Modern Slavery Act 2015: Slavery and human traffic declaration

This statement is made by Eurocept Pharmaceuticals, including all its legal entities worldwide. As a part of the pharmaceutical industry, we acknowledge that we have a responsibility to take a robust approach against slavery and human trafficking (“Modern Slavery”). The statement is made in accordance with Section 54 of the Modern Slavery Act 2015. Eurocept Pharmaceuticals is committed to Improving our practices to combat Modern Slavery.

Introduction

Eurocept Pharmaceuticals is committed to uncompromising integrity and the highest standards of business conduct. Eurocept Pharmaceutical is the umbrella name for the Eurocept Pharmaceuticals Holding legal entities that are established located in Ankeveen and Hilversum, The Netherlands and present themselves related to pharmaceutical activities. Eurocept Pharmaceuticals is involved in developing and producing medical products, obtaining and maintaining marketing authorization, pharmacovigilance and supplies to(retail) pharmacies and wholesalers in predominantly European countries. Its portfolio includes but is not limited to antibiotics, pain treatment products, cytotoxic products and product for treatment of rare metabolic diseases. Eurocept International B.V. holds the marketing authorization of (part of) this portfolio. Next to this, Eurocept Pharmaceuticals is representative for foreign marketing authorization holders, with either distribution activities or promotion and sales and distribution activities.

Eurocept Pharmaceuticals is committed to the highest level of quality in all operations related to the production and distributions of its products. Eurocept Pharmaceuticals is committed to comply with relevant national and international legislation and regulations in its areas of countries of business.

When selecting suppliers and contractors, Eurocept Pharmaceuticals works hard to choose reputable business partners who adhere to ethical standards, values and demonstrate business practices compatible with those of Eurocept International.

Our Business

Eurocept Pharmaceuticals Holding is active in the development, production, registration, pharmacovigilance, marketing and selling of medicinal products. Eurocept Pharmaceuticals Holding has its own medicinal products which are sold in Europe and the rest of the world, as well as licensed medicinal products that are sold in the Benelux countries. Finally, Eurocept Pharmaceuticals provides services in the field of pharmacovigilance, distribution and hospital account management for other pharmaceutical companies. For these companies, Eurocept Pharmaceutical is a one-stop shop.

Headquarter of Eurocept International B.V. is based in Ankeveen, The Netherlands.

Our policy on slavery and human trafficking

We strive to act ethically and comply with all applicable laws in all our business relationships. Our suppliers and contractors are expected to support and respect human rights and avoid complicity in human rights violations, including human trafficking, slavery or sexual exploitation.

Due diligence processes for slavery and human trafficking

Regarding disclosures related to human trafficking and slavery, Eurocept Pharmaceuticals expects suppliers and contractors to meet the expectations described above. We select suppliers and contractors who support our values and commitment to the highest standards of integrity and ethical business conduct.

Our supply chains include suppliers of direct materials (active pharmaceutical ingredients, manufacturing and packaging) and suppliers of indirect services (professional services. facilities. sales and marketing agencies and clinical research organizations). All pharmaceutical products or components which are used in humans must comply with Good Manufacturing Practice (GMP)rules. To be GMP compliant, manufacturers must follow detailed rules and guidance regarding the quality of products they produce, their facilities and their staff. All manufacturing sites are subject to periodic inspections based on a risk assessment by applicable government regulators to check they are GMP compliant. It is standard practice that all potential new suppliers and manufacturers shall be subject to additional due diligence checks in the form of ethical/compliance audits conducted by or on our behalf. No contract will be awarded to a supplier who is unable to comply with the Modern Slavery Act 2015. When a member of our supply chain is found to be indulging in irresponsible, unfair and unethical business practices, their business role should be terminated and appropriate action shall be taken.

Our policies on slavery and human trafficking

As a business Eurocept Pharmaceutical recognize the responsibility to be aware of the risks of Modern Slavery within the organization. Our global Code of Conduct requires all Eurocept International B.V. companies and employees to act in a professional and ethical manner and to respect and preserve the human rights of others. The Code also acknowledges that our responsibility does not end at our premises. We cascade these responsible practices across our entire value chain.

In addition to the Code of Conduct, Eurocept Pharmaceuticals has a Whistleblowing policy encourages all employees to report concerns related to the direct activities, or the supply chains of the organization. This includes any circumstances that may give rise to an enhanced risk of Modern Slavery. The whistleblowing procedure is designed to be anonymous and easy to follow. Therefore, if there are any concerns relating to Modern Slavery these can be raised in confidence without fear of retaliation.

Further steps & training

We recognize the need to be vigilant and to Identify potential exposure to Modern Slavery. We will ensure that our partners share the same zero tolerance attitude toward Modern Slavery and we will review our existing supply chain for compliance with the Modern Slavery Act 2015. In addition we intend to take the following steps:

New Policy: introduction of a responsible procurement policy, which shall set out a number of key principles related to Modern Slavery.

Vendor Qualification Process: potential new suppliers and manufacturers shall be subject to due diligence checks.

Increasing Awareness: Within the Eurocept Pharmaceuticals, awareness of Modern Slavery is being raised through communications to ensure relevant staff understand the importance. The intention is that this will enable the staff to identify and flag concerns related to Modern Slavery and take action to mitigate such risks. Employees will be encouraged to report any concerns that they may have in line with our Whistleblowing policy.

Training: To ensure a high level of understanding of the risks of Modern Slavery in our supply chains and our business, we intend to develop training for our key employees, particularly those who are most likely to encounter such risks. The policy will be periodically reviewed and updated as required to ensure that we maintain appropriate safeguards against the risks of Modern Slavery.

This statement has been prepared in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes our statement on slavery and human trafficking for the financial year ending 31 December 2022

Eurocept Pharmaceuticals Holding

Date: 17 October 2022