Aicore Consumer Hrvatska

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Aicore Consumer d.o.o.

Aicore Croatia

CODE OF BUSINESS CONDUCT

AND ETHICS

Kodeks poslovnog ponašanja i etike

 

Contents

  1. General Provisions
  2. Compliance with the Law
  3. Integrity and Anti-Corruption
  4. Ethical Interactions in Healthcare
  5. Quality, Product Safety, and Pharmacovigilance
  6. Fair Competition and Business Relationships
  7. Respect for People and Working Conditions
  8. Protecting Assets and Information
  9. The Company and Society
  10. Reporting Violations (Speak Up)
  11. Final Provisions

Acknowledgment and Commitment

 

1. General Provisions

1.1. Purpose of the Code

The Code of Business Conduct and Ethics (the “Code”) sets the shared standards of behaviour at Aicore Consumer d.o.o. Croatia (the “Company”). The Code explains our values, our mandatory rules, and what we expect from each other. It also shows where to go with questions or reports about violations. The purpose of the Code is to protect patients and consumers, the Company’s reputation, and every employee from the risks linked to breaking the law or ethical rules.

1.2. Scope

The Code applies to all employees of the Company, regardless of position, and to managers and owners in the part that concerns them. The Company also expects contractors, agents, distributors, consultants, and other third parties who act on its behalf or in its interest to follow the principles of this Code.

Not knowing the Code or the law does not remove your responsibility. If a rule seems unclear or appears to conflict with local practice, ask your manager or the person responsible for compliance for guidance.

1.3. Our Mission and Values

The Company’s mission is to extend life and improve its quality: through medicines and medical devices whose effectiveness is based on evidence-based medicine and meets international recommendations; and by promoting a culture of responsible use and responsible prescribing of medicines.

Respect for the consumer. The consumer comes first. We promote a culture of responsible use and responsible prescribing of our products.

Respect for employees. We build an open and clear management system. We value responsibility, initiative, honesty, and dignity in everyone.

1.4. Evidence-Based Medicine and Responsible Self-Care

When we choose our product portfolio and in all our communication, we follow the principle that evidence-based medicine comes first. We do not overstate what our products can do, we do not promise a guaranteed result, and we do not encourage uncontrolled use. The information we provide must be true, balanced, and supported by approved materials (the summary of product characteristics and the package leaflet, registration documents, and scientific sources).

1.5. Responsibilities of Employees and Managers

Every employee must:

  • know and follow the Code, internal policies, and the laws that apply to their work;
  • act honestly, in good faith, and in the interest of the Company, and avoid conflicts of interest;
  • report known or suspected violations;
  • cooperate during internal reviews.

Managers must also lead by example. They should create an atmosphere where people are not afraid to ask questions and report problems, and they must not allow retaliation against anyone who reports a concern in good faith.

1.6. How to Make Ethical Decisions

If you are not sure whether a decision is right, ask yourself a few questions. If the answer to any of them is “no” or “not sure,” stop and ask for advice.

Questions to check your decision

Answer

Is it legal and in line with the Company’s internal policies?

Yes / No

Is it honest toward patients, partners, and colleagues?

Yes / No

Does it avoid a conflict of interest and not look like bribery?

Yes / No

Would I be comfortable if colleagues, management, or the press found out?

Yes / No

 

2. Compliance with the Law

2.1. The Rule of Law

The Company operates in full compliance with European Union laws and the laws of the Republic of Croatia. If the law is stricter than this Code, the law applies. If the Code or an internal policy is stricter than the law, the Code applies. No business goal can justify breaking the law.

2.2. Key Legal Acts

In its work, the Company follows, among others, the acts below (the list is not exhaustive).

EU law:

  • Directive 2001/83/EC on the Community code relating to medicinal products for human use (including the advertising rules and the ban on advertising prescription-only medicines to the general public);
  • Regulation (EC) No 726/2004 and the role of the European Medicines Agency (EMA);
  • Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR);
  • Regulation (EU) 2017/745 on medical devices (MDR);
  • Directive 2002/46/EC (food supplements) and Regulation (EU) No 609/2013 (food for special medical purposes);
  • Articles 101 and 102 of the Treaty on the Functioning of the EU (competition);
  • Directive (EU) 2019/1937 on the protection of persons who report breaches (the Whistleblower Directive);
  • Directive 2011/62/EU and Delegated Regulation (EU) 2016/161 (fight against falsified medicines).

