Our business ethics approach is based on the UN Global Compact framework, which we have been signatories of for more than 15 years. It is also guided by Transparency International’s Guide – Business Principles for Countering Bribery.

It consists of the following key pillars:

Commit

UN Global Compact call to action In addition to our CEO’s commitment, we signed the UN Global Compact Call to Action and are calling on governments to promote anti- corruption measures and implement policies that will establish sound governance systems. The call-to-action urges governments to underscore anti-corruption and good governance as fundamental pillars of a sustainable and inclusive global economy.

Assess

Compliance with best practices, laws and regulations Following our business ethics risk assessment, the risk of corruption and bribery across our group was defined as low. Some of our offices are in countries with an increased risk of corruption, especially in projects with governmental organisations, and we will continue to monitor and assess these situations on a need basis.

In 2023, mci group received no fines or sanctions for unethical business practices and non-compliance with environmental or marketing & communications laws and regulations. We had no substantiated complaints regarding breaches of customer privacy and losses of customer data. No cases of discrimination or human rights violations were reported, and no injuries were reported.

Finally, mci group does not make contributions to political parties or politicians.

Healthcare industry regulations and compliance In addition to our standard event practices, the projects we organise for our clients in the pharmaceutical and medical device sector are bound by strict codes of conduct in compliance.

We adhere to the rules and guidelines laid down by IFPMA, EFPIA and MedTech Europe, and related respective regional and country codes. These rules cover activities such as commercial and medical publications, interactions with healthcare professionals (HCPs) and related hospitality through direct and indirect sponsorship, and give guidance for personal, virtual and hybrid engagements with HCPs and HCOs.

Our healthcare Subject Matter Experts and the respective Account Directors are responsible for the implementation and the training of processes and procedures for our talents, and work closely with our ethics team.

Define

Procedures and policy Our code of business conduct sets clear ethical expectations for all our talents and agencies.

Based on the UN Global Compact principles, our code expresses values and beliefs for conducting business responsibly and transparently.

Our policies and expectations are an integral part of our employee contract, and are shared with all new talents as part of our onboarding programme. So that our employees always have easy access to the relevant information, we have a dedicated “ethics” section on our intranet with our policies and guidelines, as well as training presentations on how to deal with ethics-related challenges.

The policies are assessed regularly by our group sustainability team and ethics council, in collaboration with the appropriate shared service teams (finance, procurement, legal, HR). They must also be reviewed and signed off by the executive committee.

We strive for associate ventures, affiliate companies and preferred partners to adopt ethical standards that are consistent with our own. For acquisitions, our due diligence processes also cover ethical risks.

We apply our values to our supply chain through our supplier code of conduct.

Manage

Implementing good governance Our board of directors, executive committee and group management team ensure the tone of good governance at the board level, applying the solid principles and values that provide the framework for how we do business.

The Ethics Officer is responsible for reviewing and responding to any compliance issues.

Escalation and whistleblowing procedures mci group encourages the reporting of any suspected unethical, illegal, corrupt, fraudulent or undesirable conduct involving our business, and protects individuals who raise a concern, so that they can do so without fear of victimisation or retaliation.

Reports of violations or suspected violations will be kept confidential to the greatest extent possible, consistent with the need to conduct an adequate investigation.

Our employees will not suffer demotion, penalty or other disciplinary action for reporting a concern, even if our company may lose business due to the refusal to do so.

When in doubt about a potentially unethical situation or the best course of action, employees, clients or suppliers can communicate directly with the local management team. If they are not comfortable speaking with their contact person, or not satisfied with the resolution, they can fill out a report on our external and secured platform or contact our business ethics team at ethics@mci-group.com.

In 2023, we received zero reports from whistleblowers.