Code of Ethics
Code of Ethics SIFI SpA

S.I.F.I. - SocietÓ Industria Farmaceutica Italiana S.p.A. (Italian Pharmaceutical Industry Company) (Hereinafter also referred to as SIFI or the Company) has adopted ethical and behavioural principles that are consistent with the guidelines established by the category association, Farmindustria. These principles form the basis of the relationships governing companies in the health sector, and in particular pharmaceutical industries and companies operating in the biomedical field, as well as between the latter and the healthcare and life sciences industries.
The following are the recipients of this Code of Ethics (hereinafter referred to as the “Recipients”), and are committed to respect the content of the same:
 the members of the governing bodies, the administrators, administrative directors and the technicians of the Company (the so-called “Senior Subjects”);
 the sales staff, employees and free-lancers, pharmaceutical representative as well as the other employees, administrative and technical staff of the Company (the so-called “Internal Subjects under someone’s management”);
By virtue of specific acceptance or by virtue of the appropriate contractual clauses, the following subjects who are external to the Company are also Recipients:
 consultants and in general those subjects who carry out freelance work for the Company;
 suppliers and partners (also as a temporary association as well as a joint venture);
 any counter-party with whom the Company accepts contractually regulated forms of collaboration.
It should be noted that Senior Subjects and Internal Subjects under someone's management are understood exclusively as Recipients in relation to the Organisational, Management and Control Model adopted by the Company pursuant to Legislative Decree 231/2001, and the obligation to report to the Supervisory Body.
The adoption of ethical standards of conduct set out in the Code of Ethics is a duty for the Recipients, in order to reach the company objectives in full compliance with national and international law. In particular, the same Recipients are required to:
 behave in line with what is stated in the Code of Ethics;
 immediately inform the Supervisory Body of any violations of the Code as soon as they become aware of them;
 request, if required, interpretations or explanations on the behavioural principles that are defined below.
This Code of Ethics consists of two chapters, described below:
 General ethical principles;
 Behavioural rules.

General ethical principles
The Company has adopted the following general ethical principles identifying the reference values:
The Company’s vital principle is compliance with laws, regulations and, in general, regulations in force in Italy and in all the countries in which it operates, as well as the democratic order established in these places.
In carrying out their professional activities, SIFI employees and in general the Recipients are obliged to comply with the law, current regulations, the Code of Ethics and internal regulations. In no case could the fulfilment of SIFI’s interest justify conduct that is not in line with the principle now stated.
The Company renounces any principle of discrimination based on sex, ethnic origin, nationality, religion, personal opinions and political opinions, age, health and economic conditions of its partners, including its suppliers.
Recipients must be aware of the ethical meaning of their own actions and must not pursue personal or corporate gain in breach of the laws and standards of this Code. While formulating the contractual agreements with the clients, the suppliers, the partners and in general the sale counterparts we must ensure that the clauses are stated in a clear and comprehensible manner, thus ensuring that the condition of equality among the parties is maintained. Furthermore, Recipients, should guide their conduct, within the limits of their respective powers and responsibilities, towards the achievement of the corporate mission. SIFI undertakes not to exploit for its own benefit any conditions of ignorance or inability of its partners, and commits to ensure that contracts and work assignments are carried out in accordance with what was established knowingly and freely by the parties.
Employees represent the fundamental and irreplaceable asset for the business growth of SIFI which, therefore, protects and promotes the value of its human resources in order to increase the wealth of skills possessed, in compliance with the legislation in force concerning the rights of the individual and the legislation in force concerning illegal immigration and public order. SIFI gives great importance to the physical and moral integrity of its employees, to working conditions that respect the dignity of the individual, and to a safe and healthy working environment ; in particular, it does not approve nor justify any act of violence or threat aimed at obtaining behaviour that is contrary to current legislation, including legislation on ethics, and/or the Code of Ethics.
The Company also recognises the need to protect individual freedom in all its forms and renounces any manifestation of violence, especially if aimed at limiting personal freedom, as well as any case of prostitution and/or child pornography. The Company is committed to promote, within the framework of its activities and among the Recipients, shared acceptance of the same principles.

Special attention should be given, always and in any case, in order to avoid situations in which the subjects involved in the transactions seek to achieve a different interest from the corporate mission and the equitable distribution of the stakeholders’ interests, to gain “personal” advantage from the Company’s business opportunities, and when the representatives of clients , suppliers or public institutions operate in contrast with the fiduciary duties associated with their position.
The principle of transparency is based on the truthfulness, accuracy and completeness of information both inside and outside the Company. In observance of the principle of transparency, each operation and transaction must be properly registered, authorised, and be verifiable, legitimate, consistent and fair.
For each operation, there must be adequate documentary support in order to be able to proceed, at all times, to carry out inspections verifying the characteristics and motivations of the operation, and identifying those who authorised, carried out, recorded and verified the operation itself.
The Company employs objective and transparent criteria for its choice of suppliers. This choice, in keeping with current regulations and internal procedures, must be based on objective evaluations relating to the competitiveness, quality and economic conditions practiced.
In every work activity, the affordability of the management and use of company resources must be pursued, in compliance with the most advanced quality standards.
SIFI ensures the confidentiality of the information that it possesses, and shall refrain from processing confidential data, with the exception of the case of explicit and conscious authorisation and compliance with legal regulations in force.
In addition to this, its collaborators are required not to use confidential information for purposes that are not related to practicing their profession.
SIFI’s goal is to understand, in the light of scientific knowledge, the patients’ needs, and develop innovative solutions in relation to the most serious diseases, diseases that cannot yet be treated satisfactorily, and those whose therapy can be significantly improved.