Croatian laws:

https://narodne-novine.nn.hr/clanci/sluzbeni/2013_06_76_1521.html

  • any other law under Croatian agency for Medicinal products and Medical devices:
    https://www.halmed.hr/en/O-HALMED-u/Zakoni-i-pravilnici/
  • Whistleblower Protection Act as of October 30th 2025;
  • Labour Law;
  • Personal Data Protection Act;
  • Competition Protection Act;
  • Criminal Code (provisions on corruption and bribery, including commercial bribery);
  • Act on Counteracting Money Laundering and Terrorist Financing.

The exact versions, numbers, and dates of these acts, and the list of the Company’s authorisations and registrations, should be confirmed and kept up to date.

2.3. Industry Standards

As part of the European pharmaceutical group AICORE and a partner of international manufacturers, the Company follows recognised industry standards for ethical promotion — in particular the EFPIA Code and the IFPMA Code, as well as the codes of INFARMA (the Employers’ Union of Innovative Pharmaceutical Companies): the Code of Good Practice of the Pharmaceutical Industry and the Transparency Code. If these differ, the stricter rule applies.

 

3. Integrity and Anti-Corruption

3.1. Zero Tolerance for Corruption

The Company has a zero-tolerance policy toward corruption in any form. It is forbidden to offer, promise, give, demand, or accept an improper benefit — directly or through a third party — in order to influence a decision or gain an unfair advantage. This applies to both public officials and private individuals (commercial bribery).

3.2. Improper Benefit and Bribery

An improper benefit is not only money. It can also be gifts, discounts, services, jobs for relatives, paid trips or entertainment, conditional donations, and similar things. So-called “facilitation payments” (small unofficial payments to speed up routine procedures) are also forbidden.

Special care with healthcare professionals (HCPs). Any item of value given to a doctor, pharmacist, or institution must not be a reward for prescribing, recommending, buying, or dispensing the Company’s products. Detailed rules are in Section 4.

3.3. Gifts, Hospitality, and Entertainment

Gifts and hospitality are allowed only when they are modest, occasional, suitable for the business context, recorded transparently, and do not create a sense of obligation. Below are general guidelines; specific limits are set in a separate policy.

Acceptable

Not acceptable

Low-value branded souvenirs

A modest business meal during a work meeting

Educational or scientific materials

Cash or cash equivalents (cards, vouchers)

Gifts or entertainment in exchange for a decision or prescription

Paid holidays or travel for family members; expensive gifts

It is forbidden to hide a gift or hospitality, or to record it falsely in the books.

3.4. Dealing with Government Bodies and Officials

The rules for public officials are stricter. Any hospitality, gifts, or sponsorship connected with public officials need special care and prior approval. Lobbying, tenders, and public procurement are carried out honestly and transparently, with no attempt at improper influence.

3.5. Charity, Sponsorship, and Donations

Charity and sponsorship are possible only for a legitimate purpose, set out properly in a contract, and must not be used as a hidden reward for a business advantage. Donations to political parties on behalf of the Company are forbidden. Sponsoring a doctor’s participation in scientific events is governed by Section 4.

3.6. Conflicts of Interest

A conflict of interest happens when an employee’s personal interests affect, or could affect, how objectively they do their job. Examples: a second job with a competitor or a counterparty; a financial stake in a supplier; hiring or supervising close relatives; using your position for personal gain.

Employees must avoid conflicts of interest. If a conflict exists or is likely, you must tell your manager or the compliance officer in writing without delay. Reporting in time is not a violation; hiding a conflict is.

3.7. Anti-Money Laundering and Knowing Your Counterparty

The Company does not enter into relationships that could be linked to money laundering or the financing of terrorism. Before starting to work with a counterparty, the Company carries out due diligence (“know your counterparty”): it confirms that the counterparty really exists, that its business is lawful, who its ultimate owners are, and that it is not on any sanctions list. Payments are made only for real goods or services, to the counterparty’s account, and with proper documents.

 

4. Ethical Interactions in Healthcare

4.1. Interactions with Healthcare Professionals

We work with doctors, pharmacists, and healthcare institutions with respect for the independence of their professional judgement. We may pay an HCP for a service (for example, a lecture or a consultation) only for a service that was really provided, at fair market value, under a written contract, and with supporting documents. Payment can never depend on how much of our product is prescribed or purchased.

4.2. Proper Promotion and Advertising

All promotional and informational activity must be true, balanced, evidence-based, and in line with the approved summary of product characteristics (SmPC). It is forbidden to mislead, to overstate effectiveness, to play down risks, or to make unfair comparisons between products.

