Our values are defined as the following:

• Put patients first
  Everything we do is driven by the safety, health and wellbeing of patients.
  
• Be inspired by science, committed to quality
  Our company’s efforts are based on strong scientific principles and adherence to high quality standards.
  
• Strive to innovate and succeed
  We believe that innovation drives value creation and we attempt to incorporate original and diverse thinking into our development and business strategies.
  
• Deliver on promises to stakeholders
  We honour our commitments to patients, healthcare professionals, shareholders and employees.  
  
• Work collaboratively and cross-functionally
  Our multidisciplinary team works collaboratively to determine priorities and inform fast and accurate decision-making.
  
• Act with integrity
  Our credibility and reputation as a company is built on honesty and transparency with all stakeholders.

The company is in a development phase, with a strong focus on activities aiming to achieve regulatory approval of its product candidates. These priorities form an important background for the company’s priorities of CSR topics. Responsible behaviour is key to build trust and protect reputation. Nordic Nanovector’s ability to succeed also depends on the interest, trust, relations and reputation among R&D partners, employees, regulatory authorities, shareholders and other stakeholders; across the value chain of the product candidate and in every phase of the R&D cycle.

Consequently, Nordic Nanovector focuses its CSR efforts on the following areas and stakeholders:

• Safety & well-being of patients and employees
• Compliance towards all stakeholders
• R&D and business ethics in relation to all stakeholders

Policy

Nordic Nanovector is committed to build a responsible and credible business based on sustainable and sound business principles, with respect for people, the environment and society. Responsible behaviour should be a prominent role in all parts of our operations and in all interaction with our stakeholders. Nordic Nanovector has established the following key principles, reflecting the company’s vision and values, nature of business, and key stakeholders:

• Patients first
  Everything we do is driven by the safety, health and wellbeing of patients.
  
• Focus on health, safety and good working environment for employees
  Employees’ safety, well-being and job satisfaction are prerequisites to succeed in building a responsible and credible business. Nordic Nanovector shall have processes and measures in place to safeguard these concerns.
  
• Integrity and high ethical standards
  Every action taken by Nordic Nanovector, its board of directors and employees, should be characterised by strong integrity, high ethical standards and professional practices. The company shall have ethical standards and guidelines for whistle blowing Nordic Nanovector enforces anti-bribery standards in line with international business standards.
  
• Respect for the external environment
  Any business activity performed by the company which has a potentially negative impact on the external environment should be conducted in an environment-friendly way.
  
• Compliance
  Medical research and development is subject to strict legal requirements. Nordic Nanovector is committed to operate in accordance with responsible, ethical and sound corporate and business principles, and will at all times strive to comply with applicable laws and regulatory requirements. Each employee must at all times comply with the company’s ethical guidelines, SOP, GXP requirements and any other framework applicable to the company’s activities.

Approved by the board of directors on 29 March 2019

Nordic Nanovector's code of conduct

1.   Introduction

Nordic Nanovector’s mission is to extend and improve the lives of patients with haematological cancers by developing and commercialising innovative antibody radionuclide conjugates (ARCs). The company’s lead clinical-stage product opportunity is Betalutin^®, is a next-generation radioimmunotherapy that targets CD37 and is in development for the treatment of non-Hodgkin’s lymphoma. NHL is an indication with substantial unmet medical need and orphan drug opportunities.

Nordic Nanovector’s business is based on trust, and for customers, employees, shareholders and other stakeholders to feel confident about Nordic Nanovector, ethics and values have to play a prominent role in all our operations. Ethical conduct is good business. Ethics must be an everyday concern and every action taken by Nordic Nanovector and by each employee must at all times satisfy the highest possible ethical, moral and legal standards.

Nordic Nanovector is committed to operating in accordance with responsible, ethical and sound corporate and business principles and will strive to be in compliance with all applicable laws and public regulations. This requires the collective effort of all employees in the group.