The primary purpose of SIFI’s activity is the maximum satisfaction possible, and the protection of its clients, also by paying attention to requests that can encourage an improvement in the quality of products and services.
To this end, research, development, production and marketing activities are based on a standard of quality of absolute excellence.
The Company recognises the value of competition when it is inspired by the principles of fairness, fair competition and transparency in dealings with the players in the market.
The principle of fairness implies respect for the rights of all the parties involved in the activities of the Company.
A correct and transparent relationship with customers and suppliers is a crucial aspect of the Company’s success, which must be pursued by offering high quality products and services, at competitive conditions on the market, and in compliance with the rules of fair competition.
It is forbidden to use corrupt practices, unfairly preferential treatment, direct or indirect solicitations, and rewards of any value aimed at influencing the judgment of third parties, of subjects related to him/her or of the Company in favour of the performer of the forbidden practice.
The economic resources cannot absolutely be used to establish or maintain a commercial agreement, to obtain more favourable conditions in damage of the counterpart, to influence the choices of the competitors, to solve with a direct gain controversies of any kind or to other aims that are contrasting with the values stated in the present Code.
The Company pursues the goal of the highest degree of integrity and honesty in our relations, including contractual ones, with public institutions and, in general, with the Public Administration, including in relation any request for and/or management of public funds, in order to guarantee the maximum clarity in institutional relations, in compliance with the need for organisational and management autonomy that is characteristic of all businesses.
Relations with institutional partners are maintained exclusively through specifically appointed subjects.
In its relations with the Public Administration, the Company, if necessary, must be represented by a consultant or a “third” party, if there are conflicts of interest, even potential ones.

The shareholder requires all available information in order to make investment decisions and issue company resolutions; SIFI strives to create, and maintain over time, those conditions required for the widespread and aware shareholder participation in decision-making.
The Company is pursuing the aim of ensuring health and safety in the workplace with the maximum commitment. In this regard, the Company adopts the most appropriate measures to avoid the risks associated with the running of its business and, in instances where this is not possible, for an adequate evaluation of the existing risks, with the aim of countering them directly at their roots, and ensuring their elimination or, where this is not possible, their management.
The Company complies with the rules on protection of trademarks, patents and other distinctive signs and in the area of copyright.
The environment is a primary asset that must be safeguarded; in keeping with this assumption, SIFI plans its activities by seeking the best possible balance between economic initiatives and environmental requirements, taking into account the rights of present and future generations. Consequently, the Company is committed to safeguarding the environment and contributing to the sustainable development of the area, also by using the best available technologies and the constant monitoring of business processes, as well as through the identification of industrial solutions of lesser impact on the environment. SIFI is aware of the influence that its activities have on the economic and social development and the welfare of the community in the ophthalmic sector. For this reason, the Company intends to carry out its investments in a way that is compatible with respect for the environment and the needs of local and national communities, while also supporting initiatives of scientific, cultural and social importance, in order to obtain a constant improvement of its reputation and social acceptance.
SIFI also operates in a way as to ensure that its economic/financial performances are such as to increase the Company's value, by properly rewarding the risk taken by its shareholders through investment of their capital.

Behavioural rules
The Recipients, in the awareness of their own responsibility, as well as in compliance with the law, the legislation and the statutes in force, must comply with the provision of the Model and the Code of Ethics, which forms a part of it. With reference to the Model, the following general behaviours should be adopted:
 avoiding to commence, cause or collaborate in the implementation of behaviours that may integrate any of the offenses mentioned in the Decree;
 collaborating with the Supervisory Body during verification and supervision activities carried out by the latter, and providing information, data and news requested by it;
 carrying out for the Supervisory Body the communications set forth by the Model;
 reporting to the Supervisory Body any malfunctions or violations of the Model and/or the Code of Ethics.
In case of communications with external parties, the Company must comply with the following principles in each form of communication on its part, ensuring that:
 it is based on the observance of the laws, rules and practices of good conduct;
 it is professional;
 it is made in a clear, thorough and transparent manner;
 it safeguards, among other things, industrial secrets;
 it guarantees the transparency of the source;
 it declares any sponsorship relations
“Vision is the art of seeing what is invisible to others.”
Jonathan Swift

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