2.3 Fair competition

Domestic and European antitrust law and competition laws are enforced to maintain conditions of competition in the market. These laws prohibit anticompetitive agreements and the abuse that may be exerted from a dominant position (e.g market share above 30%). The antitrust laws and competition laws promote fair competition and protect consumers from unfair business practices.

The company strictly complies with these laws. In this respect, any action which may impede or limit free competition in any way shall be prohibited.

The Company works hard to regularly inform and train its employees in order to identify and permanently reduce the risk of the company’s employees to infringe the applicable competition rules.

The Company does not refuse, conceal, manipulate, delay or prohibit the provision of any information requested by the competition control authorities or by other regulatory authorities.

The employees may collect information on the activity of competitors using public/legitimate sources of information (internet, data/statistics published by the authorities, market research data, shelf data from pharmacy visits, etc.); also the data used will be based on the source from which it came.

The company’s employees will in no way attempt to obtain confidential information from former or current employees of some competing companies.

Landmarks for employees:

• The employees shall not be involved in any kind of cartel activity;
  
  
• The employees shall not engage in direct or indirect discussions with the company’s competitors for the purpose of aligning prices or establishing by mutual agreement practices to
  approach the market;
  
  
• The employees shall not disclose to the Company competitors or to other persons directly or indirectly interested any negotiated / obtained prices from the company’s suppliers, details of the company’s participation in various auctions, details of the company’s stocks, production informations, arrival of shipments, etc., geographic allocation of sale force or of medical advocacy;
  
  
• The employees shall not be involved in any action to boycott competitors, consumers / patients or their suppliers or in any way make it difficult to enter, remain or expand new / potential or existing competitors in the market;
  
  
• The employees shall not be involved in any action leading to the imposition of restrictions of any kind on their customers limiting their sales territory, the selling price, the quantity sold, the sales channels, etc.

Employees must immediately inform the company’s management of any issues that may be relevant to free competition as well as of any facts of the company’s employees or representatives of its business partners or other companies in the market, including competitors, in the case of in which they carry out acts that may present a risk of anticompetitive conduct, in order to enable the company to take all necessary measures to avoid involving the company in such a situation.

Employees are encouraged to seek clarification from the company’s management or legal counsel on any unclear issues regarding the application of competition law as well as any situations that may pose a risk to the company from a competitive point of view.