This Code of Conduct applies to all Nordic Nanovector employees and board members in entities owned by Nordic Nanovector. By agreement it may also apply to independent consultants, intermediaries or others acting on behalf of Nordic Nanovector. The document provides a framework for what Nordic Nanovector considers to be responsible conduct, and defines the individual responsibilities of employees through a combination of broad principles and specific requirements. The Code of Conduct should be considered as a guiding instrument, outlining the principles on which our everyday work is based, here of influence of Nordic Nanovector. It is not the intention of Nordic Nanovector to grant or permit exemptions from the requirements of the Code of Conduct. Failure to comply with this code may result in disciplinary action.

The Board of Directors is ultimately responsible for the Code of Conduct and the compliance thereof. Managers are responsible for providing appropriate support to enable their teams to understand the requirements of the Code of Conduct and how they should be applied in practice. Managers must, through their actions, demonstrate the importance of compliance. Leading by example is critical, acting on any suspected unethical behaviour, as well as being available to employees who have ethical questions or wish to report possible violations.

Nordic Nanovector's intention is to meet ethical, moral and legal standards and have implemented a  Code of Conduct which staff and Board members must comply with. This Code of Conduct does not provide an exhaustive overview of what is considered to be responsible conduct. The ultimate responsibility to act in accordance with law and ethical norms will always remain an individual responsibility.

2.   Core values

The core values on which the operations of Nordic Nanovector shall be based on:

• Put patients first
  Everything we do is driven by the safety, health and well-being of patients.
  
• Be inspired by science, committed to quality
  Our company’s efforts are based on strong scientific principles and adherence to high quality standards.
  
• Strive to innovate and succeed
  We believe that innovation drives value creation and we attempt to incorporate original and diverse thinking into our development and business strategies.

• Deliver on promises to stakeholders
  We honour our commitments to patients, healthcare professionals, shareholders and employees

• Work collaboratively and cross-functionally
  Our multidisciplinary team works collaboratively to determine priorities and inform a fast and accurate decision-making

• Act with integrity
  Our credibility and reputation as a company are built on honesty and transparency with all stakeholders

The core values will be guideline for Nordic Nanovector employees and partners both in strategic and long term decisions as in the daily work and relationships with customers, business partners and colleagues

3.   General principles

♦ Comply with laws and regulations
All employees and board members shall comply with applicable laws and regulations and binding internal requirements in all their activities for Nordic Nanovector.

Nordic Nanovector actively promotes compliance with all laws and regulations in each jurisdiction in which we do business. The Nordic Nanovector Group, the individual companies, employees and board members shall always respect applicable laws and regulations. In addition, all employees shall comply with internal company policies and procedures. In some cases, these policies are stricter than public laws and regulations.

♦ Act in the best interest of Nordic Nanovector
All employees and board members shall be loyal to and serve the best interest of Nordic Nanovector.

Loyalty means working to promote the best interest of Nordic Nanovector, and, within the framework of applicable law and Nordic Nanovector’s policies, giving Nordic Nanovector’s interests priority over other interests. We should always use our best judgement to enhance Nordic Nanovector’s value creation, protect the Company’s interests and contribute to continuous improvement.

♦ Act with integrity
All employees and board members shall act with integrity in their activities for Nordic Nanovector.

Personal integrity means “doing the right thing”, even when nobody is watching. Nordic Nanovector insists on honesty, integrity and fairness and is strongly committed to upholding and promoting the highest ethical business standards in all aspects of our business.

4.   Specific principles
4.1 Society

We must practice good corporate citizenship and comply with laws and regulations wherever we do business.

Nordic Nanovector has responsibilities towards the community in which it operates. Nordic Nanovector recognizes the importance of having an open communication with those that are affected by our operations, whether they are employees, shareholders or the public and their representatives. Certain corporate information is available for interested parties, and Nordic Nanovector will respond in a timely manner to inquiries. Nordic Nanovector expresses support and respect for fundamental human rights and recognizes our responsibility to observe those rights when we conduct our business.

