment to individuals

Guiding principles

• Strategy driven
• Customer’s come first
• Make things happen - with quality
• Cost/value conscious
• Learning and adapting
• Straightforward communication
• Having fun!

Internal relations
Everyone at Moberg Pharma is expected to conduct themselves in a correct manner towards
colleagues and contribute to a positive and team-oriented working environment.

Moberg Pharma encourages diversity at all levels of the Group. The company believes firmly
that diversity is something positive and that it has the potential to improve performance. Noone
is to be discriminated against due to gender, age, nationality, religion, social or ethnic
origin, functional impediment, sexual orientation, political opinion or trade union affiliation.
This principle applies both to how we treat our employees and to the practices included in the
employment process.

Moberg Pharma views every employee as an important contributor to its operations and sets
high priority to retain its human capital. The company strives to raise the level of competency
within the company and to realize the full potential of the individual. Accordingly, Moberg
Pharma promotes the individual’s personal development by offering opportunities for
continuing professional education and opportunities to develop within the company.

Moberg Pharma takes care of the employees health by providing a safe and healthy work
environment. The work situation is to be adapted to the individual and facilitate a good
balance between work and leisure.

External relations
Everyone at Moberg Pharma is expected to conduct themselves in a correct manner in
contacts with our business partners. Accordingly, neither bribery nor corruption is accepted
by the company. Moberg Pharma’s employees and Board members are not permitted to
accept gifts, payment or other benefits that could influence business decisions, violate laws
or contravene acceptable business practices.

Similarly, no-one at Moberg Pharma is permitted to act in such a manner that is described in
the paragraph above in relation to customers, potential customers, governments or
representatives of such entities that would in turn risk influencing them in their decisions.

The company endeavors to have satisfied customers. One way of achieving this is to satisfy
customer needs. This is achieved by means of good communication and by each individual
accepting responsibility for being accessible and accommodating in relation to customers
and for correctly managing customer-related matters. Remember that you are the company’s
face to the public and that your behavior reflects the company.

Moberg Pharma has a social responsibility and takes care of both its customers and the
public by utilizing and providing safe manufacturing processes and products.

Data Protection and Privacy
Moberg Pharma and all of its employees shall be committed to complying with applicable
privacy and information security laws and regulations, including but not limited to the General
Data Protection Regulation (GDPR), when personal data is collected, stored, processed,
transmitted, and shared, including with regard to the personal data of suppliers, customers,
consumers and employees with whom Moberg Pharma conducts business.

Whistleblowing
Whistleblowing entails that an employee who has identified irregularities or potential
irregularities reports this to a unit that can act to put a stop to the irregularities in question.
Examples of irregularities are breaches of laws and internal regulations and guidelines.
Whistleblowing is positive for the individual employee, the Group and society since it
provides an opportunity to resolve the irregularities in question. There are many reasons why
it is positive to speak out: it would be ethically correct, it would be necessary on the basis of
law and regulations and saying nothing could jeopardize the company’s image. Accordingly,
people who show civil courage and are prepared to speak out about irregularities are an
important resource for Moberg Pharma.

All employees are entitled to report irregularities. In the first instance, the employees can
always make a report in writing or orally to the immediate superior or to the CEO. All
employees can also choose to contact Konrad Ziobro, who is the contact person for
whistleblowing.

Konrad Ziobro
Hansen Advokatbyrå KB
Hovslagargatan 5B
111 48 Stockholm
Mobile: +46 733 88 77 35
Email: konrad@hansenlaw.se

Although it is possible to speak out completely anonymously, openness is normally a better
way of dealing with such matters and also leads to a better result for all parties.

Responsibility
While it is the responsibility of Moberg Pharma’s managers to ensure that all employees
within the company are familiar with the company’s Code of Conduct, it is the individual’s
responsibility to comply with it. Breaches of Moberg Pharma’s Code of Conduct could lead to
disciplinary sanctions.