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Our Code of Conduct

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IntroductionAt Getinge, we strive to do the right thing, the right way

What does this mean? It may be a simple statement, but at Getinge it means staying true to our cultural core values centered around our Passion for Life, which fuels our vision of becoming the world’s most desired medtech company.

Getinge provides products and solutions that save lives across the world. Our continued success in providing these life-saving products depends on each of us upholding our cultural core values in everything we do. It also requires us to help ensure that everyone at Getinge knows how these core values apply to every aspect of our work.

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Our Getinge Code of ConductOur Code of Conduct serves as the foundation for how we demonstrate our cultu-ral core values centered on our passion for serving our customers, their patients, and our genuine desire to improve the health and well-being of others. Getinge’s continued growth and long term success is dependent upon the integrity of our people to live our core values, which combines that passion with collaboration, openness, excell ence and ownership. Our stakeholders around the world including our customers, patients, shareholders, employees and regulators depend on us to act with the highest standards of business ethics and compliance.

While always striving for positive business outcomes in our everyday work, how we conduct business is even more important than the outcome itself. What-ever role you have at Getinge, the judgments you make reflect on our reputation and are critical to our success. Ethical behavior starts with our leaders, who must serve as models for all employees by demonstrating our core values and inspiring accountability.

This Code of Conduct will help you understand what Getinge expects of you and what our stakeholders expect of us as we operate in the highly regulated medical technology industry. It is not an exhaustive list of every policy you may need to know in your particular role, but it serves as a good reference and, if you have additional questions on those topics that are not clear to you, provides you with additional resources to help guide your actions.

Please read our Code of Conduct carefully. Ask questions if you are unsure about what to do, and promptly report any concerns. Once you have read it you will have a greater appreciation that doing the right thing, the right way will make Getinge a stronger, more competitive, and more sustainable company.

Thank you for your commitment to compliance and for your hard work on behalf of the customers and patients we serve.

Sincerely,

Mattias PerjosPresident & Chief Executive Officer

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SECTION 1: Our Cultural Core Values Guide Our Actions ........................................................................... 6Why do we have a code of conduct? ........................................................................................................................7Scope of application .......................................................................................................................................................7Our responsibilities..........................................................................................................................................................8Manager expectations ....................................................................................................................................................8Violations of the code .....................................................................................................................................................8Waivers ..................................................................................................................................................................................8Making good decisions ..................................................................................................................................................9How do I raise questions or concerns? .................................................................................................................10Where do I go for help? ...............................................................................................................................................10Non-Retaliation ...............................................................................................................................................................10Our Stakeholders ............................................................................................................................................................10

SECTION 2: Doing the Right Thing, the Right Way – For Each Other ....................................................... 12Promoting respect in our workplace ......................................................................................................................13Ensuring fair employment practices .......................................................................................................................13Ensuring work place safety .........................................................................................................................................14Drug and alcohol use ....................................................................................................................................................15Violence in the workplace...........................................................................................................................................15Protecting employee privacy .....................................................................................................................................15

SECTION 3: Doing the Right Thing, the Right Way – For Our Customers and Patients ........................... 17Product safety / quality ................................................................................................................................................ 17Customer safety .............................................................................................................................................................. 17Supporting our products ............................................................................................................................................. 17Promoting our products ..............................................................................................................................................18Patient data privacy & security .................................................................................................................................18Respecting third party information .........................................................................................................................18Business intelligence ....................................................................................................................................................19Interactions with healthcare providers ................................................................................................................ 20Government contracting and tenders ...................................................................................................................21

SECTION 4: Doing the Right Thing, the Right Way – For Our Shareholders and Our Company .......... 22Conflicts of interest ...................................................................................................................................................... 23Disclosing conflicts of interest ................................................................................................................................ 23Gifts and business entertainment .......................................................................................................................... 24Managing third parties ................................................................................................................................................ 24Protecting company assets and technology use ............................................................................................. 24Maintaining accurate books and records ............................................................................................................ 26Records management ................................................................................................................................................. 26Responding to investor and media inquiries ......................................................................................................27Insider trading ..................................................................................................................................................................27Social media .....................................................................................................................................................................27

SECTION 5: Our Relationship With Regulators........................................................................................... 28Health care laws and regulations ............................................................................................................................ 29Bribery and corruption ................................................................................................................................................ 30World trade compliance...............................................................................................................................................31Fair dealing and fair competition ............................................................................................................................ 32Government audits, inquiries and investigations ............................................................................................ 32

SECTION 6: Doing the Right Thing, the Right Way – For Our World ........................................................34Sustainability ................................................................................................................................................................... 35Environmental sustainability .................................................................................................................................... 35Political activity .............................................................................................................................................................. 35Global philanthropy ...................................................................................................................................................... 35

PassionPassion is enthusiasm for improving outcomes for others. Passion is at the center of our Cultural Core Values. As Getinge employees, we truly care for our customers and the patients that they serve. Our passion is rooted in a desire to improve the health and well being of others. Our life-saving products and services as well our commitment to environ-mental sustainability are all the result of our passion for im proving the world, today and tomorrow.

CollaborationCollaboration is working together towards success. Open communication and shared best practices are corner stones of collaboration. By sharing successful models, we can build cross-functional bridges that streamline our work and capita lize on previous experiences. Thoughtful input from colleagues will help overcome obstacles, allow us to work more efficiently and improve outcomes for our customers and their patients.

OpennessOpenness is the foundation of a feedback culture that respects every contribution. Being receptive to new ideas is about establishing a culture of openness and honest feedback. We listen to and respect each other’s contributions, no matter if they come from a new employee or a member of the executive management team. This builds trust among everyone that cooperation and collaboration are the guiding stars for everything we do.

SECTION 1:

Our Cultural Core Values Guide Our ActionsThe healthcare industry and Getinge have evolved significantly over the last century, but our commitment to our core values remains unchanged. The Getinge Code of Conduct applies our cultural core values to inspire and guide us in our daily actions in order to Do the Right Thing, The Right Way.

ExcellenceExcellence is a commitment to best-in-class products, peo ple and processes. Our excellence is based on leader-ship, mentorship, teamwork and processes. Creating high- quality, best-in-class products and services is a team effort that can’t be achieved alone. We welcome new ideas and help new employees to get onboard. Knowing that best practices are the key to earning our customers’ trust, we invest in innovation, clinical proof, and strong relationships to identify unmet clinical needs.

OwnershipOwnership is a proactive effort, being empowered to make important decisions. A chain is only as strong as its weakest link. We are committed to collaboration and openness. Our success depends on each individual taking ownership of important decisions; bearing in mind what’s best for Getinge. Our personal integrity, ethics and morals must be part of every thing we do. By taking ownership in our individual roles, we come together as a stronger team.

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Why do we have a code of conduct?Getinge’s Code of Conduct (“the Code”) reflects our core values and serves as a guide to ethical business conduct. Along with our Getinge policies and procedures it provides us with an overview of the highly complex legal and compli-ance issues we face every day in the heavily regulated global healthcare industry in which we operate. The Code offers guidance on the behaviors expected of us to help make ethical decisions and shows us how we can identify potential misconduct. It does NOT address every situation you may encounter but the Code can direct you to addi-tional resources you can turn to for help in answering your questions or raising concerns. In those instances in which local customs conflict with our Code, follow the Code.

