2022 Communication on Progress

LEO Pharma A/S

Published date

June 29, 2022

No. of questions

60

Supplemental files

CEO Statement

Signed

  • Governance

    Policies and Responsibilities

    1. Does the Board / highest governance body or most senior executive of the company:

    2. Does the company have a publicly stated commitment regarding the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a commitment within 2 years

    Yes, and the commitment is focused on our own operations

    Yes, and the commitment includes our own operations and the value chain

    Yes, and the commitment includes our own operations and the value chain along with communities and society

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    LEO Pharma Sustainability Policy: https://mc-df05ef79-e68e-4c65-8ea2-953494-cdn-endpoint.azureedge.net/-/media/corporatecommunications/leo-pharma-com/files/pdflatest/21---sustainability-policy---leo-pharma---november-2021---exec----final.pdf?rev=f3e7d307e02646339b722455d0ccec14&hash=5D7A77B37ADEDD8AB6745267C02F3AF4

    3. Does the company have in place a code of conduct regarding each of the following sustainability topics?

    No, this is not a current priority

    No, but we plan to have a code of conduct within two years

    Yes, focused on employee conduct

    Yes, focused on employees and suppliers

    Yes, focused on employees, suppliers, and other business relationships

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    LEO Pharma Code of Conduct is mandatory for LEO Pharma's employees: https://mc-df05ef79-e68e-4c65-8ea2-953494-cdn-endpoint.azureedge.net/-/media/corporatecommunications/leo-pharma-com/files/code-of-conducts/leopharma-coc-us-2021-readspread.pdf?rev=1582ebf4941c498084c4fa51ef6643ee&hash=1E2A00E6107334ACF6DDCB5151DC37E0. Sustainability Standards for LEO Pharma Business Partners is mandatory for our business partners: https://mc-df05ef79-e68e-4c65-8ea2-953494-cdn-endpoint.azureedge.net/-/media/corporatecommunications/leo-pharma-com/files/pdflatest/sustainability-standards-for-leo-pharma-business-partnersenglish2021.pdf?rev=7eccf72f24b3410b821d20fcac4643d6&hash=C9B0AAE72263F5106182744EF0B2301F

    4. Has the company appointed an individual or group responsible for each of the following sustainability topics?

    No one is specifically responsible for this topic

    Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)

    Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)

    Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights

    Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?

    No formal structure

    Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)

    Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)

    Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)

    Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Optional comment
    LEO Pharma Sustainability Board (executive level board) for human rights, labour rights and environment. LEO Pharma's Global Leadership Team for anti-corruption.

    Prevention

    6. Does the company have a process or processes to assess risk?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?

    No, this is not a current priority

    No, but we are planning to develop one in the next two years

    Yes, related to our own operations

    Yes, related to our own operations and entire value chain and other business relationships

    Human rights risks

    Labour rights risks

    Environmental risks

    Corruption risks

    Concerns and grievance mechanisms

    8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?

    Optional comment
    LEO Pharma Speak-Up Line

    8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.

    No

    Yes

    Is the process communicated to all employees/workers in local languages?

    Is the process available to non-employees (e.g., contractors, vendors, suppliers)?

    Is the process confidential (e.g., whistleblowing process)?

    Are there processes in place to avoid retaliation?

    Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)

    Other (Please provide additional information)

    9. Does the company provide or enable access to effective remedy to right holders / stakeholders where it has caused or contributed to the adverse impact?

    No process to enable remedy to stakeholders

    Remedy available to some stakeholders (i.e., some geographies, employees only)

    Remedy is available to all affected stakeholders

    Remedy is available to all stakeholders, and suppliers are expected to have similar policies

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Lessons

    10. How does the company capture lessons regarding each of the following sustainability topics?

    No lessons are regularly captured

    Conducts root cause analyses/investigation of major incidents

    Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly

    Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Executive Pay

    11. Is executive pay linked to performance on one or more of the following sustainability topics?

    No, and we have no intention to change

    No, but we plan to within two years

    Yes

    Human Rights

    Labour Rights / Decent Work

    Environment

    Anti-Corruption

    Board Composition

    12. Percentage of individuals within the company’s Board / highest governance body by:

    Number/Percentage

    Not applicable (Please provide additional information)

    Total number of board members (#)

    8

    Male (%)

    87.5

    Female (%)

    12.5

    Non-binary (%)

    We are not reporting on this metric.