Among those rights that Nordic Nanovector considers as fundamental are:

• Freedom of thought, conscience and religion
• Freedom of opinion and expression
• Freedom from any kind of discrimination based on race, creed, color, nationality, ethnic origin, age, religion, gender, sexual orientation, marital status, disability, or other status
• Freedom from arbitrary detention, execution or torture
• Freedom of peaceful assembly and association
  

4.2   Employees

Our relationship between Nordic Nanovector and our employees, and between all employees, must be built on mutual trust, respect and dignity.

Nordic Nanovector strives to be the best at developing its business. To attract skilled people we have to be an attractive employer that offers good working conditions, fair wages and appropriate training.

Nordic Nanovector respects the rights of all employees to form and join trade unions of their choice and to bargain collectively in accordance with local laws, regulations and principles. We recognize the importance of fair wages. Nordic Nanovector shall comply with applicable working time regulations reflected in national legislation or industry standards. Moreover, we recognize the importance of providing a safe and healthy working environment.

4.3   Avoid discrimination and harassment

All employees shall avoid behavior which may be seen as discrimination or harassment.

Nordic Nanovector promotes a productive work environment and does not tolerate disrespectful behavior. Nordic Nanovector is an equal opportunity employer. Discrimination in hiring, compensation, training, promotion, termination or retirement based on ethnic and national origin, religion, sex or other distinguishing characteristics is never acceptable. Nordic Nanovector will not use force of any form or involuntary labor or employ any persons below the legal minimum age.

4.4   Avoid conflicts of interest

All employees and board members shall be loyal to Nordic Nanovector by avoiding any conflict of interest.

Business decisions must always be based on objective reasons and criteria, made in Nordic Nanovector's best interests and without unjustified influence from third parties. Employees must avoid conflict of interest between their private activities and their part in the conduct of the business of Nordic Nanovector and shall not seek to obtain advantages for themselves or others that are improper or may harm Nordic Nanovector’s interests.

Business decisions must be based on the best interests of Nordic Nanovector, rather than personal considerations or relationships. A conflict of interest arises when there is a risk that any person (or his/her relatives, friends, etc.) obtains a benefit at the expense of Nordic Nanovector. Employees must provide complete and immediate disclosure of any interest that they may have, at the time of hire or during employment, which creates, or may create, a potential risk of conflict of interest. Employees may, for example, not:

• work outside Nordic Nanovector in any capacity, such as an employee, a consultant or as a member of executive/management bodies without Nordic Nanovector 's prior written consent
• perform non-Nordic Nanovector work during working hours, unless prior authorization by the employee's superior of members of the senior management
• accept money or benefits of any kind for any advice or services employees may provide to a supplier in connection with its business with Nordic Nanovector
• offer/accept reimbursements, gifts or benefits to/from a third party which are inconsistent with accepted business practices or would be unlawful or unethical (when in doubt, employees should consult their supervisor or manager)
• demand/accept or offer/give, directly or indirectly, any kind of bribe or kickback

Employees or board members who become aware of a potential and unacceptable conflict of interest shall, without delay, notify their immediate superior.

4.5   Environment, health and safety (EHS)

Nordic Nanovector shall strive to achieve a vision of zero harm to people, the environment and society, and work purposefully and systematically to reduce the environmental impact. The Group’s services shall always be subject to strict requirements in terms of quality, safety and impacts on personal health and the environment.

4.6   Bribery and corruption

Nordic Nanovector does not permit or tolerate engagement in any form of corruption. Corruption is unacceptable business conduct, it constitutes a threat to fair competition and it undermines legitimate business activities. Applicable local and international law prohibit Nordic Nanovector and its employees from engaging in corruption, such as the bribery of public and/or private sector officials. Extraterritorial application of several anti-corruption regimes implies that it is not sufficient to observe local law when doing business abroad.