Scope of applicationThis Code of Conduct and all relevant company policies and procedures apply to everyone conducting business for

Get inge no matter where in the world they work or what position they hold in every subsidiary or controlled affiliate regardless of seniority level, business area, function, or region. This includes all full and part-time:

• Employees• Executives• Members of the Board of Directors

We also expect anyone who works on Getinge’s behalf to comply with the relevant aspects of this Code of Conduct including but not limited to:

• Suppliers and Vendors• Agents• Consultants• Other Third Parties

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Our responsibilities££ Know the Code Each of us is responsible for knowing and complying with this Code of Conduct. Read it and follow it, along with any policies and procedures that apply to your job.

££ Act with Integrity In everything you do, be professional, transparent and honest. Realize that every action you take on behalf of Getinge reflects on Getinge.

££ Ask Questions When you don’t know how to respond in a given situa tion, ask for guidance BEFORE you act. Each of us is required to ask questions and voice concerns about our Code of Conduct through the appropriate channels to ensure Getinge’s standards are upheld.

££ Watch for Violations Stay alert for any activity that is against the law, our Code, or our policies. No one at any level of the com-pany has the authority to require you to violate the law, Code or our policies. If anyone attempts to do so, you should raise this by following the steps set out in “How Do I Raise Questions and Concerns” on Page 10.

Manager expectationsIf you manage others, you are held to a higher standard and have additional responsibilities. Managers must:

££ Offer Guidance Get to know the Code yourself and ensure your teams understand their responsibilities under the Code, and any relevant company policies and procedures.

££ Lead by Example Help employees to work ethically and honestly by always upholding our core values and our Code, supporting them openly through your words and actions. Include compliance as a factor when evaluating employee per-formance. Be alert and intervene and stop any violations of our Code, company policy or the law by anyone.

££ Observe an Open Door Policy Encourage your direct reports and other employees to feel comfortable asking questions, voicing concerns or reporting any suspected misconduct. Listen for under- standing and provide guidance when appropriate. Raise questions or concerns through the appropriate chan-nels, including your manager and the Global Ethics & Compli ance Office and report any conduct that you believe is, or may be, unethical or illegal.

££ Prevent Retaliation Never retaliate and never permit retaliation by others against anyone who raises a good faith concern about compliance with our Code, policies or the law. Clearly communicate Getinge’s ‘no-retaliation’ policy and take appropriate action if you believe there is the potential for any form of retaliation. Please refer to Page 10 of this Code for further information related to non-retaliation.

Violations of the codeAny act that violates our Code or the law could damage Getinge’s reputation and financial prospects. Failure to comply also may result in significant civil and criminal liability for individual employees and Getinge. A violation can happen when someone doesn’t follow our Code, company policies or ignores someone else’s miscon-duct or pressures someone to violate the Code.

We take all violations seriously. Violations of the Code or relevant policies and procedures may result in discipli-nary action, up to and including termination where not prohibited under applicable law.

WaiversThe Audit Committee of the Getinge Board of Directors may authorize a waiver of this Code. Waivers will only be granted in exceptional circumstances and Getinge will publicly disclose waivers as required by law.

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Making Good DecisionsDoing the Right Thing, the Right Way

We all want to do what’s right, but sometimes the right decision isn’t clear. If that ever happens ask yourself:

Answering “yes” to all of these questions means the action is probably acceptable. Any “no” or “I’m not sure” response is a signal to stop,

reconsider your course of action and ask for guidance. Remember, ALWAYS ASK BEFORE TAKING ACTION!

£ Is it Legal?

£ Is it consistent with our Code, Policies and Core Values?

£ Would I be comfortable if my manager was made aware of my actions?

£ Am I doing what is right for my team members and our customers?

£ Would I want my actions to be made public?

If you can answer YES to

ALL of these questions the action is likely

okay.

If you answer NO or are not

sure to ANY of these questions

STOP and ASK!

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How do I raise questions or concerns?

Often it is easy to identify what the proper course of action is, but we may encounter situations where the right choice is unclear or there is conflicting information. If you have questions or doubts as to whether an action is consistent with our Code of Conduct, Getinge policies, or law you are expected to seek guidance to help ensure you do the right thing the right way in that particular situation.

You also have a responsibility to Getinge and your fellow employees to report any known or suspected violations of our Code of Conduct, Getinge policies or the law. By making such a report, you are helping protect the reputation and integrity of our Company and our People.

Where do I go for help? When seeking guidance you should first consult this Code of Conduct and any relevant policy or procedure. In those situ ations not directly addressed by the Code, Getinge has a number of other resources available to us. Getinge main-tains numerous policies and procedures that provide speci-fic direction across many functions of our business. Each of us is responsible for knowing and following the policies and proce dures relevant to our specific business activities. Many of these policies are also referenced within this Code of Conduct and are available on the Getinge intranet.

If, after reviewing the Code, and any relevant Getinge po-licies and procedures, you still have questions, you should consult with your manager, your local Human Resources (HR) representative, or the Ethics & Compliance organiza-tion. In addition, you may consult with subject matter experts or any of the designated compliance ‘ambassadors’ within the organization.

In most cases, your manager is in the best position to address any questions or concerns. If you are not comfort-able speaking with your manager about a given topic (for any reason), you can speak with another Getinge manager. In addition, you may ask questions relating to specific functional areas, including:

££ Human Resources For employment or employee-related issues, such as questions or concerns about potential discrimination or haras sment or concerns about management, please contact the Human Resources Department.

££ Legal Department For questions about laws and regulations and how they affect your business activities, please contact the Getinge Legal department. In addition, please contact the Getinge Legal department with questions related to lawsuits, potential lawsuits, and government or administrative investigations.

££ Finance Department For questions relating to finance or accounting issues, please contact the finance representative for your team.

££ Ethics & Compliance The Getinge Global Ethics & Compliance organization is available to assist you with any questions or con-cerns regarding our Code, company policies, and any underlying procedures. In addition, for those situations where you are more comfortable asking questions or raising concerns with someone other than your mana-ger or a subject matter expert (SME), you can raise those questions or concerns with the Global Ethics & Compliance organization or via the Getinge Ethics Line. Upon request, your identity will be kept strictly confidential to the extent permitted by applicable law.

Non-RetaliationGetinge has a strict policy against retaliation. Any individual who raises a good faith concern or question about business practices or a violation of the Code or company policies and procedures, will be protected from retaliation. A ‘good faith’ report means that an individual has earnestly raised an issue that he or she believes may be in violation of this Code, Getinge policies or procedures, or law. Examples of retaliation include but are not limited to:

• Denial of benefits• Termination of employment• Demotion• Suspension• Threats• Harassment or discrimination

Our Stakeholders

Patients and CustomersGetinge is built on a genuine compassion for people’s health, safety and well-being. Based on our many years of experience and in close cooperation with healthcare provi-ders, patients and our other customers, Getinge develops innovative solutions that improve peoples’ lives, today and tomorrow, in line with our brand promise, Passion for life.

