This Code of Ethics and Conduct establishes the standards, principles and values ​​to guide decisions and professional behavior to be adopted in the activities carried out by employees, partners and all those involved in ZEMIR PHARMA CONSULTING, LDA (hereinafter referred to as ZEMIR PHARMA).

ZEMIR PHARMA is committed to acting with integrity, transparency and responsibility.

1. General principles and duties

It is the responsibility of ZEMIR PHARMA and those who act on its behalf to maintain a culture of integrity and respect for:

• Employees,
• National and European legislation and that of the countries with which they work,
• Suppliers, customers and partners,
• The environment.

The values that are an integral part of ZEMIR PHARMA's primary values and which it undertakes to comply are Honor, Professional ethics, Honesty, Courage,  Integrity and  Loyalty.

All employees and partners of ZEMIR PHARMA are aware of the Code of Ethics and Conduct and undertake to comply with it in the performance of their duties.

Any violation of this Code may result in disciplinary sanctions, including termination of employment contracts or cessation of business relations.

ZEMIR PHARMA shares this code with all parties involved, in order to ensure that they are aware of, understand and correctly apply the principles and policies described herein.

2. Business Integrity and Transparency

ZEMIR PHARMA acts with honesty, integrity, transparency and respect, establishing business relations based on mutual trust. All people are treated with dignity and respect, and there is no discrimination regarding age, sex, race, beliefs, political views or sexual orientation.

Accordingly, bribes, gifts or any other form of undue advantage are not accepted or offered in exchange for business or decisions related to our products.

At ZEMIR PHARMA we are committed to communicating, in a clear and precise manner, all information regarding our products, including their characteristics, benefits and risks.

ZEMIR PHARMA's integrity and transparency stance aims not only to comply with legislation, but also to build business relationships based on trust, respect and social responsibility.

3. Discrimination, violence and harassment

ZEMIR PHARMA promotes an inclusive, respectful and safe work environment for all employees, regardless of their ethnicity, gender, sexual orientation, religion, age or disability. Discrimination, violence and harassment, in any form or circumstance, are unacceptable and will be dealt with with appropriate sanctions, which may include severe disciplinary measures.

Any situation of discrimination, violence or harassment must be reported immediately. Complaints will be investigated, treated confidentially and disciplinary measures will be taken impartially and fairly.

4. Criminal Prevention

ZEMIR PHARMA has zero tolerance for the practice of any illicit conduct, both in internal operations and in commercial relations with external parties.

ZEMIR PHARMA employees and partners are responsible for ensuring that the company does not engage in any type of crime or criminal offence during its operations. It is also the duty of all those involved to act in a manner that prevents and detects potential risks of offences.

ZEMIR PHARMA does not permit any form of illicit activity and immediate and rigorous action will be taken in the event of an offence.

5. Anti-corruption

ZEMIR PHARMA has a zero tolerance policy towards corruption. As such, there is a commitment to ensure that the activity is carried out in an honest and transparent manner, promoting business practices in accordance with ethics and legislation. Bribes, extortion, or any other type of undue payment or benefit to influence a business decision are not tolerated, whether by employees, suppliers, customers or any other party involved.

Corruption, in any form, is a crime that undermines trust, fairness and equality, compromising the integrity of business relationships. ZEMIR PHARMA is committed to preventing and combating corruption, regardless of its origin or those involved.

In order to ensure compliance, all employees, suppliers, partners and third parties acting on behalf of ZEMIR PHARMA are required to refuse offers, request or accept any type of bribe, payment, gift, favor or any other advantage that could be interpreted as an attempt to influence decisions. This principle applies not only to commercial transactions, but also to any type of benefit or service that may be offered in exchange for favors or favorable decisions.

In addition, all our employees must be able to identify situations that may be considered as suspicious of corruption and report them immediately.

Violation of this policy will be treated with the utmost seriousness and may result in severe disciplinary measures, including termination of employment, termination of business relations and cooperation with the competent authorities for the investigation thereof. ZEMIR PHARMA assumes the responsibility of creating an impartial and transparent business environment, in which all involved act with trust and integrity.

