Ethical business conduct

Commitment to compliance with the law and guidelines, as well as to acting with integrity, is a fundamental part of Galenica’s corporate culture and a constant focus of our corporate management. The obligation to comply with the law during day-to-day operations begins with every employee. This is how we contribute to a peaceful and inclusive society.

Our objectives

We pursue the clear objective of consistently preventing any form of breaches of the law, corruption and unethical behaviour. In order to live up to this requirement, we rely on a preventive and effective compliance system, which is geared in particular towards regular, target group-oriented training and awareness-raising measures for employees.

Our management approach

For Galenica, compliance forms the basis of trust, integrity and sustainable corporate success. We are committed to act with integrity and consistent compliance with all relevant laws, guidelines and standards – including internal and industry codes. These include, for example, legal requirements arising from therapeutic product, data protection, health insurance, labour, antitrust, tax and criminal law as well as international standards such as ISO 14001 or Good Distribution Practice. In addition, we uphold human rights in all our business activities. The Legal Department of the Galenica Group advises all companies and divisions on the correct interpretation and application of legal provisions. It also supports the implementation of new legal provisions within the company. In addition, Galenica Group employees increasingly have access to digital tools that help them to act in compliance with the law.

Corporate governance

The Galenica Group attaches great value to responsible and ethical corporate governance. Galenica Ltd., the ultimate parent company, has its registered office at Untermattweg 8, 3027 Bern, Switzerland. Galenica is listed on the SIX Swiss Exchange and has subsidiaries in Switzerland, Germany and Austria. Details of the Group structure can be found in the Corporate Governance Report. In order to uphold responsible corporate governance, the organisation of the Board of Directors as the supreme management body is clearly regulated. In addition, binding rules and processes ensure that no conflicts of interest arise. Further information can be found in the Corporate Governance Report. In addition, the remuneration policy and the procedures for determining remuneration are also transparent. The performance evaluation process and the remuneration systems for the Board of Directors and the Executive Committee are described in detail in the Remuneration Report.

Code of Conduct

The central instrument is the Code of Conduct of the Galenica Group, which, in addition to the relevant legal provisions, sets out the ethical rules and standards that all employees must uphold. It was approved by the Audit and Risk Committee of the Board of Directors and must be accepted by all employees as part of the employee handbook upon commencement of their employment. Among other things, the Code includes provisions on conflicts of interest, insider dealing or corruption, as well as on environmental protection. The Code also contains clear commitments to human rights, such as fair working conditions, the exclusion of child or forced labour, discrimination and the health and safety of employees. The Code of Conduct thus contributes to the removal of taboos from certain grey areas.

Managers are responsible for addressing and dealing with specific conflict situations in day-to-day business.

The Pharmacies division also has a specific code of conduct, which serves as a binding internal work instruction devised to ensure the pharmaceutical independence of pharmacists at all times and thus to always give priority to the health and wishes of patients.

Prevention of corruption and anti-competitive behaviour

As Switzerland’s largest healthcare network, combating corruption and preventing anti-competitive behaviour are key issues for Galenica. Both topics are governed by the Code of Conduct. In addition to the Group’s Code of Conduct and that for Suppliers, the Anti-Corruption Policy also sets out principles and guidelines for combating corruption and governs their implementation by employees and business partners of the Galenica Group. Any form of corrupt conduct towards or bribery of public officials and private individuals, whether directly or via third parties, is prohibited. Galenica has a zero-tolerance approach to corruption and bribery on the part of employees, partners, suppliers and representatives of third parties.

The Galenica Group is not aware of any cases of corruption in the reporting year. Furthermore, there were no new legal actions due to anti-competitive behaviour or violations  of anti-trust and anti-competitive law.

Training on compliance and ethical conduct

To ensure compliance and ethical conduct, we rely on a comprehensive approach in the areas of prevention, detection and response. Training and awareness-raising measures on laws, guidelines as well as internal and industry codes, and policies are a key tool for prevention. The aim is to train employees on the various topics several times a year in a way that is appropriate for the target group they represent.

In 2025, nine compliance awareness-raising measures and training sessions were carried out, thus achieving the target. In addition, these training sessions were supplemented by additional measures, including targeted internal communications, the development of legal maps, continuous improvement and the development of new processes and templates. In doing so, we raise awareness of compliance and promote principled conduct in our day-to-day work.

In 2025, all Galenica Group companies acted in compliance with the law. In the two competition-related proceedings already underway prior to the reporting year, the sanctions imposed were significantly lower than originally expected.

Whistleblower reporting office

The Whistleblower Reporting Office plays a decisive role in uncovering unethical behaviour and breaches of the law. Internal and external stakeholders may raise concerns about Galenica’s business activities through the external Whistleblower Reporting Office. This offers all employees and business partners the opportunity to anonymously report suspected breaches of the rules. All reports are investigated. Reports of corruption and bribery must also be reported to the committee appointed by the Board of Directors. As well as this, various channels and points of contact are available to employees through which they can report concerns or matters of key importance. These include the People & Culture department, staff committees, the employee survey and annual staff appraisals. The Executive Committee deals with key and critical points from the employee survey or the staff committee and introduces effective measures.

In 2025, an incident of discrimination was reported via the Whistleblower Reporting Office. The internal investigations had already been initiated, meaning the necessary steps for clarification and implementation could be taken promptly.