Fellow EmployeesGetinge operates in over 40 countries around the globe and conducts sales in more than 160 countries. Every day our talented employees work together to realize our vision of becoming the world’s most desired medtech company. We are passionate about helping our customers save lives and guarantee excellent care for patients across the world. We can only achieve this by working together to create a healthy and safe working environment free from discrimination and haras sment. Getinge promotes a culture based on collabora-tion and openness, two of our company core values.

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FOR QUESTIONS OR CONCERNS ABOUT: CONTACT: CONTACT INFORMATION:

• Any Code of Conduct Topic

• Violation of Law, Getinge Policy or Procedure

• Concerns regarding misconduct

• Your Manager

• Your local Human Resources representative

• Ethics & Compliance representatives

• HR@getinge.com

• Ethics.Compliance@getinge.comYour Global E&C or Regional Compliance Officer

• The Getinge Ethics Line Country local #s can be found on the Getinge Ethics Line at www.getinge.ethicspoint.com

• Quality or Product Concerns

• Health, Safety or Security Issues

• Quality and Regulatory Compliance

• Your Manager

• Your local Human Resources representative

• Facilities Management

• Local/Site Quality Management Representative

• HR@getinge.com

• Local/Site facility management representative

Media and investor inquiries or public requests for information

Communications & Brand Management

getingeinfo@getinge.com

Corporate Social Responsibility/ Sustainability or Environmental Concerns

• Your Manager

• Your local Human Resources representative

• Getinge Sustainability Office

Getinge Sustainability Office HR@getinge.com

Company and InvestorsWe have a responsibility to our company and our sharehol-ders to act on the company’s behalf based on its interests rather than our own self-interests. We have a responsibi-lity to ensure that our company’s books and records are accurate, that information we learn while performing our work is used properly, and that we treat company assets and information with great care. Additionally, we have a responsibility to ensure that those with whom we do busi-ness share our commitment to follow Getinge’s standards for business integrity.

Government RegulatorsWorking in the highly regulated medical device and techno-logy industry, Getinge is subject to government laws and regulations designed to protect the public health by ensur-ing patients receive safe and effective products while ensuring the integrity of the marketplace. Governments are

increasingly taking on the role of customers and payors in the industry and in order to maintain our position as a trust-ed company that influences or participates in the market for our products and services we follow not only the letter of the law and regulations, but the spirit of those laws and regulations in all jurisdictions in which we operate.

Communities and the Public As a global health care company with thousands of employ-ees, we have a responsibility to the communities in which we live and operate and to the public at large. It is important that we act responsibly in all aspects of our local, national and global communities including in the political, environ-mental, and charitable activities in which we participate.

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SECTION 2:

Doing the Right Thing, the Right Way – For Each OtherA commitment to people is central to all of Getinge’s operations as demonstrated through our cultural core values combining passion with collaboration, openness, excellence and ownership. Getinge offers a work environment based on these core values and our commitment to people, including our employees.

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Promoting respect in our workplaceGetinge values its diverse workforce. We count on every em ployee to respect the varied backgrounds, skills and cultures of others, act fairly and help make sure everyone has an opportunity to participate.

££ Diversity and Inclusion Getinge recognizes that diversity is a key competitive ad vantage and becoming increasingly important to achieving success in a global environment. Getinge endeavors to recruit from a diverse mix of backgro-unds, skills, expertise and experiences to create a dynamic organization that continues to advance the company in line with its strategic objectives.

££ Equal and Fair Opportunities/Non-Discrimination Getinge is committed to providing equal opportunities in employment. We treat our fellow employees, appli-cants and business partners fairly and never engage in any form of unlawful discrimination. Getinge follows all relevant laws, regulations and standards in the coun-tries in which it operates with respect to our employ-ment decisions such as recruiting, hiring, training, salary and promotion. Getinge does not discriminate against individuals on the basis of race, gender, age, national origin, religion, sexual orientation, gender identity and expression, marital status, citizen ship, disability, or any other legally protected factor.

££ Respect for Others-Preventing Harassment Getinge does not tolerate any form of harassment or vio lence in the workplace. ‘Harassment’ is behavior that creates an offensive, intimidating, humiliating or hostile work environment that unreasonably interferes with another person’s work. Harassment can take on many forms and can include words, gestures, or physi-cal acts. Be aware that behavior that is “acceptable” in your home country may NOT be acceptable elsewhere.

Ensuring fair employment practicesGetinge supports and respects the protection of internatio-nally proclaimed human rights. Each of us has a responsi-bility to show respect for human rights and uphold the law. Getinge avoids third-party arrangements that could cause human rights violations and expects anyone who works on our behalf to share our respect for human rights.

££ Child and/or Forced Labour We do not use child or forced labor in any of our global operations or facilities. Getinge complies with appli-cable laws and international standards regarding child and forced labor. None of us should tolerate any form of unacceptable treatment of workers in our opera-tions or facilities. This means, among other things, that we do not permit exploi ta tion of children, physical punish ment or abuse, or involuntary servitude. We fully respect all applicable laws establishing a minimum age for employment, in order to support the effective abolition of child labor worldwide, Workers under the age of 18 shall not perform hazardous work.

££ Compensation and Development Practices Getinge focuses on eliminating improper wage diffe-rences and strives to reward each employee in a fair manner in accor dance with their individual performan-ce and contribution to the company. Getinge follows all applicable wage and hour laws, including minimum wage, overtime and maximum hour rules. Getinge also provides employees with opportunities for appropriate learning activities to help them develop relevant skills, grow within the company, and progress in their careers.

££ Freedom of Association Getinge respects and recognizes the right of organi- zation for employees and the right to collective bar-gaining and agreements. Getinge is committed to maintaining good communication and involvement of unions where appli cable and to always provide clear communi cation with each employee through company informa tion and consultation procedures.

What are some examples of behavior that could be considered harassment?

• Jokes or slurs related to race, religion, ethnic origin, etc.• Teasing that causes someone to be humiliated• Unwelcome flirting or advances• Displays of inappropriate materials• Bullying• Violence or threats of violence

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Ensuring work place safetyWe are committed to providing safe and healthy working con di-tions for all of our employees. We have a responsibility to under-stand and follow all company and site specific safety and security policies and procedures as well as applicable laws and regula-tions. Nothing justifies working around or ignoring any safety rule, regardless of whether it is Getinge policy, regulation or law.

If you become aware of, or suspect, any unsafe working con-ditions or other safety issues, you should report the situation to your manager, your human resources representative and/or your site safety leader or the Getinge Legal department immediately.

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Drug and alcohol useIn order to ensure a safe, healthy and productive work environ-ment for our employees, contractors and others, Getinge main-tains a drug and alcohol free workplace. We therefore may never use alcohol, illegal drugs, controlled substances or medication in a way that might harm our ability to conduct Getinge business safely and successfully. On rare occasions, we may be permitted to consume alcohol at designated work functions. These include holiday parties or office-wide celebrations. Employees are still expected to exercise moderation during such events. You should consult with your human resources representative to learn more about the drug and alcohol policies applicable to your location.

