Supplier Code of Conduct

1. Introduction

AGC Biologics has established this Supplier Code of Conduct describing the principles that AGC Biologics follows within anticorruption and ethics, human rights and labor, health and safety and environmental management.

The principles are based on the Ten Principles of the UN Global Compact, UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, the PSCI principles for responsible supply chain management and other relevant principles.

Supplier commitment to these principles is essential and AGC Biologics expects suppliers to follow these or equivalent principles and expect suppliers to select their own suppliers and subcontractors in a way that contributes to support these principles.

AGC Biologics will take appropriate action to prevent/minimize the extent of any supplier violations identified and supplier’s material breach of this Supplier Code of Conduct may result in the termination of the business relationship.

2. Application

This Supplier Code of Conduct aims as fostering a commitment to apply responsible and sustainable business practices by suppliers in their direct and indirect activities, i.e. both activities that directly impact the activities that the supplier performs for AGC Biologics, as well as its auxiliary activities. Thus, it applies to the entire production and service delivery process of the supplier, from raw material extraction to end customer delivery, including all actions of the supplier in its own business area as a vendor and a purchaser, respectively.

Suppliers are expected to familiarize themselves with and adhere to the principles set out in AGC Biologics’ Code of Conduct as appended hereto.

Should there be any inconsistency between applicable law, rules or regulations and the principles described in this Supplier Code of Conduct, the highest standards shall apply.

AGC Biologics acknowledges that conforming to these principles can be a challenge and expects suppliers to inform AGC Biologics of any nonconformance.

In the event of any identified violation, AGC Biologics will take appropriate remedial action to prevent, end or minimize the extent of the violation.

AGC may terminate the business relationship with the supplier under the following circumstances:

1. When a material breach occurs.

2. If the supplier’s implemented corrective measures fail to remedy the situation within the specified timeframe.

3. When no alternative or less severe means are available, and efforts to increase influence prove unsuccessful.

Regular training sessions and awareness programs must be established for employees and business relationships at the Supplier, focusing on reporting potential or actual breaches. Such initiatives must include comprehensive information on relevant whistleblower mechanisms, if any, ensuring that stakeholders are well-informed and capable of reporting any concerns.

To ensure compliance, AGC Biologics may issue surveys and/or perform audits, based on the principles described in this Supplier Code of Conduct.

3. Anticorruption and Ethics

AGC Biologics aims to establish long-term and mutual prosperous partnerships and to keep close communication with its suppliers to build and enhance a trusting relationship.

Suppliers are obligated to:

• Conduct their business in an ethical manner and comply with applicable law, rules or regulations and industry standards.

• Maintain healthy and normal relations with any stakeholder, and abstain from giving or receiving inappropriate financial or material benefits.

• Inform AGC Biologics of any conflict of interest or potential conflict of interest with AGC Biologics that could occur in their business.

• Not engage directly or indirectly in any form of bribery, activities that hinder fair and open competition or abuse their superior bargaining position.

• Establish a management system for import and export of goods and technologies, regulated by laws and regulations of each country and region and carry out proper export procedures.

• Safeguard and protect proprietary information, intellectual property and other assets to ensure AGC Biologics’ rights are protected.

• Comply with applicable privacy and data protection laws and ensure the protection, security and lawful use of personal data.

4. Human Rights and Labor

AGC Biologics respects the dignity and human rights of all people and expects its suppliers to comply with applicable national and international laws relating to human and labor rights.

Suppliers shall ensure that they:

• Do not allow use of forced labor, slave labor, child labor or unreasonable low-paid labor, that does not provide the employees with at least a minimum amount of income to meet their basic needs.

• Do not discriminate against people regardless of race, ethnicity, religion, caste, nationality, political affiliation, age, gender, disability, marital status, sexual orientation or any other In particular, the supplier must pay special attention to the following groups: Persons belonging to national or ethnic, religious and linguistic minorities; women; children; persons with disabilities; and migrant workers and their families.

• Do not engage in acts such as sexual harassment, abuse or power harassment that deny the personality of others or harm personal dignity.

• Ensure workers are free to leave their jobs, after reasonable notice, and are paid on time and in full for the work they have performed prior to leaving.

• Comply with the applicable laws and regulations of each country and region regarding employee working hours, holidays, paid leave grants and wages.

