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ESGBERT 26

We implement our EHS Policy through our global EHS management system that guides our actions and tracks key performance indicators to manage our risks and drive continuous improvement.

Site leaders, in collaboration with global and local EHS teams, are responsible for routinely identifying and having access to applicable health and safety legal requirements and implementing compliance systems consistent with applicable legal requirements and the standards outlined in our EHS policy.

Each Alexion site implements an EHS Incident Management Procedure that complies with our EHS Policy and local regulatory requirements.

A key component of our EHS management approach is employee involvement.

to employee health and safety, in concert with our speak-up culture.

Each challenge was modeled after one of the three core elements of a successful health and safety program: Management Leadership, Worker Participation and Finding/Fixing Hazards.

Finding and fixing hazards in the workplace is an ongoing process that helps better identify and control sources of potential injuries or illnesses.

Our emphasis on teamwork and solid governance is fundamental to our CSR approach.

in the development and recommendation of policies and management systems for environmental, health, safety and social responsibility matters to the Board.

the complement system is dysregulated, it can lead to disease.

In addition to our internal research programs and direct collaborations, we support clinically and scientifically sound independent research to generate evidence and ultimately contribute to advancing patient care.

ensuring compliance with all applicable laws, guidelines and standards.

to create brighter futures for all of our stakeholders, is an unwavering commitment to ethics and compliance.

Alexion’s Ethics and Compliance program is led by our Chief Compliance Off icer, Compliance Committee and Compliance team.

In principles applicable to all employees in a new structure and digital format.

The Code is in addition to more detailed company policies and procedures, as well as the geographyspecific policies and procedures.

It is the responsibility of every employee to read, understand and follow this Code, as well as all other company policies.

This Code is the foundation of Alexion’s overall program to ensure that all Alexion employees worldwide follow the appropriate standards and comply with all legal requirements in each country where we do business.

Alexion educates and trains employees on the Code through live training sessions, web-facilitated trainings and via online resources and training programs.

At Alexion, integrity is clearly defined as working first and foremost in the best interest of our patients.

In integrity underscores everything we do and how we embrace its foundational role in our daily work.

metrics (see table on Page is to be a key influencer of compliance standards across the industry through ongoing, proactive thought leadership.

based compliance program into a robust, control-based program at the Society of Corporate Compliance & Ethics (SCCE) Compliance & Ethics Institute.

The SCCE is a member-based association for compliance and ethics professionals worldwide.

ANTI-CORRUPTION POLICY Alexion has a zero-tolerance policy toward bribery and corruption.

The Alexion International Compliance team led throughout 2018 and 2019, reaching more than 2,200 employees in all of our markets globally.

serve as an extension of our global International Compliance team.

The program has an established governance structure to share insights, learnings and best practices.

The Nominating and Corporate Governance Committee also has oversight of political activity and spending.

We publish a description of Board and management oversight of political spending on our website.

In adopted its Policy on Political Contributions and Lobbying Activity, which outlines our commitment to disclose semi-annually, among others: (i) corporate contributions to candidates in state and local elections as well as corporate contributions to other political committees, PACs and political party committees; (ii) contributions made by the Alexion Pharmaceuticals Inc. PAC; and (iii) the nondeductible portion of annual payments to trade associations receiving $25,000 or more in dues or payments in the year and corporate payments to other tax-exempt groups that may be used for election related purposes.

OUR VENDOR CODE OF CONDUCT In suppliers in 2020.

All suppliers are required to read and acknowledge the Vendor Code of Conduct, which aims to ensure our suppliers share our commitment of high ethical standards and compliance with all applicable laws, regulations and other legal requirements in every country in which they operate.

Topics include anti-bribery/anti-corruption, privacy, animal welfare, fair labor and hiring practices, and environmental, health and safety.

Nominating and Corporate Governance Committee Charter governance body The Board receives education on a variety of topics, including CSR and governance.

Alexion also funds Board members’ attendance at relevant educational seminars, and Board members belong to the National Association of Corporate Directors (NACD).

sustainability reporting The Nominating and Governance Committee of the Board has oversight of Alexion’s CSR program and reviews Alexion’s CSR Report.

102-49 Changes in reporting N/A - This is Alexion’s first CSR Report 102-50 Reporting period Calendar year 2019, which also serves as Alexion’s fiscal year.

102-52 Reporting cycle Alexion reports on an annual basis.

regarding the report [email protected] 102-54 Claims of reporting in accordance with the GRI Standards This report references disclosures from the GRI Standards 2018 and the SASB Biotechnology & Pharmaceuticals Industry, as detailed in this index.

However, we practice design for the environment and aim for lean, efficient and sustainable operations in all new capital projects and operations.

MARKET PRESENCE Ratios of standard entry level wage by gender compared to local minimum wage Alexion operates in multiple locales and jurisdictions that have varying minimum-wage requirements, but employees’ starting salaries are typically well above applicable minimumwage requirements.

ANTI-COMPETITIVE BEHAVIOR Legal actions for anti-competitive behavior, anti-trust, and monopoly practices During the reporting period, Alexion was not identified as a participant in any legal actions alleging anti-competitive behavior or violations of anti-trust and monopoly legislation that rose to the level of materiality that would have required disclosure in our periodic reports filed with the SEC.

ENVIRONMENTAL COMPLIANCE laws and regulations During the reporting period, Alexion identified no noncompliance with environmental laws and/or regulations that rose to the level of materiality that would have required disclosure in our periodic reports filed with the SEC.

In Ireland, for example, we regularly engage with the Industrial Development Authority of Ireland; peer companies in the Dublin and as part of the Jobcare D15 Jobnet program; the Irish National Transport Authority on a Smarter Travel Program; the Institute of Technology Blanchardstown to sponsor technical students; and the Irish Business Employers Confederation to participate in several working groups for biopharma, pharma and chemical industries.

Incidents of noncompliance concerning the health and safety impacts of products and services During the reporting period, Alexion identified no new incidents of noncompliance with regulations concerning the health and safety impacts of Alexion products and services that rose to the level of materiality that would have required disclosure in our periodic reports filed with the SEC.