Violence in the workplaceAs part of Getinge’s commitment to creating a work environment based on our core values of collaboration, ownership and openness we never engage in or tolerate any form of violence. At Getinge, ‘violence’ includes acts of physical intimidation, threats of violence and physical abuse. Weapons are not allowed on company premi-ses, company vehicles or while conducting company business or at company-related meetings or functions, consistent with local laws. If you know or suspect incidents or threats of workplace violence, you must immediately report your concerns. If you believe some-one is in immediate danger, you should contact building security and/or local authorities.

Protecting employee privacyWe respect and protect the confidentiality of all prospective, cur rent or former employees’ personal information. If your work involves handling such information then:

• Know and follow the standards for access, use, transmissi-on, storage and disposal of employee personal information.

• Limit access to this information to authorized persons witha legitimate business need.

• Where appropriate, we should provide notice to explainhow Getinge will use an employee’s personal informationand respect individual choices regarding the collection,use and disclosure of personal information. We shouldretain or destroy personal information in accordance withcompany policies.

If you believe confidential information has been accessed or distri buted, whether purposefully or inadvertently, please contact the Ethics & Compliance organization immediately. Failure to do so could subject the company to fines and/or regulatory action.

Get Help!Getinge reserves the right, subject to local laws and practices, to test applicants and current employees and contractors for illegal drugs, alcohol or abuse of doctor prescribed drugs.

If you or another employee is struggling with substance abuse, Getinge provides resources that can help. Please visit the My Employment section of the Getinge Intranet for your location or contact your local HR representative for assistance.

What is Personally Identifiable Information (PII)?Personally Identifiable Information is any information that can be used, alone or in combination with other information, to identify a specific individual. It includes such information as a person’s name, address, email address, ID, government ID, photo-graph, date of birth or any combination of information that might identify an individual.

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Product safety / qualityQuality and patient safety are the foundation of our business and a prerequisite for our future development. We comply with all international, regional and national regulatory requirements for the design, development, manufacturing, service and support of our products. This includes meeting all regulatory requirements for product safety and efficacy as well as proper labeling of those products through out the product lifecycle. Every Getinge employee is expected to demonstrate this commitment to quali-ty by taking responsibility for the quality of our offerings.

Customer safetyGetinge is committed to provide sustainable solutions, products and services that deliver consistently high value, quality and reli-a bility. Product and patient safety are of the utmost importance and Getinge uses its best efforts to maintain product and patient safety at all times. All of Getinge’s products and services shall comply with relevant regulatory requirements in this respect including good manufacturing practices and Getinge policies.

Supporting our productsAll employees are expected to demonstrate the following behaviors:

• Take pride in your work and pay attention to detail,regardless of the task.

• Follow all Getinge policies, procedures and workinstructions every time.

• Complete all required training in a timely manner.• Take appropriate action in any situation in which you are

concerned about quality of a product, solution or service.• Immediately report all potential product complaints to the

appropriate quality personnel.• Look for ways to improve quality within your position

and the Company.

Reporting Potential Product IssuesYou may become aware of a potential quality or safety issue concerning Getinge products in any number of ways. This could include conversations with customers or suppliers; telephone calls; email; blogs; social media, letters, and even face to face conversations with customers, neighbors, friends or family. No matter the source, when you receive information from any source that Getinge product or service may be unsafe, you should report all information to the appropriate Quality perso nnel for your local country or region.

SECTION 3:

Doing the Right Thing, the Right Way – For Our Customers and PatientsBased on our extensive experience and in close cooperation with the healthcare industry, Getinge develops innovative solutions to improve people’s lives, today and tomorrow. We are committed to excellence in solutions for our products, systems and services by delivering well-designed and safe products, with a high degree of clinical and ergonomic efficiency. We serve our customers and patients by providing competent, responsive, and efficient solutions and services along with reliable delivery performance of those solutions and services. We strive to continuously improve by utilizing customer and patient feedback and fostering a company-wide culture of quality where all of us contribute to achieving excellence.

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Some of us fulfill a critical need by providing technical support for our products in clinical settings. This includes educating healthcare providers in the application and use of our products and interacting with patients as appropriate under the direction and supervision of that patient’s healthcare provider. In these situations it is important to remember that you represent the company and are not part of the hospital staff and are not enga-ged in the practice of medicine.

Promoting our products Our customers and patients can be assured of our credibility because we are committed to being professional and presenting our solutions in an honest and ethical manner. We promote and sell our products based on the approved product labeling and ensure that all marketing communications and materials deve-loped are accurate, truthful, and not misleading. All materials we create must be reviewed and approved through the proper channels prior to dissemination of those materials. This includes more than just brochures, sales sheets, and other promotional pieces. It can also include papers, presentations and any other materials produced by or on behalf of Getinge.

We must comply with all applicable laws and regulations and secure the appropriate approvals and marketing clearance for our products through the regulatory agencies and bodies in each region and country in which we do business globally. We will comply with all requirements for marketing, sale and promotion of those products for each particular country in which we operate.

Patient data privacy & securityWe must safeguard the privacy of all personal health information (PHI) we may come into contact with concerning patients, custo-mers, suppliers, contractors, vendors and others that we receive in the course of our work.

As a medical technology company Getinge is subject to various health information privacy laws around the world that vary widely by geography. We must understand and comply with their require-ments. Violations of health information privacy laws can result in criminal and/or civil liability and/or fines for failure to comply with these laws. If you have any questions with regard to health informa-tion privacy laws, please contact Getinge Ethics & Compliance.

Respecting third party informationAs a global leader in the healthcare market, Getinge must part-ner with third parties in order to maintain or grow our business. We seek out partners who share Getinge’s commitment to quali-ty, innovation, cost effectiveness and increased efficiency.

We strive for open communication with all of our interested third parties. As a result, we may be privy to confidential informa-tion about our vendors, suppliers, and other business partners. We must safeguard this information and honor all contractual commitments. In part, this means protecting all third party intel-lectual property, such as inventions and software, from disclo-sure, theft, loss, or misuse. Equally important, is making sure those third parties we engage with who have access to Getinge’s information safeguard it.

What is Patient Health Information (PHI)?As with PII, patient information is any information that can be used, alone or in combination with other information, to identify a specific individual. It includes such information as a person’s name, address, email address, ID, government ID, photograph, date of birth or any combi-nation of information that might identify an individual. This could include informa-tion about health status, the provision of healthcare, or payment for healthcare that can be linked to a specific individual. It also includes any information related to a patient’s health condition, services recei-ved, invoices, medical charts and insurance coverage information.

What is a Third Party?Third parties are individuals or entities or prospective individuals or entities and their representatives from whom we purchase or sell goods and services (such as suppliers, vendors, distributors, sales agents, consul-tants, or organizations (non-governmental), and investment firms).

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Business intelligenceWhile we need to know what our competitors are doing in order to effectively compete, we must respect their confiden-tial and proprietary information. Therefore, we may only use lawful and ethical methods to gather information about our competitors and customers (current or potential). We may collect business intelligence from publicly available sources such as company websites, published articles, promotio-nal materials, and customers who are not subject to any confidentiality obligations. Any Getinge business partners, consultants or agents working on our behalf should also follow these guidelines.