    Under 30 years old (%)

    We are not reporting on this metric at Board of Director's level.

    30-50 years old (%)

    We are not reporting on this metric at Board of Director's level.

    Above 50 years old (%)

    We are not reporting on this metric at Board of Director's level.

    From minority or vulnerable groups (%)

    We are not reporting on this metric at Board of Director's level.

    Executive (%)

    We are not reporting on this metric at Board of Director's level.

    Independent (%)

    We are not reporting on this metric at Board of Director's level.
    Optional comment
    Data based on Board composition at December 31, 2021

    13. Do you produce sustainability reporting according to:

    Data Assurance

    14. Is the information disclosed in this questionnaire assured by a third-party?

  • Human Rights

    Materiality / Saliency

    1. Which of the following has the company identified as material human rights issues connected with its operations and/or value chain, whether based on their salience (i.e., the most severe potential negative impacts on people) or another basis?

    Optional comment
    Employee wellbeing, health & safety identified as material issue in our materiality assessment for 2021. See LEO Pharma Sustainability Report 2021 pages 12-13.

    Response

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    In 2021, we established a cross-functional working group with representation from Global Public Affairs, Clinical Process Management, Global Risk & Compliance, Global EHS, Procurement Sustainability, Risk & Compliance, Agile Working and Global Diversity & Inclusion and Global Sustainability. The purpose of the group is to strengthen our approach to human rights and support the embedding of a consistent human rights due diligence practice across LEO Pharma. To define a cohesive approach to a corporate human rights risk assessment, expanding on the high-level gap assessment conducted in 2020, the working group reviewed current approaches to risk assessment within the organization and defined the requirements to ensure alignment with the UN Guiding Principles. The corporate human rights risk assessment was conducted as a self-assessment across six impact areas: 1) Research and development, 2) Procurement, 3) Health and safety, 4) Products, sales and marketing, 5) Community impact, and 6) Employment practices. The data was collected at the end of 2021 and the analysis was completed in early 2022. The purpose of the analysis is to identify and address current or potential adverse impacts from our operations or business relationships. Due diligence is a dynamic process and maturity increases over time. We acknowledge that new, complex issues relating to human rights arise, with a commitment to review our salient issues regularly and identify appropriate actions.

  • Labour

    Commitment

    1. Does the company have a policy commitment in relation to the following labour rights principles?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    LEO Pharma Human Rights Policy November 2021

    Forced labour

    LEO Pharma Human Rights Policy November 2021

    Child labour

    LEO Pharma Human Rights Policy November 2021

    Non-discrimination in respect of employment and occupation

    LEO Pharma Human Rights Policy November 2021

    Occupational safety and health

    Occupational Health and Safety Policy in LEO Pharma Code of Conduct from 2016

    Working conditions (wages, working hours)

    1.1. For each labour rights policy, is it:

    Aligned with international labour standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving labour rights expertise from inside and outside the company?

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Optional comment
    LEO Pharma Human Rigths Policy: https://mc-df05ef79-e68e-4c65-8ea2-953494-cdn-endpoint.azureedge.net/-/media/corporatecommunications/leo-pharma-com/files/pdflatest/23---human-rights-policy---leo-pharma---november-2021---exec---final.pdf?rev=8079d9f8992d46c197fc2879d729916b&hash=67CAAA75837E77A397DFFCEE852EFB8E Occupational Health and Safety Policy in LEO Pharma Code of Conduct: https://mc-df05ef79-e68e-4c65-8ea2-953494-cdn-endpoint.azureedge.net/-/media/corporatecommunications/leo-pharma-com/files/code-of-conducts/leopharma-coc-us-2021-readspread.pdf?rev=1582ebf4941c498084c4fa51ef6643ee&hash=1E2A00E6107334ACF6DDCB5151DC37E0

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks /impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights issue?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders, in particular workers' organizations, to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    4. Who receives training for the following labour rights issues?

