Clinigen : Global Health & Safety Policy

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If this procedure is a printed copy it shall be considered an uncontrolled copy

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Clinigen seeks excellence in every aspect of its business and is committed to ensuring compliance with all applicable Health and Safety laws, regulations, and other requirements, to ensure the Health and Safety of our employees, visitors to our places of business, and others directly affected by the relevant activities under our control.

It is our policy and commitment to ensure that we do business according to the highest ethical standards and that our practices comply with all applicable laws in any country we operate in through directly related companies or third parties.

This Policy was established referring to the laws, regulations, and other policy mechanisms concerning Health and Safety.

2. Purpose

This Policy sets out Clinigen's Health and Safety principles and commitments. This Policy represents our overarching commitment to provide a safe working environment and informs of our specific policies and practices relating to Health and Safety operated locally across the company.

3. Scope

This policy applies to Clinigen Limited, its subsidiaries and affiliates ("Clinigen"). All Clinigen directors and employees worldwide are expected to comply with this Policy. This Policy also applies to any visitor, and/or sub-contractors working or in attendance at a Clinigen controlled site.

This Policy should be considered as complementary to local Health and Safety policies in place. All the subsidiaries and affiliates should comply with this Policy and local policy. In case of absence of such policy, this Policy will be applicable.

4. Our Health and Safety Principles

We believe in the following principles to guide our actions:

• All injuries and work-related illnesses can and should be prevented;
• Management is accountable for the Health and Safety performance;
• Communication, involvement, and training of all employees are essential in Health and Safety excellence;
• Everyone continuously has a role to play in preventing injuries and illnesses;
• Excellence in Health and Safety supports excellent business results; and,
• Health and Safety must be integrated into all business management processes.

5. Our Commitments

It is the aim of Clinigen so far as reasonably practicable to:

• Eliminate hazards and reduce any Health and Safety risks associated with our activities;
• Prevent accidents and work-related ill health, to our people and visitors; and
• Develop a Health and Safety culture.

To achieve these aims, we will:

• Establish effective safety management systems across the business;
• Identify, evaluate, and eliminate Health and Safety risks to ensure that hazards are managed;
• Establish effective processes for preventing all injuries and work-related illnesses;
• Build a supportive culture that requires visible Leadership with clear accountability;
• Provide Personal Protective Equipment ("PPE") where required;

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• Ensure the safe handling, transport, storage, use and disposal of substances;
• Provide and maintain safe plant and equipment;
• Provide everyone with effective training so that we are all able to work safely;
• Investigate all incidents in order to prevent a recurrence;
• Establish measurable objectives to monitor progress through regular audits and reporting;
• Comply fully with all legal and other applicable requirements and meet or exceed these expectations wherever we operate in the world; and
• Update and test emergency procedures.

6. Responsibility of Clinigen, its Employees and Management

7.1 Management

The Chief Operating Officer ("COO") is ultimately accountable and responsible for ensuring that this Policy is implemented. The COO is support by the Executive Management Team and Senior Leadership Team ("Management") to ensure Health and Safety risks are effectively managed and mitigated.

It is the responsibility of Management for our regional businesses, business units, and support functions to discharge the commitments stated within this Policy. Management is expected to:

• Promote a positive Health and Safety culture by providing visible and tangible leadership;
• Ensure a safety management system is maintained and implemented such that it meets or exceeds the requirements of this Policy, local laws and our "expectations for Health and Safety management", and adequately addresses local Health and Safety risks;
• Make Health and Safety integral to everything we do, by ensuring it is given equal importance to other operational items and periodically reviewed at leadership meetings;
• Set Health and Safety objectives annually, communicate these to all employees, and monitor and report progress to the Board of Directors ("Board") at least annually;
• Seek to continuously improve by encouraging the sharing of best practices and lessons learned across our global operations;
• Ensure that acquired businesses are integrated into our way of working;
• Ensure that all visitors and sub-contractors are aware of this Policy and that they have a duty to ensure their own safety and that of others;
• Ensure an appropriate level of resources and funding to support this, Policy;
• Communicate with employees on any Health and Safety matters which may affect them; and
• Provide feedback and recognition to employees who positively contribute to reducing Health and Safety risks.

7.2 Employees

The effective implementation of this Policy requires the involvement and the commitment of employees at all levels. Employees have a duty of care to themselves, and others potentially affected by our activities and are expected to be aware of, and encouraged to contribute to the delivery of this Policy, by:

• Knowing where they can access suitably qualified and experienced Health and Safety Advisors (or equivalent) for guidance and advice.
• Making Health and Safety personal by reporting any accidents, incidents, unsafe acts, near misses or observations where safety performance could be improved.
• Challenging the status quo, suggesting improvements, and proposing innovative ideas which can remove or reduce risk from our activities.
• Keeping Health and Safety a priority in our offices, on our sites and when working from home.

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7. Risks

Violations may trigger severe sanctions against Clinigen which includes, but are not limited to, the followings:

• Authorities may impose substantial fines on Clinigen;
• Criminal sanctions may lead to fines for individuals; and,
• Allegations of poor safety environments and bad labor conditions may lead to substantial reputational damage and may impact our business and value.

8. Consequences Of Violations

The consequences for violating this policy will depend upon the facts of each situation but may lead to disciplinary action which may include termination of employment.

9. Record-Keeping And Reporting

All accurate records shall be kept regarding Health and Safety matters in accordance with the related internal policies. All these records shall be clear and transparent.

All directors and employees are expected to report any violation of this Policy and other related requirements they become aware of. If you become aware of any actual or suspected breach, you must raise your concerns as soon as possible. This can be done by contacting the relevant local Health & Safety lead. Reporters can remain anonymous if they wish. How to report a concern anonymously is set out in the Global Freedom to Speak Up Policy.

It is the policy of Clinigen to report illegal acts to the appropriate authorities and to fully cooperate in any subsequent investigation.

10. Communication And Training

Communication and training are being implemented so that this policy is fully understood.

11. Monitoring And Review

The effectiveness of the implementation of this policy will be monitored and reviewed regularly considering its suitability, adequacy, and effectiveness.

12. Document History

If this procedure is a printed copy it shall be considered an uncontrolled copy

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