Please follow these guidelines for collecting and/or disseminating competitive information:

• Use only appropriate methods for collecting and disseminating competitive information.

• Never lie or misrepresent yourself when gathering infor-mation, or use covert means of gathering information.

• Do not recruit employees with the intent to obtain anyconfidential or proprietary third party information.

• Upon inadvertent or unsolicited receipt of confiden-tial third party information, immediately call the Ethics& Compliance department prior to showing or forwar-ding to others so that appropriate action can be takento address the situation.

• Never obtain confidential or proprietary informationdirectly from a competitor (please refer to Getinge’sCompetition Policy or see the Fair Dealing and Fair Competition Section of this Code of Conduct for further information).

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Interactions with healthcare providersWe respect the relationships we have with our customers and patients. We must also respect the relationship that exists bet-ween patients and their health care providers (HCPs). HCPs have a moral, ethical and legal obligation to put the patient’s healthcare ahead of their own self-interest. Our work should never com-promise the integrity of the patient-HCP relationship. Getinge complies with the follow ing basic principles with regard to wor-king within the healthcare industry and with healthcare providers (HCPs) and patients:

££ Patient Benefit All interactions between Getinge and HCPs must be based on the HCP’s activities and the needs of their patients and clearly linked to Getinge’s business.

££ Transparency All cooperation between Getinge and HCPs must be open and transparent and in accordance with applicable laws, regulations, standards/codes; Getinge policies and good business practices.

££ Proportionality The obligations Getinge undertakes must be reasonable in relation to the obligation of the other party. Remuneration must be proportional, reasonable and correspond to the fair market value (FMV) of the goods or service provided.

££ Moderation Any meetings or collaboration sponsored by or arranged by Getinge must not improperly influence or jeopardize, or be per ceived as improperly influencing or jeopardizing the inde pendence of the HCP.

££ Documentation Any arrangement between Getinge and HCPs (or Patient organizations) must be documented in writing to ensure transparency of all relationships with HCPs.

Therefore, we are prohibited from offering anything of value to an existing or potential customer in order to improperly influence the selection of our products. Improper incentives may include but are not limited to inappropriate meals, entertainment, trips, gifts, free product or services, honoraria, grants or scholarships. On occasion, we may provide approved educational items, meals or other items of value in accordance with company policies and procedures.

When interacting with health care providers (HCPs) our sales and marketing teams must understand and follow all applicable company policies. In addition, Getinge adheres to and complies with the AdvaMed Code of Ethics on Interactions with Health Care Professionals (published July 1, 2009); the AdvaMed Code of Ethics on Interactions with Health Care Professionals In China (published January 1, 2017); as well as the MedTech Europe Code of Ethical Business Practice (published December 2, 2015), Abimed Code of Ethics (published 2010) and other applicable standards and codes where Getinge does business.

What is Fair Market Value (FMV)?FMV generally means the price at which items or services would be exchanged between a willing buyer and a willing seller, without consideration of either party’s position to make or influence referrals, to furnish items or services to, or otherwise generate business for the other party.

Your Ethics & Compliance organization takes into account a number of factors in determining FMV such as the individual’s qualifications, experience, geography, type of work and additional factors.

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Complying with these rules is vital to our stakeholders as well as our goal of enhancing outcomes for our patients and their caregivers. Consequences for failing to comply can result in substantial criminal or civil fines, and possi-bly even personal criminal liability. Additionally, failure to comply with these rules can directly affect our reputation in the marketplace, our brand, and our success. If you are ever uncertain as to whether a meal or other activity is appropri-ate, please contact your manager or Ethics & Compliance.

Government contracting and tendersIncreasingly, Getinge interacts with government officials and employees around the world. In many countries these interac tions are governed by very strict rules. When we respond to government tenders and contract directly with government agencies, we must comply with a complex set of rules and work closely with the Legal Department. Failure to follow these rules can result in the loss of contracts and significant or even criminal liability.

At a minimum, we must ensure that:

• All representations to the government in project pro-posals, bids, and reports are complete, accurate, andnot misleading;

• All claims for payment reflect work accurately and donot overstate the amount to which Getinge is entitled;

• We cooperate in good faith with all government requests for audits and inspections; and

• We immediately report any suspected violations oflaws or regulations, company policies or our con-tractual obligations to Legal / Ethics & Compliance.

There are different rules not only depending on where the inter actions with the government take place, but also where products and services involved originate. Please review all applicable global and country/region specific policies and procedures for interacting with and selling to the govern-ment and consult with Getinge Legal or Ethics & Complian-ce for further handling.

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SECTION 4:

Doing the Right Thing, the Right Way – For Our Shareholders and Our CompanyOne of Getinge’s cultural core values is Ownership. To succeed in meeting our obligations, sustaining our growth and reaching our goals, we must all act like owners, by protecting and treating our Company’s assets as our own and behaving with Getinge’s long-term success in mind. Assuming responsibility for our actions, demonstrating personal integrity in our decision making allows us to do the right thing, the right way for our shareholders and our company.

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Conflict of InterestA ’conflict of interest’ exists when your per-sonal, social, financial, civic, or charitable activities could conflict with Getinge’s interests or compromise your objectivity. Be aware that the activities of your relatives and/or close associates can also create conflicts of interests.

Thinking of joining an external board where a conflict of interest might exist?Please consult with your manager or Ethics & Compliance before making a commitment.

Conflicts of interestWe are obligated to act at all times solely in the best interests of Getinge. In order to uphold our Company’s reputation, we must be alert to any situations that may create a conflict of interest, whether actual or potential. A ‘conflict of interest’ arises when you have a personal relationship or financial or other interest that could interfere with your obligation to act solely in the best inte-rests of Getinge, or when you use your position within Getinge for personal gain.

There are many situations that may create a potential conflict of interest. We must be careful to make sure our business and financial dealings and relationships do not cause situations where we may even give the appearance of being biased. Some common situations where an actual or potential conflict of inte-rest may arise include:

• You (or a member of your household or immediate family)are a supplier, customer or competitor of Getinge, or anemployee of such a company.

• You (or a member of your household or immediate family)have a substantial financial, ownership or professionalinterest in a supplier, vendor, customer, competitor, distri-butor or other company with which Getinge seeks to dobusiness.

• You have a direct or indirect reporting relationship with(or have the ability to influence employment decisions for)a member of your immediate family or household, or some-one with whom you have a personal relationship.

• You have outside employment or other activities with acom pany or individual that competes with Getinge, or doesbusiness with Getinge, or that affects your ability to doyour work for Getinge.

• Accepting a gift, payment or favor to a business partner.• Offering a gift, payment or favor to a business partner.• Accepting a business opportunity for yourself that was

intended to benefit Getinge.

Disclosing conflicts of interestIf you find yourself in a situation in which a potential or actual conflict of interest could occur, you must immediately report it to your manager, your local Human Resources manager, or directly to Ethics & Compliance. Once you disclose the potential or actual conflict, the appropriate Getinge personnel can then properly review the situation and assess it through the Com-pany’s Conflict of Interest policies and processes. Getinge will work with you to find an appropriate solution. You are expected to take any remedial actions requested by the Company.