• Respect employee freedom of association rights to freely and voluntarily associate and build and maintain good relationships with employees through discussion and dialogue, without threat of reprisal, intimidation or harassment.

• Demonstrate reasonable modern slavery due diligence by maintaining an active view on the inherent risk of modern slavery in your supply chain (this includes third-party certifications in relation to human rights and social compliance standards). Among other modes of inquiry, AGC Biologics would expect this to include engaging human rights specialists to perform validation audits of high-risk suppliers on an intermittent, but no less than annual, basis.

5. Environment

AGC Biologics strives to minimize its impact on the environment, consumption of natural resources and final disposal volume of waste. Consequently, suppliers are expected to have comprehensive policies, criteria, and guidelines in place to ensure that business practices align with the highest environmental standards.

Adverse environmental impact, defined as significant changes that harm ecosystems, socio- economic systems, or people, should be assessed using the best available science. AGC Biologics requires its suppliers to share its vision and to ensure the following:

• Establish an environment where employees can work safely in a physically and mentally healthy environment.

• Comply with all applicable environmental laws and regulations of each country and region.

• Recognize the impact of its business operations on climate change and commit to both mitigation and adaptation measures.

• Obtain all required environmental permits, licenses, information registrations and restrictions, and follow their requirements.

• Continuously operate and improve an environmental management system to register and ensure the safe handling, movement, storage, disposal, recycling, waste, air emissions and wastewater.

• Appropriately manage all hazardous substances to prevent and mitigate accidental spills and releases to the environment.

• Appropriately manage and treat, prior to release, any waste, wastewater or air emissions, with the potential to adversely impact the environment.

• Continuously monitor and strive to reduce the consumption of energy and pursue the sourcing of renewable energy to promote sustainable consumption and production, including through the promotion of circular economy approaches.

• Acknowledges the importance of biodiversity and commit to document and disclose any use of mineral resources contained in any product, identify conflict minerals (tin, tantalum, tungsten, gold) and cobalt as high-risk minerals.

• Promote responsible mineral procurement through the use of suppliers that have been certified as not using minerals that are related to armed forces or injustice such as human rights violations.

6. Health and safety

AGC Biologics is committed to achieving the highest performance in occupational health and safety throughout its business. AGC Biologics seeks to establish and maintain a safe work culture through employee involvement and participation in the safety process.

AGC Biologics expects its suppliers to:

• Comply with all applicable occupational health and safety laws, regulations and industry standards.

• Maintain a safe and healthy environment for its employees, visitors and contractors.

• Measure the results and effectiveness of safety efforts for continual improvement.

• Ensure employee participation and engagement in the safety process.

• Consider the impact of both physical and psychological factors within the work environment in the health and safety planning process.

• Provide for the protection of employees through safe workplace and equipment design, engineering controls and procedures, training and personal protective equipment.

• Manage preventive actions to ensure that identified hazards and workplace risks are monitored and continuously reduced.

• Register and take appropriate action on reported near-misses to avoid injury.

• Provide for treatment and rehabilitation of injured or ill employees through emergency and post-injury management.

• Maintain effective communication to foster awareness of this policy and to facilitate prompt response to any inquiries or concerns.

• Ensure that all employees, visitors and contractors comply with the occupational health and safety policy and immediately report any health and safety concerns.

7. Data Privacy and Security

AGC Biologics requires its suppliers to protect the privacy of individuals, including but not limited to employees, customers, other trade partners, and the security of confidential assets and information.

Suppliers must protect AGC Biologics’ and its stakeholder’s confidential assets and information. Suppliers must design and maintain processes to provide appropriate protections for this information.

AGC Biologics requires suppliers to protect personal information in compliance with all applicable laws and regulations. Personal information provided by or on behalf of AGC Biologics must only be used, accessed, and disclosed as permitted by agreement and in compliance with all applicable laws and regulations.

8. Sanctions

AGC Biologics supports sanctions, trade embargos, export control or other trade restrictions put in place with the aim of changing the behavior of the target country’s regimes, individuals or groups in a direction which will improve the situation in that country.

Suppliers should ensure they conduct their business in compliance with all lawful international sanctions regimes. As such, suppliers must:

• Fully comply with all lawful sanctions regimes affecting their business.

• Implement effective internal controls to minimize the risk of any non-compliance with relevant sanction regimes, including training and support for their employees and contract workers.