Ethics and Integrity

At Roche Canada, we believe that our success is owed to the integrity of our employees. Given the complexities of the global environment within which we operate, governance and compliance are critical competencies for our organization. We know that by doing the right thing, as well as being honest and transparent, we will continue to be a successful organization making an impact on the lives of the patients who depend on our diagnostics and medicines.

Theoutlines our expectations of employees and sets the standards for business behaviour that apply throughout the Roche Group. All employees must comply with this Code of Conduct, regardless of their location and the nature of their work.

The Roche Group Code of Conduct is built on our corporate principles andIt contains guidance in the areas of products and services, personal integrity, corporate integrity, employment, company assets, responsible business and comprehensive compliance management. It also provides questions and answers, examples and information on where to find more detailed guidance on various topics of importance to our company.

In addition to our company Code of Conduct, Roche — as a global organization — is also a corporate member of numerous pharma and diagnostics/medical device associations, further adhering to their self regulating codes of conduct. In Canada, we are a member ofthe industry association representing Canadian innovative pharmaceutical companies, and we comply with itsWe are also a member of Medtech Canada, Canada's innovative medical technology industry association, and we comply with their Code of Conduct as well.

Our focus on ethics and integrity is critical when operating in local communities. This includes how we work with and engage with our vendors. Our suppliers (i.e., suppliers of materials, service providers and contract manufacturers) play an important role as enablers of our sustainable growth and overall success. As such, we have also established thethat governs how we work with external suppliers.

As a partner within the Canadian healthcare system, we believe that enhancing transparency will help us build trust within the communities in which we live and operate.

We believe that engaging with health system stakeholders is essential to our understanding of their expectations, needs and concerns, as well as to identifying and filling gaps in the healthcare system. By embedding their feedback and needs into our strategy, as well as our daily business, we are able to collectively address common issues and develop long-term solutions that prioritize patient outcomes. These solutions may include novel medicines, diagnostics, as well as support programs and/or initiatives that drive education and access to care to help improve the overall health of Canadians.

Our interaction with stakeholders is governed not only by our own internal guidelines that outline a systematic process by which to engage stakeholders at a local and global level, but is also regulated by self-regulating ethical guidance from our industry associations includingand MEDEC’s Code of Conduct.

As a global organization, we have taken numerous steps towards becoming more transparent about our interactions with stakeholders and making this information accessible, as we fundamentally believe that collaboration is the key to improving healthcare across the globe. Collaboration between companies such as ours and healthcare providers, government, payers, patient organizations, as well as hospital institutions drives scientific advancements, enhances medical education, promotes health literacy and improves access to care across societies.

In support of our global commitment to transparency, in Canada we are voluntarily publishing aggregated sums of payments made to Canadian healthcare providers (HCPs) and healthcare organizations (HCOs) in 2023 in the chart below. This data will be updated on an annual basis and is being reported in accordance with the Voluntary Disclosure Framework that has been developed in partnership with and endorsed by Innovative Medicines Canada.

In addition to the above, we also invest significantly into medical research that is conducted in Canada. In 2020 alone, Roche invested more than $66 million CAD in clinical research in Canada through 188 Roche-sponsored clinical trials, providing Canadians with the opportunity to access novel medicines for many debilitating and/or life threatening diseases.

The Voluntary Disclosure Framework currently does not account for these investments or funding that is provided to patient organizations, which are reported separately:

Additional information about our activities and how we work with healthcare providers, government, payers, regulatory bodies, patient organizations, hospital institutions and other stakeholders is