If you are aware of any other potential conflicts at Getinge, you should report these to your manager or through the other appro-priate channels for reporting. Executive officers and directors must report potential or actual conflicts to Getinge Legal.

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Gifts and business entertainmentJust as gifts and business courtesies can undermine the integrity of our relationships with customers, they can create a real or per ceived conflict of interest in our interactions with third parties. While there may be appropriate business reasons for accepting business courtesies, such as meals and entertainment, we must use sound judgment in order to avoid a real or perceived conflict of interest. We may never solicit gifts, entertainment, or recrea-tion for personal use. Likewise, we may never offer or provide gifts to any customer, supplier, distributor, vendor or other per-son with whom we do business or seek to do business.

As a common business courtesy, or per local custom, there may be rare occasions where we may accept gifts that are nominal in value and could not be perceived as being lavish (i.e. pens, mugs, meals etc.) or intended to improperly influence busi-ness decisions. However, you should check with your manager, Human Resources, or Ethics & Compliance if you are unsure.

Managing third partiesWe rely on our suppliers and other third parties to provide quality products and services for our company and our customers. It is critical that our suppliers and other third parties with whom we do business share our commitment to conducting business with integrity and in compliance with all applicable laws and regula-tions. When dealing with suppliers, contractors, consultants, distributors, agents, or other third parties, you should abide by the following:

• Engage in fair and open competition.• Not retain a third party to do anything illegal or improper.

We cannot ask third parties to do something that we arenot allowed to do ourselves.

• Consider any actual or potential conflict of interest that could occur as a result of engaging that particular third party.

• Choose qualified third parties with a reputation for qualityand integrity.

• Make sure all arrangements with third parties follow allapplicable Getinge policies and procedures.

Protecting company assets and technology useWe work in many different locations. These can include an office, a warehouse, a manufacturing facility, a hospital, other health-care facilities, remote locations or our home. The equipment

we use to perform our work is to be used for appropriate business purposes. We each have a responsibility to protect these assets from theft, loss, misuse and waste.

There are instances where you may use company equipment for personal use (e.g. computers or cell phones). Such use is permitted as long as it is lawful, minimal, does not interfere with your work performance; does not result in a perceived or actual conflict of interest, and does not result in a loss to Getinge. For additional information with regard to access to company compu-ter resources such as company internet and email please refer to the End User Acceptable Use Policy.

Know how to say”No Thank You”.It isn’t always easy to refuse a gift or an offer of entertainment, especially if it may offend the giver or damage a business relationship. If you are unsure of how to proceed in a given situation, ASK:

• Your manager, or• Human Resources, or• Ethics & Compliance

What is a Third Party?Third parties are entities or prospective entities and their representatives with whom we do business.

Confidential InformationConfidential information can be any com-pany information that is not yet public. It can include such things as financial data or projections; business development activi-ties; strategic plans; new or current product design plans; customer lists; terms, discount rates or fees offered to particular customers or suppliers; manufacturing and marketing processes or techniques; and passwords or other security information.

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A. Confidential InformationOpen exchange of Company information is critical to our success as an organization. Information concerning our business activities is often confidential and crucial to maintaining our competitive advantage. Disclosure of confidential information outside Getinge could seriously damage our Company’s interests. Therefore, safe-guarding our Company’s information is everyone’s responsibility. We must:

• Ensure conversations are not overheard• Secure sensitive documents; and• Protect mobile, handheld devices and laptops from theft

and loss and never leave them unattended.

If you know or believe confidential information has been shared (either purposeful or inadvertent), you should contact your mana ger, Getinge’s Security or Privacy officer immediately upon becoming aware of such a situation.

B. Intellectual PropertyGetinge’s intellectual property is one of our most valuable assets. We protect our Company’s intellectual property by obtaining patent, trademark, or trade secret protection, and by taking appropriate care to prevent inappropriate disclosure of, use or loss of such infor mation. We vigorously protect our rights and enforce where appro priate to protect them. For more informa-tion on your obligations please see Getinge Group Intellectual Property Policy: Patent Rights Management or contact Getinge Legal. If you wish to engage in discussions with third parties and may receive or disclose confidential and/or intellectual property information, please contact Getinge Legal to ensure you have the appropriate protection in place prior to disclosing or recei-ving such information via a Non-Disclosure Agreement (NDA) or other appropriate documentation.

Intellectual PropertyIntellectual property is commonly under-stood to be patents, trademarks and copy-rights, but also includes trade secrets, trade dress, manufacturing know how, photos, videos, individual names and likenesses, and other intangible industrial or commercial property.

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Maintaining accurate books and recordsGetinge shareholders depend on our honesty and integrity, particu larly when measuring the financial performance and strength of our Company. Reporting accurate, complete and understandable information about our Company’s business, earnings and financial condition is one of our most important duties. Getinge will provide accurate, timely and transparent information on the company’s activities, performance, and financial situation to all shareholders in accordance with stock market regulations. Getinge’s ac-counting statements will present a true and correct picture of the company’s financial performance in line with Interna-tional Financial Reporting Standards (IFRS).

It is essential that everyone at Getinge works to ensure the integrity and prompt, accurate reporting of business information. Manage ment personnel and financial officers involved in the prep aration or communication of our public disclosures must understand and comply with Getinge’s standards for public disclosure.

For further information on this topic please refer to the Getinge Communication Policy and Getinge Insider Policy.

Records managementEach of us is responsible for the accuracy of the records we create and maintain. We must never knowingly create or partici pate in creating incomplete or misleading informa-tion or inaccurately record the timing of any event or trans-action. Doing so may constitute fraud and may subject you and Getinge to criminal prosecution.

We also must comply with all applicable company poli-cies and procedures related to maintenance of accurate written records. These include, but are not limited to:

• Manufacturing and quality systems records to facilita-te inspection, audit review and regulatory inspectionfor our products.

• Sales and distribution information to generate accura-te financial reports and projections.

A. Legal HoldsIt is important that we take special care to retain all docu-ments that relate to any imminent or ongoing investiga-tion, lawsuit, audit or examination involving our Company

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consistent with applicable privacy laws. This means that we never conceal, alter, or destroy any documents or records related to any such inquiries consistent with applicable privacy laws. Engaging in such activity may expose you or our Company to criminal liability.

Responding to investor and media inquiriesEffective information and communication is vital to Getinge’s success. Getinge’s Communication Policy provides a common platform and practical guidance to ensure accurate and alig-ned communication in compliance with all applicable laws and regulations and to protect and promote our company image and business in a proper and consistent manner. In order to ensure we speak with one voice, we are prohibited from initiating com-munications on behalf of Getinge with the press, investors or public interest groups unless we are authorized to do so under Getinge’s Communication Policy.

Should you receive any inquiries or requests for information, please take the following actions:

A. For all Media and General InquiriesIf you receive a request for information about Getinge from the media or community members at large, you should refer them to Getinge’s Corporate Communications department.