6. Prevention of Money Laundering and Terrorist Financing

ZEMIR PHARMA is committed to complying with the requirements relating to the prevention of money laundering and terrorist financing, and it is essential to adopt measures to ensure that the operation is not used for illegal purposes, namely the concealment of funds obtained illegally or the financing of terrorist activities.

ZEMIR PHARMA has implemented a set of measures and procedures to prevent and detect any activity related to money laundering or terrorist financing, namely:

• All customers, suppliers and partners are identified and the legitimacy of their activity is validated. ZEMIR PHARMA may reject business relationships with entities whose background or behavior is considered suspicious.
• All financial transactions are monitored in order to identify any suspicious activity. Any transaction involving large amounts, transfer of funds between high-risk countries, or other suspicious activity will be duly investigated.
• Internal communication channels are provided so that anyone can report suspicious activity or any concerns.

Violation of this policy will be treated with the utmost seriousness, and any involvement or attempted involvement in money laundering or terrorist financing practices will result in strict disciplinary measures, including termination of employment or cessation of business relations, as well as collaboration with the responsible authorities for investigation and possible criminal prosecution.

7. Prevention of Conflicts of Interest

ZEMIR PHARMA values ​​transparency, impartiality and objectivity in business decisions. A conflict of interest is considered when any person involved in ZEMIR PHARMA's activity has personal, family or financial interests that may influence, or appear to influence, their impartiality in the performance of their work.

Therefore, we aim to identify, prevent and effectively manage conflicts of interest, ensuring that all decisions are made taking into account the best benefit for the company. All those involved must act in a way that avoids situations in which their personal or external interests may conflict with professional responsibilities or the interests of the company.

Therefore, all employees, partners and suppliers are obliged to inform the company of any situation of possible conflict of interest. ZEMIR PHARMA proceeds with the analysis of the situation in order to assess whether it is necessary to implement corrective actions or other measures to mitigate the risk. These actions may include refusal to perform the activity, adjustment of responsibilities or carrying out an independent review.

At ZEMIR PHARMA, any behavior involving undisclosed or hidden conflicts of interest is prohibited, as this behavior compromises the integrity of the company's operations and the trust of its stakeholders.

Any violation of the provisions on conflicts of interest will be treated with due seriousness and may result in disciplinary measures, including termination of the employment contract or cessation of business relations.

8. Due Diligence towards Suppliers and Subcontractors

ZEMIR PHARMA recognizes the importance of maintaining business relationships with suppliers and subcontractors who share the same ethical values ​​and commitment to good business practices. To ensure this practice, specific procedures are adopted for the selection and monitoring of suppliers and subcontractors.

The process of selecting a supplier involves an analysis of the supplier to ensure that it complies with the necessary regulatory and ethical obligations, and also validates whether the supplier complies with internal quality and safety standards. No supplier or subcontractor will be selected based solely on the financial component. After selection, ZEMIR PHARMA begins a continuous monitoring process to ensure that the agreed conditions are met.

If a supplier or subcontractor violates the established policies or commitments, or fails to meet the required ethical and compliance standards, ZEMIR PHARMA may terminate the contract immediately, without prejudice to any legal liabilities.

ZEMIR PHARMA is committed to working only with suppliers and subcontractors who are in line with its values ​​of excellence, integrity and social responsibility. In this way, we ensure that our business partnerships are safe, transparent and sustainable in the long term, contributing to the company's reputation and success.

9. Environmental and Social Responsibility

ZEMIR PHARMA promotes sustainable practices and is committed to preserving the environment, recognizing social and environmental responsibility as an integral part of its activity, since our activity must respect the balance between economic development, environmental protection and well-being.

ZEMIR PHARMA implements actions to minimize environmental impact, namely by encouraging conscious consumption practices, reducing waste and recycling. The activity is developed in order to promote the protection of natural resources and contribute to sustainability.

In terms of social responsibility, there is a commitment to having a positive impact on society, promoting equality, inclusion and respect for human rights.

 

Last update May 2025.