Prescription medicines. Advertising prescription-only medicines to the general public is forbidden (Article 7 of the Medicine promotion Act). Information about such medicines may be given only to healthcare professionals, in the proper formats (specialist events and publications).

Over-the-counter (OTC) products. Advertising OTC products to the general public is possible, within the limits of the Pharmaceutical Law and Medicine promotion Act: without suggesting that a specialist’s advice is not needed; without promising a guaranteed effect; without using fear of illness. Advertising must not be directed at children.

Medical devices and food supplements. These categories have their own rules (the Medical Devices Act and Regulation (EU) 2017/745 for medical devices; food law for supplements). It is forbidden to claim medicinal properties for products that are not medicines.

4.3. The Work of Medical Representatives

Medical representatives give professionals only accurate, current, and approved information. They respect the time and the workflow of institutions, do not apply pressure, and do not offer inproper incentives. All visits and activities are recorded in line with internal procedures.

4.4. Product Samples

Where allowed, samples are given only so that professionals can get to know the product, in reasonable quantities, and with records of how samples move. It is forbidden to give samples as an incentive or to allow them to be resold.

4.5. Scientific Events and Support for Education

The Company may organise or support scientific and educational events (conferences, webinars, symposia). The venue and format must fit the work purpose; the entertainment part must not be the main focus. If the Company pays for a professional’s participation (registration, travel, accommodation), the amount must be reasonable and modest, must not cover the costs of accompanying persons, and must not include luxury conditions.

4.6. Transparency and Disclosure of Transfers of Value

In line with the EFPIA Code and the INFARMA Transparency Code, the Company aims for transparency and discloses transfers of value to healthcare professionals and healthcare organisations — for example fees, participation costs, and sponsorship. Disclosure is made in the manner and within the time limits set by the applicable codes and laws.

4.7. Patients and Patient Organisations

Cooperation with patient organisations must be transparent: we disclose our support and do not try to influence their independent position. The Company does not give individual medical advice and always directs consumers to qualified healthcare professionals.

 

5. Quality, Product Safety, and Pharmacovigilance

5.1. Product Quality and Compliance

The safety of patients and consumers comes first. The Company works only with products that are authorised or registered for the market. It follows the rules for storage and transport and the requirements of good distribution practice. Any doubt about product quality is escalated immediately to the responsible persons.

5.2. Pharmacovigilance and Reporting of Adverse Reactions

Important: if you – whatever your position – learn about an adverse reaction, a quality complaint, a lack of effect, off-label use, or any other case linked to product safety, you must pass this information to the pharmacovigilance officer within 24h.

Pharmacovigilance officer contact (QPPV / local contact person):
Vlatka Kartelo, aicore-office@aicore-consumer.hr

5.3. Fighting Counterfeit Medicines

The Company actively fights the circulation of falsified, substandard, and unregistered medicines. It applies authenticity-verification measures under Delegated Regulation (EU) 2016/161. Report any sign of such products in the supply chain immediately and do not let them move further.

5.4. Accuracy of Product Information

All information about products — on websites, in materials, and in presentations — must match the approved data. It must carry the notice that the information does not replace a consultation with a doctor or the advice of healthcare professionals.

 

6. Fair Competition and Business Relationships

6.1. Fair Competition

The Company competes fairly, on the quality of its products and service. Any agreement with competitors on prices, on dividing markets or customers, or on coordinating tender terms is forbidden, as is the exchange of sensitive commercial information that could breach competition law (including Articles 101 and 102 TFEU). It is forbidden to obtain information about competitors by illegal or dishonest means.

6.2. Relationships with Partners, Suppliers, and Distributors

We choose partners and suppliers objectively, based on quality, price, reliability, and integrity. We expect partners to follow principles comparable to this Code, including anti-corruption requirements and respect for human rights. Contractual obligations are met in good faith.

6.3. Fair Advertising and Communication with Consumers

Communication with consumers must be clear, true, and not misleading. We do not use manipulative techniques, we respect consumer rights, and we respond to enquiries and complaints in time and correctly.

 

7. Respect for People and Working Conditions

7.1. Dignity, Equal Opportunity, and Non-Discrimination

We respect the dignity of every person and provide equal opportunities. Decisions on hiring, pay, training, and promotion are based on a business assessment, not on sex, age, ethnic origin, religion, health, disability, family status, political views, or other features that are not related to the work.