    No training provided

    Select employees

    All employees

    Contractors

    Direct suppliers of the organization

    Indirect suppliers of the organization

    Other – such as partners, clients, etc.

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights issues?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Forced labour

    Child labour

    Non-discrimination in respect of employment and occupation

    Occupational safety and health

    Working conditions (wages, working hours)

    Performance

    6. What is the percentage of employees covered under collective bargaining agreements?

    Percent of employees (%)

    Unknown

    Employees covered under collective bargaining (%)

    7. What is the percentage of employees in a trade union or other workers' organization?

    Percent of employees (%)

    Unknown

    Not applicable (Please provide additional information)

    Employees in a trade union or on a worker committee (%)

    8. In the course of the reporting period, what was the percentage of women in:

    Percent of women (%)

    Unknown

    Senior leadership level position

    50

    Non-executive board

    Optional comment
    In 2021, the gender distribution at difference management levels were: Executive management: 50% women / 50% men Senior management: 34% women / 66% men Middle management: 48% women / 52% men

    9. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?

    Salary ratio (%)

    Unknown

    Choose to not disclose

    Women / Men (%)

    10. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?

    Frequency of injury

    Unknown

    Choose to not disclose

    Frequency of injury

    1.7
    Optional comment
    We use Lost Time Injury (LTI) rate - covering our manufacturing sites. Global LTI rate per million working hours calculated as: (Number of global injuries with more than one day's absence from work x 1,000,000 working hours) / Total number of working hours based on local standard working hours

    11. In the course of the reporting period, what was the company’s incident rate?

    Incident rate

    Unknown

    Choose to not disclose

    Incident rate

    Response and Reporting

    12. In the course of the reporting period, has the company been involved in providing or enabling remedy where it has caused or contributed to the adverse impact associated with the following labour rights issues?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Freedom of association and the effective recognition of the right to collective bargaining

    Choosing not to disclose

    Forced labour

    Choosing not to disclose

    Child labour

    Choosing not to disclose

    Non-discrimination in respect of employment and occupation

    Choosing not to disclose

    Occupational safety and health

    Choosing not to disclose

    Working conditions (wages, working hours)

    13. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the labour rights principles, including any challenges faced and actions taken towards prevention and/or remediation.

    Diversity and inclusion: • Launched our Diversity and Inclusion manifesto ‘Curiosity beyond’. • Introduced the Lead Inclusively leadership learning journey. • Launched first wave of Ignite Inclusion social learning events for employees. Employee safety: • All our manufacturing sites hold ISO 45001 certification. All sites passed the annual EHS audit under ISO 45001 (Health & Safety) without any major non-conformances. • Safety awareness continued through toolbox talks, safety walks, and systematic problem solving in case of injuries, to improve safety performance. • High focus on safety in large construction projects.

  • Environment

    Commitment

    1. Does the company have a formal policy on the following environmental topics?

    No, and we have no plans to develop a policy

    No, but we plan to in the next two years

    Yes, included within a broader policy

    Yes, articulated as a stand-alone policy

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Biodiversity mentioned in Environment, Climate & Energy Policy in the LEO Pharma Code of Conduct. Last reviewed in 2016.

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Minimizing energy use is mentioned in our Environment, Climate & Energy Policy in the LEO Pharma Code of Conduct. Last reviewed in 2016.

    1.1. For each environmental policy, is it:

    Aligned with international environmental standards?

    Publicly available?