B. For all Financial related InquiriesIf you receive a request for information about Getinge from an agency, including investors and financial analysts, please immedi ately contact the Chief Financial Officer (CFO) or the Head of Investor Relations.

Insider tradingWe may become aware of material non-public information about our Company or other companies with whom we do business. We are strictly prohibited from engaging in or becoming involved in insider trading or other trading actions or disclosure of insider information to others as prohibited by law. Any violation of insider trading laws is a serious crime and may result in criminal liability and damage to Getinge’s reputation. Getinge has also developed an Insider Policy that is applicable to all Getinge employees and contractors registered as an inside person with the insider register kept by the Swedish Financial Supervisory Authority. This Policy contains additional requirements for all affected persons.

For additional information, please see our Getinge Insider Policy and Guidelines.

Social mediaSocial media offers ways to interact with customers, current and future employees and the world at large. There are a variety of tools including blogs, online social networks, and chat rooms. However, we may not use social media tools to speak for or on behalf of Getinge, conduct Getinge business, or otherwise res-pond to information requests for business purposes unless you are authorized to speak on the Company’s behalf. Further, when using social media purely for personal reasons, we may not share Getinge confidential information or give the appearance that we are speaking on Getinge’s behalf.

What constitutes inside information?Inside information is information of a precise nature which has not been made public, which directly or indirectly concerns an issuer or a financial instrument and which, if it were made public, is likely to have a signi-ficant effect on the prices of such finan cial instruments or the prices of related finan-cial derivative instruments.

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SECTION 5:

Our Relationship With RegulatorsGetinge operates in the highly regulated medical device and technology industry around the globe and is subject to ever increasing and complex laws and regulations. These laws and regulations are designed to protect the public health by ensuring patients receive safe and effective products while ensuring the integrity of the marketplace. In order to maintain our reputation and demonstrate our cultural core values of Passion, Collaboration, Openness, Excellence and Ownership we must always operate in an ethical manner in each interaction with government regulators.

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Health care laws and regulationsWe follow all applicable health care laws and regulations in the development, manufacture, promotion, sale, and distribution of our products. We have developed internal policies and proce-dures to ensure we meet or exceed these legal requirements and are expected to follow them. In addition, there are various industry standards such as the MedTech Europe Code of Ethical Business Practice and AdvaMed Code of Ethics on Interac-tions with Health Care Professionals with which Getinge also complies. These areas of law include:

£ Medical Device Laws : We comply with all applicable laws, regulations and company policies in the design and development, approval and regi-stration, and promotion and distribution of our products. Laws vary from country to country and we must understand and comply with the laws in each country in which we do business. In addition, we are required to maintain records and document our activities to demonstrate to government agencies that regulate medical devices, such as the United States Food and Drug Administration, that we have appropri-ate quality systems and controls in place to ensure the safe and effective manufacture and distribution of our products.

£ Sales, Reimbursement and Billing: We sell our products based on their efficacy quality, safety and price, not as the result of inappropriate financial relation-ships, gifts or entertainment of health care providers (HCPs) or patients. We don’t give anything of value to induce a HCP to use or recommend our products. Likewise we don’t submit or cause the submission of false claims for healthcare reim-bursement to the government (see side information box).

£ Transparency Laws: We report certain transfers of value (TOV) to physicians and other health care providers or organizations as required by transparency laws and regulations in every location where we operate.

£ Ineligible Persons: We do not hire or work with individuals who have committed fraud or other unlawful actions against government health care programs. In the U.S., individuals who have engaged in such activities may be placed on exclusion lists that debar them and by extension any companies they work with from doing business with the government. Any U.S. employee who is, or learns that he or she may become, an ineligible person must immediately disclose this to Ethics & Compliance.

What Laws apply to Sales and Reimbursement?Since government payors are an integral part of and provide payment of healthcare around the world there are laws in place globally that prohibit the inducement of, purchase, or submission of false claims for these products or therapies such as the U.S. Anti-Kickback Statute and False Claims Act. There are similar laws and standards in other countries as well.

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Bribery and corruptionCorruption undermines our integrity and reputation and has a significant negative impact on the value of our business and long-term success. All countries in which we do business have laws prohibiting companies and individuals from engaging in corrupt activities or paying bribes to influence business decisions. We comply with these laws and participate only in business activities where we can compete honestly and fairly based on the quality and price of our offering. Any attempts to improperly influence decisions or gain favorable treatment for our company are prohibited.

For additional information please see the Getinge Anti-Cor-ruption Policy which applies to all employees and members of the Board of Directors. In addition, Getinge expects all business representatives, including agents, distributors, consultants, ser-vice partners, suppliers and other contractors or intermediaries representing Getinge to comply with all relevant aspects of our Anti-Corruption Policy.

A. BriberyWe conduct business responsibly, ethically and free from any form of bribery, regardless of local practice or custom. We do not make business decisions based on any personal benefit given or offered to us. Likewise, we may never, in any instance, offer a bribe to or receive a kickback from anyone working on our behalf.

B. Third PartiesWe cannot hire third parties to do something that we are not allow ed to do ourselves. We can still be liable for violating anti-corruption laws even if we did not know, but should have known, that an agent, distributor, or other third party acting on our behalf was giving someone such as a government official an illegal payment.

We must screen and perform proper due diligence on any third parties with whom we do business. If you suspect that a third party may be making illegal payments, please notify your manager and Ethics & Compliance immediately to share your concerns.

Consequences for failure to comply with anti-corruption laws such as the UK Bribery Act; Brazil Clean Companies Act; and U.S. Foreign Corrupt Practices Act can be severe. Payment of illegal bribes by or on our behalf can result in criminal and civil liability including imprisonment. In addition, bribery in one country can result in criminal and civil liability not only in that country but also in other countries as well.

C. Gifts for Governmental OfficialsOne of Getinge’s cultural core values is openness and we take pride in our honest and transparent business practices. Doing business with the government and public officials is subject to additional rules and increased scrutiny. As such we must avoid giving any kind of gift to a government official or to an emplo-yee of a government owned enterprise. There are standards for nominal gifts and entertainment that vary from country to country and even region to region within those countries. You are respons ible for knowing and complying with local monetary lim its, laws, regulations, applicable company policies and indu-

Bribery DefinitionThe offer or receipt of any payment, kick-back, gift, loan, fee, reward, contract, service employment, favors or any other advantage to or from a person as an incentive to im-properly do something or refrain from doing some thing, or to unduly influence a deci-sion or to act dishonestly or improperly in relation to his principal or employer. A bribe does not have to be cash.

Government OfficialsGovernment Officials can include officials and employees of a government department or agency, a political party, a state-owned/controlled company or entity (such as a public hospital, public university or state- owned media organization) or a public international organization such as the World Health Organization or the UN or any candi-date for political office irrespective of title, level of seniority or the person.

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stry standards with regard to providing anything of value (i.e. meals, small nominal gifts, etc.). If you have any questions or are not sure, please contact your regional Legal or Com-pliance representative or contact Global Ethics & Compli-ance for guidance prior to engaging in any activity.

For more information, please see our Anti-Corruption Compliance Policy.

