Boehringer Ingelheim Compliance and Ethics

Dear colleagues and business partners,

The term "compliance" means to act in full conformity with and to observe all applicable laws and regulations. Therefore, our approach to Compliance and Ethics at BI focuses on recognising and avoiding legal risk of and effectively handling any violation.

In our Boehringer Ingelheim Code of Conduct we emphasise our objective and commitment that "we act with integrity, are trustworthy and set a good example". This is based on our longstanding tradition that integrity is an important value per se, especially so for a company which works directly for the wellbeing of people.

The long-term success of our company may only be sustained if we are and remain an honest organisation which is highly esteemed by our business partners, patients, health care providers and the authorities likewise. Therefore it is our ambition and commitment to act in line with applicable laws and not to violate any of them. This especially applies to Anticorruption laws, Antitrust laws and Antidiscrimination laws, be they civil or criminal, and in particular those that expose our company to financial risks and personal penalties.

Ensuring compliance in all what we do is the personal responsibility and duty of each employee at Boehringer Ingelheim.

Boehringer Ingelheim Code of Conduct

We...

• Act with integrity, are trustworthy and set a good example
• Ensure our conduct "complies" with Boehringer Ingelheim policies and regulations
• Use company resources in the company's best interest and do not misuse these resources
• Distinguish between company and private interests and avoid possible conflicts of interest; do not accept gifts, invitations and similar favours which could interfere with this principle
• Support and respect human rights and are against any form of discrimination
• Treat everybody in the corporation with honesty, openness, fairness and dignity based on the leadership principles
• Communicate wrongdoing, doubtful practices, risks, and deviation from policies, procedures, and planned time schedules.

So question...

• Is it legal?
• Does it comply with the values and goals of our Corporation?
• Is it fair?
• Does it feel right?
• How will other people in the company react?
• What would happen if everybody did this?
• Is this what we want?
• Can I discuss this freely with my supervisor?
• How would it look if it was made public?

We specifically invite you to refer to the Boehringer Ingelheim Anticorruption Policy.

Please help us maintain these legal standards so that our success of today will be our taintless success of tomorrow.

Thank you very much!