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Code of Conduct & Ethics Code of Conduct & Ethics Going to incredible lengths to impact incredible lives. Over 500 employees and their friends and families participated in the virtual “Walk to Cure Arthritis” in May 2020. Health Care Letter From Ethical Decision Patients and Professionals & Employees Communities Speak Up Our CEO Making Caregivers Organizations Contents Letter from our CEO .............................................................................................. 3 Communities ......................................................................... 27 Ethical Decision-making ....................................................................................... 4 Safeguarding our Environment .......................................................................... 28 Patients/Caregivers ................................................................ 5 Participating in Community Engagements ....................................................... 29 Interactions with Patients and Patient Organizations ....................................... 6 General Information ............................................................. 32 Product Safety .................................................................................................... 10 Speak Up ................................................................................ 33 Research and Development ............................................................................... 11 Health Care Professionals & Organizations ..................... 13 At Horizon, Ethics is everyone’s responsibility, and we all must remain committed to maintaining the highest standards of business conduct and ethics. Our Code Interactions with Health Care Professionals and Organizations ..................... 14 of Conduct and Ethics is a principles-based guide and is not intended to lay out Off-label requests from HCPs and HCOs ........................................................... 15 rules for every business action. Instead, each of us must follow applicable laws, regulations and Horizon policies and exercise good judgment, common sense and Anti-Bribery and Anti-Corruption ...................................................................... 16 honest and ethical conduct and decision-making when making business decisions Transfer of Value to HCPs and HCOs ................................................................. 17 and representing Horizon. Employees ............................................................................ 20 Interactions with Employees ............................................................................. 21 HOW TO USE THIS PDF Protecting our Company .................................................................................... 23 Roll-over and click the buttons in the navigation below to jump to different Maintaining our Integrity ................................................................................... 25 sections of this document. General navigation is located to the left side: Contents Start Over Previous Next Health Care Letter From Ethical Decision Patients and Professionals & Employees Communities Speak Up Our CEO Making Caregivers Organizations Hello Team, When we started Horizon in 2008, we had one goal: bring breakthrough solutions – and hope – to people living with challenging diseases. Over a decade later, we continue to deliver on that promise. And, while our path to success has been filled with change at every turn, one thing has remained the same – and that’s our guiding principle: Do the right thing. Doing the right thing is infused in every facet of our work – how we advocate for patients, how we work with healthcare providers, how we treat each other, how we make decisions and how we operate with integrity. Above all, doing the right thing is our north star and at the very core of who we are. Inside, you’ll find our Code of Conduct, which provides an instructive set of principles and guidelines to operate our business in an ethical and compliant way. I encourage you to read it and use it as a tool to guide each part of your day. While our Code of Conduct lays out a clear model for how to serve patients and our communities, it is you, as a valued member of our Horizon family, who bring it to life. So, hold yourself and others accountable. Pay attention, ask questions and speak up when something doesn’t look or feel right. And, as always, do the right thing for those who depend on us. Tim Walbert Chairman, President and Chief Executive Officer Health Care Speak Up Patients and Communities Letter From Ethical Decision Professionals & Employees Caregivers Our CEO Making Organizations Decision-Making Framework Navigating decisions can be challenging. Whenever you are making a decision or using the Code of Conduct & Ethics, remember the acronym “WHY?” and utilize this framework to help you make a sound ethical choice. W H Y Well-Advised: Horizon: You: Is the decision well-advised? What does the decision How do you feel about mean for Horizon? the decision? Is it consistent with the law and Horizon’s values, key principles Would I be comfortable if it was Would I be comfortable if friends and policies? in the news? and family knew I was responsible At Horizon, we are committed to our values for this decision? of transparency, accountability and growth. If you answered, “NO” to any of these questions or if you are unclear about Horizon’s values, our key principles, any of our policies or applicable law, please consult with your manager or Ethics & Compliance. Health Care Letter From Ethical Decision Patients and Professionals & Employees Communities Speak Up Our CEO Making Caregivers Organizations Patients and Caregivers KEY PRINCIPLE Horizon is focused on researching, developing and commercializing medicines that address critical needs for people impacted by rare and rheumatic diseases, while ensuring safety and protecting patient privacy. Horizon puts patients and caregivers first byinstilling trust through ensuring accountability to standards set forth by the Food and Drug Administration (“FDA”) and other regulatory agencies. Horizon listens and learns from patients, caregivers and health care professionals to cultivate innovation. Christina Caregiver, mom and chronic granulomatous disease carrier Liam Lives with chronic granulomatous disease Health Care Letter From Ethical Decision Patients and Professionals & Employees Communities Speak Up Our CEO Making Caregivers Organizations IN OUR INTERACTIONS, WE: Interactions with Patients and 1. Respect the boundaries of our role as a biotechnology company Patient Organizations 2. Maintain professional, appropriate and respectful behavior At Horizon, we put patients first. We provide access to our medicines and 3. Align with Horizon’s policies and approved messaging, elevate the patient’s voice and needs through the engagement and support as well as industry standards and regulations 4. Transparently disclose when Horizon sponsors of patients, caregivers and patient organizations. or supports patient-focused materials, activities or programs Engaging with stakeholders to understand how Evaluating and sponsoring advocacy initiatives to evolve our medicines and pipeline to meet from patient organizations that improve the lives unmet needs of patients and their caregivers WE DON’T: Providing patient and caregiver support Making non-conditional charitable contributions 1. Improperly influence the use our medicines or services programs, including patient access and to qualifying independent charitable foundations reimbursement support, mentoring and 2. Refer to or recommend health care professionals education, financial support, free medicine (“HCPs”) or health care organizations (“HCOs”), including sites of care and expanded access for qualifying patients Please see the Policy for Interactions with Patients 3. Provide medical advice or interfere with the Following the lead of patients and Patient Organizations for further guidance and HCP-patient relationship additional restrictions for Horizon sales. and their advocates 4. Interfere with the independence of Patient Organizations Health Care Letter From Ethical Decision Patients and Professionals & Employees Communities Speak Up Our CEO Making Caregivers Organizations WHAT FINANCIAL SUPPORT DOES HORIZON PROVIDE TO Supporting Patients and Patient ORGANIZATIONS SUPPORTING PATIENTS? Organizations Donations to Independent Sponsorships of Patient Organizations Charitable Foundation As part of our commitment to help patients live A patient organization is a tax-exempt An independent charitable foundation is a tax- organization with a primary purpose of creating healthier and more productive lives, we provide both exempt organization that improves access to awareness of a disease or educating patients patient support programs and financial support through care for underinsured patients with coverage and caregivers about a disease. We provide from government insurance. These patients financial sponsorships to these organizations as donations and sponsorships to patient organizations do not have applicable commercial insurance. a promotional activity. These organizations may and independent charitable foundations. While we make charitable donations to these support a therapeutic area that pertains to one organizations, we do not improperly influence, of our medicines. Horizon does not tie any financial support to the usage, support or interfere with the independence of EXAMPLE any independent charitable foundation. distribution, payment
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