World trade complianceGetinge is a company that operates globally and needs to comply with the complex laws and regulations that govern the import and export of products (i.e. devices, software, services or technology). Those of us responsible for ship-ping and transferring products from one country to another or are engaged with third parties who do so on our behalf need to be aware of, understand and comply with all rele-vant company policies regarding international trade. There are three general areas of trade compliance that apply.

££ Export Controls Export Controls refer to laws and regulations imposed by countries (usually in furtherance of foreign affairs, national security, or human rights objectives) that restrict dealing with targeted countries, individuals, entities, or govern ments. A number of countries res-trict the export of parti cular types of technology and information without an appropriate license, regardless of the intended destination of the particular techno-

logy or information. We must ensure that we follow appropriate policies and procedures to understand whether such exports are permitted and whether any additional licenses are needed prior to shipping.

££ Sanctions Sanctions are trade penalties imposed by one nation onto one or more nations. Sanctions can be unilateral- imposed by one country on another or multilateral-im-posed by one or more countries on a number of different countries. We must ensure that Getinge is not prohibited from shipping products or technology to countries or certain individuals. We accomplish this by following the appropriate policies and procedures to understand whether such exports are permitted and whether any additional licenses are needed prior to shipping.

££ Boycotts Some countries require vendors to boycott doing busi-ness with a particular country, company or person. Anti-boycott laws can be complex. As such please contact the Getinge Legal department immediately if you receive a request to cooperate with a prohibited boycott. For questions about trade laws or Getinge’s poli-cies and procedures related to trade compliance please see our Export Controls Compliance Policy or contact the Legal, Ethics & Compliance or Regulatory Affairs.

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Fair dealing and fair competitionGetinge strongly supports vigorous yet fair competition. We succeed based on the quality of our products and our people, never through unfair business practices. While Getinge always will compete strongly for business opportunities, this must be done fairly and in compliance with competition and antitrust laws. Such legislation generally prohibits agreements or understandings bet-ween competitors that undermine competition, including price fixing, allocation of customers or geographical markets, bid rigging or abuse of dominant position. Of course, it is perfectly acceptable to collect business intelligence through publicly available sources. However, we will not tolerate any behavior that prevents, restricts or distorts free and fair competition, including:

Prohibited behaviors:

££ Collusion with Competitors Proposing or entering into any agreements or understandings – whether expressed or implied, written or oral – with anycompetitor regarding sensitive matters such as pricing, bids, terms and conditions etc.

££ Sharing Information We are prohibited from sharing commercial or market informa- tion with our competitors concerning pricing, terms and conditions of sale, nor coordinate our activities with competi- tors in any way.

££ Restricting Customers and Suppliers We must consult with and obtain approval from our Legal Department before entering into any agreement with a custo mer that would prohibit the customer from purchas-ing products from our competitors. We must also consult with and obtain approval from our Legal Department be-fore entering into any agreement with a vendor that could place restrictions on supplying one of our competitors.

For additional guidance, please see Getinge’s Competition Policy or contact Getinge Legal or Ethics and Compliance.

Government audits, inquiries and investigationsWe cooperate and comply with valid governmental investiga-tions and requests for information, while also protecting the legal rights of our Company and its employees. As a global healthcare company, we are subject to regular inspection in our facilities as well as inquiries regarding our business activities from a number of government agencies and personnel. We have developed policies for handling inquiries and inspections. Please consult the relevant policies before submitting to any interviews; answering questions; producing documentation or discussing compliance related matters.

Please use the following table for information on who to contact for additional information for handling various inquiries or inspections.

Trade AssociationsMake sure you clearly understand the rules for engagement and discussion with compe-titors. If anyone starts to talk about confi-dential business information (i.e. pricing, markets, future business plans), identify WHO you work for and, if necessary leave the conversation.

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TYPE OF AUDIT, INQUIRY OR INVESTIGATION

Manufacturing or Service Facility Inspections or Inquiries

Lawsuit, subpoena, search warrant or request for pro-duction of documents

Interview Requests

WHO TO CONTACT: Contact your local Quality and Regulatory Compliance Management Representative

Contact Getinge Legal Department

Contact Getinge Legal Department and Communications & Brand Management

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SECTION 6:

Doing the Right Thing, the Right Way – For Our WorldOur relationship with the global community is maintained through our commitment to human rights, labor, environment and anti-corruption as evidenced by our early adop-tion of and support of the UN Global Compact and the ten principles addressing these areas. We strive to be good corporate citizens globally while recognizing our social responsibility at the local level in the markets in which our company operates.

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Sustainability

As a global provider in medical technology, Getinge is in a position to make significant contributions to a better society. Getinge always acts as a responsible company to support human health as well as society in general. With a passion for life, Getinge is built upon a genuine compassion for people’s health and well-being. Based on our firsthand experience and close partnerships with clinical experts, healthcare professionals and medical technology specia-lists, we are improving the everyday life for people – today and tomorrow.

In order to realize our vision to become the world’s most desired medtech company we embrace our social and environmental responsibilities by integrating sustainability into our long term business strategy.

Getinge has established a Sustainability organization to further operationalize our sustainability efforts and drive employee engagement. The Sustainability organiza-tion identifies and further develops sustainability metrics and our methods for reporting those. Getinge reports its progress towards its sustainability goals as part of Ge-tinge’s Annual Report and is currently working to develop a Sustainability Report providing disclosures based on the Global Reporting Initiative (GRI) Sustainability Reporting Standards to further demonstrate our commitment towards positive sustainable development.

Environmental sustainabilityOur environmental objective is to contribute to a sustai-nable society. We are committed to optimizing the use of energy and natural resources, minimizing our emissions to air and reducing the environmental impact of our waste handling. We expect all employees to perform the following consistent with our policies and procedures.

• Comply with all environmental laws and regulations• Integrate environmental considerations into all of

their activities

At the company level, we require all manufacturing units to implement and certify management systems that meet the ISO: 14001 standard (Environmental Management Systems) and also to have implementation plans in place for any new facilities/acquisitions for complying with ISO 14001.

We also have established the following environmental goals and metrics:

• Reduce CO2 emissions from production andcompany vehicles

• Reduce energy consumption in production• Reduce amount of hazardous waste in production• Establish recycling programs for all non-hazardous

waste in production

For additional information please see the Getinge Annual Report or contact the Getinge Sustainability organization by emailing HR@getinge.com.

Political activityEveryone is free to participate in the political process. However we may only do so on our own time and at our own expense. Getinge does not support political parties and does not make political donations. We may never use or give the appearance of using Getinge’s name, time, funds or facilities, assets or other resources directly or indirectly for political purposes or contributions without express written approval from Getinge management.

Global philanthropyWe seek to make a positive and sustainable contribution to the communities in which Getinge conducts business. You are encouraged to participate in community affairs. Charitable donations will generally be made to high- quality research and development initiatives in the medical tech-nology field in accordance with Getinge’s focus areas in different units and regions. Investments in education are also in line with the ambition of Getinge as a sustainable and responsible company. Please refer to Getinge’s Grants Policy for additional information related to Education or Research Grants.

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