Code of Business Conduct and Ethics www.alnylam.com CHALLENGE ACCEPTED TABLE OF CONTENTS Leadership Message Message from Alnylam’s CEO ________________________________________________________________3 Integrity – It’s in our RNA What’s in a Name?, Our Vision, Our Mission _____________________________________________________4 Accepting the Challenge to Conduct Business with Integrity ________________________________________5 Living Our Values Patients Putting Patients at the Center _______________________________________________________6 Protecting Patient Privacy __________________________________________________________6 Conducting Ethical Research ________________________________________________________7 Supporting Patient Organizations ____________________________________________________7 Ensuring Product Quality and Patient Safety ____________________________________________8 Healthcare Professionals Interactions with Healthcare Professionals ______________________________________________9 Engaging in Scientific Exchange _____________________________________________________10 Communicating Product Information _________________________________________________10 Managing Gifts and Hospitality Appropriately __________________________________________11 Employees Building Teams and Respecting One Another ___________________________________________12 Providing Equal and Fair Opportunities _______________________________________________13 Presenting Ideas with Confidence ___________________________________________________13 Maintaining a Safe and Secure Workplace _____________________________________________13 Avoiding Conflicts of Interest ____________________________________________________14-15 Participating in the Political Process _________________________________________________15 Community We Care _______________________________________________________________________16 Being Responsible to our Communities _______________________________________________16 Providing Full and Fair Information about our Investigational Products ______________________16 Company Protecting the Integrity of Company Technology ________________________________________17 Safeguarding Intellectual Property __________________________________________________17 Protecting Confidential Company Information __________________________________________18 Avoiding Insider Trading ___________________________________________________________19 Keeping Accurate Books and Records ________________________________________________19 Marketplace Doing Business Free from Corrupt Activities ____________________________________________20 Gifts and Gratuities _______________________________________________________________21 Responding to Investor and Media Inquiries ___________________________________________21 Treating Suppliers Fairly __________________________________________________________22 Protecting Fair Competition _______________________________________________________22 Gathering Business Intelligence Honestly _____________________________________________23 Abiding by Trade Control Regulations ________________________________________________23 Cooperating with Investigations ____________________________________________________23 Making Ethical Decisions No Code of Conduct Can Anticipate Every Situation _____________________________________________24-25 The Compliance Helpline _________________________________________________________________25 How do I Contact the Helpline? ____________________________________________________________25 2 Return to TOC Questions – Contact our Helpline at 844-543-8355 or alnylam.ethicspoint.com LEADERSHIP MESSAGE Message from Alnylam’s CEO Since our founding in 2002, Alnylam has had a strong scientific heritage driven by curiosity, innovation and an unwavering focus on developing products to help patients. As an employee of Alnylam, you have chosen to be part of a company with a mission to improve lives. With that privilege comes the responsibility to meet the highest level of ethical and legal standards. Our patients and others expect and deserve no less. While our commitment to the highest standards is clear, doing things the right way in today’s complex regulatory and global environment can be a challenge. Every day we must collaborate and work together to help one another meet this challenge, make good decisions, and protect our reputation. Our Code of Business Conduct and Ethics is intended to do just that. Our reputation and the trust that others put in us are the most valuable assets we have. They must be earned anew each day and protected with the utmost care. Our science is all about RNA. Integrity must also be part of our RNA. The quality of our people and our commitment to ethics and compliance will not only enable us to succeed today but will help us to thrive and excel and most importantly continue to deliver transformative medicines to patients. John Maraganore, PhD Chief Executive Officer Alnylam Pharmaceuticals 3 Return to TOC Questions – Contact our Helpline at 844-543-8355 or alnylam.ethicspoint.com INTEGRITY – IT’S IN OUR RNA Innovation & Discovery We are all product champions who aspire to drive new discoveries from concept to cure. We strive for an environment that crackles with creativity and collaboration, extending beyond the laboratory into everything we do. We accept the challenges inherent in creating and delivering a new class of medicines.” What’s in a Name? Alnylam is derived from “Alnilam,” the center star in Orion’s belt, which shines the brightest of them all. It is also the Arabic word for “string of pearls.” Click on the “From Possibility to Patients: What’s in a Name?” video below to learn more. Our name may not be the easiest to pronounce – but once you learn it, you never forget it. Our Vision Harnessing a Revolution in Biology for Human Health Our Mission Build a top-tier, independent biopharmaceutical company founded on RNAi 4 Return to TOC Questions – Contact our Helpline at 844-543-8355 or alnylam.ethicspoint.com INTEGRITY – IT’S IN OUR RNA Open Innovation Culture & Discovery Commitment Alnylam’s to People Passion for Core Values Excellence Sense of Urgency Accepting the Challenge to Conduct Business with Integrity This Code is intended to promote the conduct of Company business globally with the highest standards of integrity, consistent with our Core Values and in compliance with all applicable laws and regulations in every country in which we operate. This Code applies to everyone in the Company, no matter where you work. While laws may differ across the world, this Code sets forth the common vision of integrity for all Alnylam employees, officers and directors. The principles in this Code are general in nature, and the Code does not cover every situation that may arise. Use common sense and good judgment in applying this Code. This Code is not your only source of guidance and information. You should also consult applicable policies and procedures in specific areas as they apply. If you have any questions about applying the Code or any Alnylam policy, don’t hesitate to seek guidance from the many resources available to you, including your manager, any member of management, Human Resources, Compliance, Legal or the Alnylam Helpline. 5 Return to TOC Questions – Contact our Helpline at 844-543-8355 or alnylam.ethicspoint.com LIVING OUR VALUES PATIENTS Sense of Urgency “Our purpose is to discover and deliver transformative new treatments for patients with a sense of urgency.” Putting Patients at the Center We put patients at the center of everything we do. We strive, with humility, to understand patients’ journeys, experiences, and unique needs and to continue to advance the development of potential therapies to treat rare and serious diseases. To honor our patients, we do not compromise in our research, our products or our capabilities. We are transparent and honest in our communications. We believe that our therapies must get to those who will benefit from them so we will work hard for patient access. We are committed to growth through continuous innovation. Serving patients requires their trust. We should never compromise that trust. Protecting Patient Privacy Information about a patient’s health, medical records, and genetic status, among other things, is considered highly sensitive and is protected by many laws and regulations all over the world. In carrying out our activities, including conducting clinical research and providing services to patients, we may obtain private or confidential information about the patient or their family members. Keeping patient information secure and using it appropriately is a top priority for Alnylam. This means that we will: • Make sure that we always obtain patient information in the right way, with the appropriate consent • Safeguard any personal information of our patients when collecting, processing, storing, and transferring that information • Ensure that patient information is used only for the reasons for which the information was gathered, is shared appropriately and only with those Alnylam employees that need such information, and is kept only as long as Q&A we need to and in accordance with applicable laws Q: What if I have to share a patient’s personal information with a third party for business purposes? Not disclose any information about • A: It may be necessary, in order to conduct our business, to work a patient without approval unless with third parties and share confidential patient information legally required to do so (for example,