It will always be contrary to Nordic Nanovector’s interests to engage in any form of corrupt activity. Absolute compliance with Nordic Nanovector’s anti-corruption policy is required by all Nordic Nanovector employees at all times, and no Nordic Nanovector employee may authorize another Nordic Nanovector employee to deviate from this policy. Any failure to comply with this procedure will be considered a serious breach of the employee’s obligations towards Nordic Nanovector and will most likely result in termination of the employment or other applicable sanctions.

Nordic Nanovector's Anti-corruption Manual provides further guidance on Nordic Nanovector’s anti-corruption policies, and explains the basic legal and ethical requirements that Nordic Nanovector employees and representatives shall follow to avoid corrupt practices throughout their business activities for Nordic Nanovector.

4.7   Fair competition and anti-trust

Nordic Nanovector is committed to complying with fair competition and anti-trust laws applicable in the markets in which we operate. These laws are intended to prohibit practices that restrain trade or unduly limit free and fair competition.

We support fair and open competition in all markets, and we will not engage in any anti-competitive practices. As such, Nordic Nanovector shall never:

• Agree or fix prices with competitors vis-à-vis third parties, or the timing of an increase or decrease in price.
• Agree, fix or divide up certain customers, territories or markets with a competitor.
• Enter into any other form of agreements with customers, suppliers, competitors or others that are intended to unfairly limit competition.
• Share information with a competitor about our customers, prices or market strategies.
• Discuss any aspect of bidding, tenderers etc. with any of our competitors.  
• Limit a customer to only buying from the company, or require a supplier to only sell to the company.
• Agree with the customer the price it can charge to its customers or agree a minimum resale price.
• Discriminate unfairly in terms of price or services, or any other behaviour abusing a position of market dominance.
  

4.8   International trade, economic sanctions and export control

Laws governing international trade affect the transmission of goods, services and technology across national borders. These laws may include economic and trade sanctions, anti-boycott laws, export controls, and laws intended to combat money laundering and the financing of terrorism and other criminal activities. Such sanctions include sanction regulations enforcing UN Security Council resolutions in national laws, sanctions adopted by the European Union and U.S. sanctions.

It is our policy to strictly comply with these laws and regulations in the countries in which we operate. Employees who are involved in importing, exporting and in business across national borders have a particular responsibility to remain up-to-date on the latest requirements and regulations governing international trade.

4.9   Never engage in insider trading

Employees and board members shall refrain from insider trading.

Employees and board members shall not trade, nor give advice to others about trading, in the securities of Nordic Nanovector or other listed companies on the basis of non-public information acquired in work for Nordic Nanovector which, if publicly known, may influence the price of the securities.

If an employee or a board member is in doubt concerning how to apply or interpret Nordic Nanovector’s requirements or public laws on insider trading, Nordic Nanovector’s senior management should be consulted.

4.10   Money laundering

Employees and board members shall not in any way become involved in money laundering.

Money laundering is defined as arrangements implemented in order to make money which is acquired through criminal activities look as though it has been lawfully earned. Money laundering is prohibited by law, and will not be tolerated by Nordic Nanovector. Should an employee observe activities which may indicate that money laundering is, or has been, taking place in connection with company activities, the employee shall without delay report his or her concern to Nordic Nanovector.

The same rules apply to arrangements with the intent to speculate in non-detection of illegal or disloyal avoidance of taxes, customs or other duties.

4.11   Use of information and technology resources

Employees are required to safeguard and not misuse Nordic Nanovector's assets and resources.

