Policies Codes And Standard

Anti-Bribery and Corruption (ABAC) Programme

The Anti-Bribery and Corruption (ABAC) Programme is part of wondertrust’s response to the threat and risk of bribery and corruption. The programme includes an ABAC Policy and Standard, which have been designed to help staff and external parties understand bribery and corruption risk, and their responsibilities to actively combat it.

Binding Corporate Rules

Our human resources and research and development activities involve the processing of “personal information”, including the transfer of that personal information internationally. We have adopted Binding Corporate Rules (BCRs) to enable us to make international transfers of personal information within our group of companies in compliance with data protection laws of the European Union, in particular the General Data Protection Regulation.

Third Party Oversight Programme

Our Third Party Oversight Programme helps control risks from third party business engagements with suppliers, distributors and other business partners. We want to work with business partners who share our commitment of high ethical standards and operating in a responsible way.

Our public policy statement on Working with Third Parties sets out our expectation that Third Parties will:

• Share our commitment to high ethical standards

• Comply with all applicable laws and regulations and adopt, at a minimum, our Anti-Bribery & Corruption and Labour Rights Principles

• Where relevant, comply with our standards on quality, patient safety, health and safety and the environment

• Create a culture which supports staff reporting of suspected violations of law, rules and regulations, as well as of unethical conduct, without fear of reprisal or retaliation.

Socially Responsible Investing

Socially Responsible Investing (SRI) is most commonly understood to mean investing in a manner that takes into account the impact of investments on wider society and the natural environment, both today and in the future. The Trustee of the our Pension Plans annually reviews its SRI policies as part of the Trustee business planning process, and the our Pension Plans publish ‘Statements of Investment Principles’ which provide a high level overview of the SRI policies.

The Trustee aims to be an engaged and responsible long-term investor in the assets and markets in which it invests. The Trustee believes that the integration of environmental, social and governance (ESG) factors within investment managers’ investment processes is not detrimental to the risk and the sustainable long-term expected returns from pension schemes’ investments.