Ethics and Business Conduct

A Foundation Built on Ethical Business Practices

At Celgene, we assume the best in each other, and we treat each other with dignity and respect as we work together to advance our common mission. We value each individual for the integrity they bring to their work and their relationships.

Code of Business Conduct and Ethics

Celgene was founded, and continues to grow, based on the core principles of honesty, integrity and accountability. We hold one another to the highest standards in what we do and how we do it. These principles are the foundation for Celgene’s Values and form the basis of our Code of Business Conduct & Ethics. This code applies to all employees and anyone acting on Celgene’s behalf.

Celgene’s Board of Directors has oversight responsibility for our Global Compliance Program, and the Chief Compliance Officer provides the Board with regular compliance updates.

Corporate Compliance and Ethics Hotline

The Celgene Compliance and Ethics Hotline is available to report any conduct or action which is or may appear inconsistent with applicable law, Celgene policies, the Code of Business Conduct & Ethics or Celgene’s Values.

The Hotline provides a means of filing a report anonymously (where permitted by applicable law) 24-hours a day, seven days a week, to a third-party service provider that will ensure a caller’s confidentiality. Celgene will not retaliate against any employee who reports a complaint or concern in good faith.

In the U.S., dial the Hotline directly at 1–866-480‐6139. Click here for Hotline numbers outside the U.S.

Employee Ethics Training

All Celgene employees receive training on the Code of Business Conduct & Ethics when they join Celgene. We expect our employees to read, understand and abide by the requirements in the code to ensure ethical business practices and compliance throughout our organization.

Celgene has a robust program of compliance training on a wide variety of topics. All employees receive training on anti-bribery and anti-corruption, conflicts of interest, anti-harassment, data protection and privacy, and other policies and procedures that outline how they are expected to conduct their day-to-day responsibilities. Employees involved in sales and marketing receive regular compliance training on the laws, regulations and codes that govern interactions with physicians and other customers, and the promotion of our products.

Global Compliance Program

Celgene’s Global Compliance Program supports legal and ethical conduct throughout the company. Employees have an obligation to report any conduct that they in good faith believe violates laws, corporate policies and/or the Code of Business Conduct and Ethics. There are various avenues available both to seek advice on ethical behavior and to report concerns related to violations of such behavior.

Discrimination and Harassment

It is the policy of Celgene Corporation to provide equal employment opportunities in all terms and conditions of employment. Our Equal Opportunity Policy, which applies to all employees in the U.S., provides that we will not discriminate against any qualified employee or job applicant with respect to any terms, privileges or conditions of employment regardless of race, color, religion, sex (including gender identity), sexual orientation, marital status, pregnancy, national origin, ancestry, citizenship, age, veteran status, physical or mental disability, or medical condition (including cancer or genetic information), or other legally protected classifications.

Anti-Bribery and Anti-Corruption

At Celgene, bribery is never permitted. This principle does not change based on local culture or if we are working with a government official, healthcare professional or commercial customer. All employees must follow all applicable anti-corruption laws and regulations, including the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act and similar laws wherever we do business.

Celgene’s Anti-Bribery and Anti-Corruption Policy and the Code of Business Conduct & Ethics provide standards of conduct and practices for all employees of Celgene, its affiliates and subsidiaries, to ensure compliance with applicable laws. Training on this policy is required by all employees worldwide on an annual basis, and target groups receive enhanced in-person training led by Legal and Compliance personnel. The policy identifies potential actions and areas of bribery and corruption that could generate risk for Celgene operations.

Conflicts of Interest

It is Celgene policy that employees and others acting on behalf of the company must be free from conflicts of interest that could adversely influence their judgment, objectivity or loyalty to the company in conducting Celgene business activities and assignments.

Employees, officers and directors are required to disclose any activity or personal interest that could potentially present a conflict of interest as described in the Conflicts of Interest Policy. This policy outlines procedures that identify and manage conflicts of interest that may exist for employees and proper avenues of internal disclosure and management.

Anti-Counterfeiting Activities

Counterfeiting medicines is a serious criminal offense and a growing public health risk. Counterfeit medicines may be too strong or too weak, miss key ingredients, or even be made with dangerous contaminants that can lead to serious health issues. When patients consume fake medicine, trust in the quality of medicines in general is destroyed and hope for successful treatment of their disease is undermined. Celgene believes there is no higher priority than ensuring that patients receive genuine, safe and effective medicines. It is because of this strong commitment to patient safety that we take deliberate, sustained and proactive steps to strictly enforce the quality and safety of our medicines.

Celgene continuously implements strategies and explores new technological developments to deter counterfeiting. We also address product integrity issues by establishing business practices to ensure that our therapies are securely distributed within our authorized markets. We work closely with regulatory bodies, law enforcement agencies, industry peers and consumer protection authorities worldwide to strengthen, enact and enforce anti-counterfeiting laws and to raise awareness of counterfeiting. We also support law enforcement and industry initiatives to actively combat counterfeiting.

On a global basis, Celgene works with international law enforcement and customer agencies to act against the manufacturers and distributors of counterfeit medicines. We are also deeply engaged through the Pharmaceutical Security Institute and similar organizations to prevent all types of pharmaceutical crime, including counterfeiting, theft and illegal diversion.

Antitrust and Competition

Celgene employees are directed to follow all antitrust and competition laws in all places where the company conducts business. Such laws are designed to preserve fairness for all businesses by prohibiting any agreements and practices that improperly restrain business competition within marketplaces.

Animal Testing

Celgene’s Statement on Animal Testing

In the course of developing innovative new drugs for the patients we serve, it is necessary to conduct research with non-human animals. This research is done only when all other means of obtaining data cannot answer the question being asked. Any research conducted with non-human animals is done under the strict Guidelines of the Institute for Laboratory Animal Research, Division on Earth and Life Studies, National Research Council and any applicable Federal or State Guidelines. All non-human animals are acquired from approved vendors of purpose-bred animals. All research is done with review and approval by a licensed veterinarian who specializes in Laboratory Animal Medicine.

All regulated animal studies conducted to support human clinical trials, regulatory submissions and registrations are conducted in accordance with Good Laboratory Practice Regulations in AAALAC accredited test facilities. These studies are in compliance with the appropriate parts of U.S. Department of Agriculture’s (USDA) Animal Welfare Act (9 Code of Federal Regulations (CFR) Parts 1, 2, and 3). In addition, each study protocol is reviewed by the Institutional Animal Care and Use Committee (IACUC) for compliance with all appropriate regulations.