Nordic Nanovector ASA is dedicated to achieving our business objectives. Nordic Nanovector's information and technology resources (including phones, computers, Internet and e-mail resources and the like) are provided to the employees for business use. Computer equipment must be used in compliance with Nordic Nanovector's IT guidelines. Employees are, for example, responsible for exercising good judgment regarding the reasonableness of personal use. When in doubt, employees should consult their immediate superior. Employees who engage in social networking (all types of postings on Internet, such as blogs, Twitter, Facebook, YouTube and similar media) should be mindful that their postings, even if done outside work, could have an adverse effect on Nordic Nanovector's business. Employees are expected to respect the principles of this Code of Conduct and therefore must not post any derogatory, offensive or inappropriate comments concerning Nordic Nanovector and/or our employees, customers, suppliers, other business partners or competitors. Furthermore, employees should not write about, post pictures or videos of, or otherwise refer to any employee, customer, supplier, other business partner without the consent of the relevant person. In addition, employees must not claim or imply authorization to speak as a Nordic Nanovector representative or use Nordic Nanovector's logos, trademarks, copyrights or other intellectual property rights in any manner.

4.12   Treatment of healthcare professionals in the US

In addition to complying with the provisions laid down in this Policy, all interaction between US healthcare professionals and Nordic Nanovector employees or representatives must be in accordance with the Compliance Guide for U.S.-Bases Healthcare Professionals as well as other specific guidelines and agreements prepared by Nordic Nanovector for this purpose.

5    Compliance and implementation
5.1 The duty to comply

Each Nordic Nanovector employee and board member has a personal responsibility for complying with all the requirements specified in this Code of Conduct. Employees and board members shall not act (or encourage others to act) contrary to the Code of Conduct. This requirement applies even when violation of a principle may appear to be in the interest of Nordic Nanovector.

Any uncertainty as to whether a particular activity is in accordance with the principles of this Code of Conduct, should, insofar as is practicable, be discussed in advance, primarily with the immediate superior. Nordic Nanovector believes in discussions about responsible conduct in an improvement-oriented and informal manner. Nevertheless, breaches of the requirements set out in this Code of Conduct may lead to internal disciplinary action and in serious cases to dismissal or even criminal

5.2   Whistle blowing

Nordic Nanovector is committed to the highest possible standards of openness, honesty and accountability. We therefore expect employees who have serious concerns about any aspect of Nordic Nanovector’s work to come forward and voice such concerns.

In accordance with the procedures laid down in Nordic Nanovector's Whistleblowing Policy, you should make a report if you suspect actual or potential breaches of laws, our Code of Conduct, internal policies or procedure, e.g. our Anti-Corruption Policy, or ethical norms, or other kinds of wrongdoing by the company that affects employees, suppliers, customers, the company or the public in general.

Observations of conduct which is illegal or represents a breach of the principles in this Code of Conduct should be reported either orally or in writing to the employee’s immediate superior. If the employee finds it difficult to report to his or her immediate superior, the report may be addressed to the head of the Company’s investor relations and business development or any other relevant department/function, the Chief Executive Officer or the Chairman of the Board.

All reports made in good faith will be looked into internally. If serious allegations are made, the company may decide to engage external resources to assist with an investigation.

Disciplinary actions, retaliations or any negative reactions from the company towards a person who has provided a report in an appropriate manner is unlawful under this Policy.

You will never experience any negative reactions, whether formal or informal, such as dismissal, suspension, demotion or other change in duties or relocation, as a result of voicing concern in accordance with the Whistleblowing Policy.

5.3   Implementation and monitoring

The responsibility for implementing this Code of Conduct in each company lies with the company’s head of investor relations and business development in collaboration with the Group executive management. The Code of Conduct shall be distributed to all employees, managers and board members. The Code of Conduct shall also be referred to in the company’s employment contracts and Personnel Handbook. All employees, managers and board members shall carefully read this Code of Conduct.

The Board of Directors is responsible for updating this Code of Conduct and for developing relevant support material, and may also assist the companies in awareness training. The status of the companies’ activities related to this Code of Conduct will be reviewed annually as part of the business areas’ board meetings and Nordic Nanovector’s sustainability reporting.

This Code of Conduct is a statement of certain fundamental principles that apply to the conduct of employees and board members. It does not create any legal rights for any customer, supplier, competitor, shareholder or any other third party.

Approved by the board of directors 22 March 2018