    Approved at most senior level of the company?

    Applied to the company’s own operations?

    Applied to the company’s supply chain and/or other business relationships?

    Developed involving environmental expertise from inside and outside the company?

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Prevention

    2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental issues?

    No engagement on this topic

    To better understand the risks/ impacts in question

    To discuss potential ways to prevent or mitigate the risks/ impacts in question

    To agree on a way to prevent/ mitigate the risks/ impacts in question

    To assess progress in preventing/ mitigating the risks/ impacts in question

    To collaborate in the prevention/ mitigation of the risks/ impacts in question

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    We comply with authority requests with regards to thresholds.

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Optional comment
    LEO Pharma has submitted its emission reduction target to the SBTi.

    3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?

    Provided internal training/ capacity building for the direct workforce

    Building capacity among relevant business relationships (e.g., partners, suppliers, clients, etc.)

    Conducting an audit process and/or corrective action plan

    Collective Action with peers or other stakeholders to address the issue

    Collaboration with governmental or regulatory bodies

    Other (Please provide additional information)

    No action within reporting period

    Climate Action

    Increase share of renewable electricity to 92%

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    High recycling rate (98.9%) driven by progress at out manufacturing sites in Esbjerg (DK), where residual waste is processed and used as fertilizer.

    Energy & Resource Use

    Increase share of renewable electricity to 92%.

    4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?

    No monitoring of progress

    Review issues on ad-hoc basis

    Set annual targets/ goals, track progress over time (internal programs only)

    Set annual targets/ goals, track progress over time (internal and external programs)

    Other (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    4.1. For each environmental topic in which the company sets timebound goals / targets, what kind of targets has the company set?

    Description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)

    Climate Action

    Scope 1 and 2 target: Reduce carbon emissions by more than 50% from 2019 to 2030. Scope 3: Ensure that 75% of our suppliers by emission have set their own science-based targets by 2026. Our emission reduction target are validated by the Science Based Targets initiative (SBTi).

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    4.2. For each environmental topic in which the company sets timebound goals / targets, how is progress against target / goal tracked?

    Progress is reviewed against goals annually or more frequently

    Progress is reported internally to the most senior level

    Progress is reported externally

    Other (Please provide additional information)

    Climate Action

    Energy & Resource Use

    Water

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Oceans

    5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any actual impacts associated with the following environmental issue(s)?

    Yes

    No

    Choose to not disclose

    Not applicable (Please provide additional information)

    Climate Action

    Water

    Oceans

    Forests / Biodiversity / Land Use

    Air Pollution

    Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)

    Energy & Resource Use

    Climate Action

    6. What were the company’s gross global greenhouse gas emissions for the reporting period?

    Scope 1 Emissions

    Emissions (tCO2e)

    22559

    Scope 2 Emissions

    Emissions (tCO2e)

    9182

    Scope 3 Emissions

    Emissions (tCO2e)

    393369
    Optional comment
    Scope 2 covers our market based (585 tonnes) and location based (8597 tonnes) emissions. Scope 3 emissions covers 2020 data - our scope 3 data is one year delayed.

    7. What percentage of the company's revenue was invested in R&D of low-carbon products/services during this reporting period?

    Percent of revenue (%)

    8. Has the organization acted to support climate change adaptation and resilience?

    Energy / Resource Use

    9. Please report the company's renewable energy consumption as a percentage of total energy consumption in the reporting period.

    % of total energy consumption

    92
    Optional comment
    Share of renewable electricity. Data covers our manufacturing sites in Ballerup and Esbjerg (Denmark), Dublin and Cork (Ireland), Segrate (Italy) And Vernouillet (France).

    Technology

    10. What percent of the company's revenue came from environmentally friendly products / services during this reporting period?

    Percent of total revenue (%)

    Sector-specific Questions

    11. Which sector(s) does the company operate in? If diversified, choose top 3 by revenue.

    Sector-specific: Water

    12. Please provide details regarding the company's water withdrawal and consumption (own operations) during the reporting period.