7.2. No Harassment, Bullying, or Violence

Any harassment (including sexual harassment), bullying, intimidation, humiliation, or violence is unacceptable. Everyone has the right to work in a safe and respectful environment. Report such cases through the channels described in Section 10.

7.3. Health and Safety at Work

The Company cares about the health and safety of its employees, follows occupational safety requirements, and expects everyone to take responsibility for their own safety and that of their colleagues.

7.4. No Child or Forced Labour

The Company does not use and does not tolerate child labour, forced labour, or bonded labour in any form, either in its own operations or in its supply chain.

 

8. Protecting Assets and Information

8.1. Confidential Information and Trade Secrets

Employees must protect the confidential information of the Company, its partners, and its counterparties (commercial terms, product data, plans, know-how). It may be disclosed only with proper authority or when the law requires it. The duty to keep information confidential continues after employment ends.

8.2. Protection of Personal Data

Personal data of employees, consumers, doctors, and partners is processed in line with the General Data Protection Regulation (GDPR) and the Croatian Personal Data Protection Act. Data is collected only for lawful purposes, in the minimum amount needed, kept secure, and not shared with third parties without a legal basis. The supervisory authority is Personal Data Protection Agency (AZOP). Information about adverse reactions is handled with special confidentiality.

8.3. Property, IT Resources, and Intellectual Property

Company property (including computers, phones, access rights, and funds) is used for work purposes, with care, and lawfully. It is forbidden to install unlicensed software, to bypass security tools, or to use resources for unlawful acts. We respect intellectual property — our own and that of others — and do not infringe copyrights, trademarks, or patents.

8.4. Accurate Records, Reporting, and Documents

All financial and other reporting must be complete, accurate, and on time. It is forbidden to create false, incomplete, or misleading records, or to keep hidden accounts or off-the-books cash. Documents are kept in line with the law and internal rules.

 

9. The Company and Society

9.1. Media and Public Statements

Only authorised persons give official comments on behalf of the Company. If you are not authorised, do not make statements on behalf of the Company and pass any requests to the responsible team.

9.2. Social Media

Use social media responsibly. Do not disclose confidential information, do not promote prescription medicines, and do not give the impression that your personal opinion is the Company’s official position.

9.3. Sanctions and International Restrictions

The Company complies with applicable sanctions and trade restrictions. It is forbidden to enter into relationships with persons or organisations under sanctions, or to help bypass such restrictions.

9.4. Responsibility to the Community and the Environment

We aim to act responsibly toward the community and the environment, to use resources wisely, and to manage waste properly, in line with the law.

10. Reporting Violations (Speak Up)

10.1. The Duty to Report

If you witness a violation of the Code, the law, or internal policies, or you have a reasonable suspicion of such a violation, you must report it. Reporting in time helps to fix the situation early and to protect the Company and its people.

10.2. Reporting Channels

You may use any channel that is convenient for you:

  • your direct manager or a more senior manager:

          Bruno Požgajčić

  • the internal reporting channel:
    Andriy Lovin

  • Under the Whistleblower Protection Act, there is also an external channel — a report to the Commissioner for Human Rights (Ombudsman) or the competent public authority.

10.3. Protection of Whistleblowers (No Retaliation)

The Company has zero tolerance for retaliation against anyone who reports a violation in good faith or takes part in a review. Any retaliation (dismissal, pressure, worse conditions) is itself a serious violation of the Code and of the law. This protection applies even if the suspicion later turns out to be wrong, as long as the report was made in good faith. Knowingly false reports are not protected.

10.4. Handling Reports

Reports are reviewed fairly, confidentially, and within a reasonable time. The number of people who have access to the information is limited. Appropriate measures are taken based on the results.

10.5. Consequences of Violating the Code

A violation of the Code may lead to disciplinary measures under labour law — up to and including termination of employment — and to civil, administrative, or criminal liability under the local laws. Measures are applied fairly and consistently, regardless of position.

 

11. Final Provisions

This Code takes effect on the date it is approved by the authorised body of the Company and is communicated to all employees. The Code is reviewed when needed, but at least once a year, taking into account changes in the law and in the Company’s activity.

The person responsible for explaining, updating, and monitoring compliance with the Code is Bruno Požgajčić, Regional marketing and sales manager.

Send questions about how to interpret the Code to aicore-office@aicore-consumer.hr

 

Company details:

Aicore Consumer d.o.o.

Jarunska ulica 35, 10000 Zagreb, Croatia

www.aicore-consumer.hr