    Water withdrawal (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

    Percentage of water withdrawn in regions with high or extremely high water stress (%)

    Water consumption (volume of water in megaliters):

    Mega-liters

    Unknown

    Not applicable (Please provide additional information)

    Total

    384

    Groundwater:

    Surface water:

    Rainwater:

    Wastewater:

    Percentage of water consumed in regions with high or extremely high water stress (%)

    Optional comment
    The above number is converted from m3 (384,046 m3)

    13. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.

    Water intensity of products (cubic meter/$):

    Sector-specific: Waste

    18. Please report the company's total weight of waste generated in metric tonnes during the reporting period.

    Waste Generated (t)

    125489
    Optional comment
    Data covers our manufacturing sites in Ballerup and Esbjerg (Denmark), Dublin and Cork (Ireland), Segrate (Italy) And Vernouillet (France).

    19. Please report the percentage of the company's waste that was hazardous waste (i.e., hazardous waste ratio) during the reporting period.

    Hazardous Waste Ratio (%)

    0.16

    20. Please report the company's estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.

    Single-use plastics (tonnes)

    Overall Environment

    21. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including any challenges faced and actions taken towards prevention and/or remediation.

    • Submitted climate targets to the Science Based Targets initiative. • Set supplier engagement target for Scope 3. • Our manufacturing site in Segrate moved to 100% renewable electricity contracts, bringing five out of six manufacturing sites up to this standard. • Our manufacturing sites passed annual audits under ISO 50001 and ISO14001. One major nonconformity during the energy audit of the Dublin site (IE) due to lack of efficient control during the audit as a consequence of changes in the organization. All manufacturing sites, except Vernouillet (FR), hold ISO 50001. All manufacturing sites hold ISO 14001 certification.

  • Anti-corruption

    Commitment

    1. Does the company have an anti-corruption compliance programme?

    Last reviewed in 2021
    Optional comment
    Based on an external gap assessment, the programme plan was revised.

    2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g. with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?

    Optional comment
    Anti-Corruption and Anti-Bribery Policy included in the LEO Pharma Code of Conduct: https://mc-df05ef79-e68e-4c65-8ea2-953494-cdn-endpoint.azureedge.net/-/media/corporatecommunications/leo-pharma-com/files/code-of-conducts/leopharma-coc-us-2021-readspread.pdf?rev=1582ebf4941c498084c4fa51ef6643ee&hash=1E2A00E6107334ACF6DDCB5151DC37E0

    Prevention

    3. Who receives training on anti-corruption and integrity?

    Optional comment
    As well as ad-hoc training of third parties (distributors)

    3.1. How often is such training provided?

    One time only

    Every year

    Every two or more years

    We do not collect this data

    All employees

    Select employees

    Contractors

    Direct suppliers of the organization

    Other – such as partners, clients, etc.

    Indirect suppliers of the organization

    Optional comment
    Yearly Code of Conduct training, but stand alone Anti-corruption training every 3 years

    4. Does the company monitor its anti-corruption compliance programme?

    Optional comment
    Monitoring is country and risk based. A formalized approach is under development.

    Response and Reporting

    5. Please report the company's total number and nature of incidents of corruption during the reporting year.

    Number of incident(s)

    Unknown

    Choose to not disclose

    Confirmed during the current year, but related to previous years

    Not chosen as metric in external reporting

    Confirmed during the current year, and related to this year

    Not chosen as metric in external reporting

    6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?

    7. Does your company engage in Collective Action against corruption?

    8. Briefly describe practical actions the company has taken during the reporting period and/or plans to take to implement the anti-corruption principle, including any challenges faced and actions taken towards prevention and/or remediation.

    • Relaunched the LEO Pharma Code of Conduct and related training to all employees. • Implemented new system for our Speak-Up Line replacing the Whistleblower Hotline.