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Our position statement on:
RESPECTING HUMAN RIGHTS

Mölnlycke is committed to conducting its activities in a responsible manner and with respect for the human rights across its operations.

Mölnlycke has been signatory to the UN Global Compact since 2017 and is committed to avoid causing or contributing to adverse impacts on people – whether in our own company, through our business partners, or in the communities where we operate.

When referring to human rights we take into consideration, at a minimum, the International Bill of Human Rights. It includes the Universal Declaration of Human Rights, the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights, and the ILO Declaration on Fundamental Principles and Rights at Work. We endorse the principles of the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines for Multinational Enterprises, and implement our commitment to respect human rights via our Code of Conduct, and through the development and implementation of other internal procedures and processes.

The responsibility to implement our human rights commitments is anchored in our Business Ethics and Compliance team, under the Legal Department. It is further supported by the relevant functions People, Supply Chain, Operations, Sustainability and it is overseen by a Human Rights Committee with representatives from the ELT.

We work actively to ensure that our commitment to operating with respect for human rights is integrated into relevant policies, processes, and ways of working, as well as in interactions with our stakeholders.

We have included human rights questions in our due diligence procedures and we continuously consolidate our efforts to identify, assess, and take action on the human rights impacts of our business activities and relationships. We demand the same high standard and responsible behaviour from our business partners, suppliers as well as distributors, and integrate this in dedicated reference documents such as Supplier Code of Conduct and Distributor Code of Conduct.

Mölnlycke has an available human right grievance mechanism through the use of its Ethics Hotline, which can be used by all to report concerns on any human rights issues related to Mölnlycke and its activities. In cases where we may be directly linked to adverse impacts, we commit to work with the other party involved to provide remedy.

FAIR COMPETITION

This position statement sets out the scope and approach of Mölnlycke’s fair competition ambition, taking into account the nature of our industry and stakeholders as well as relevant legislation.

Mölnlycke is committed to conducting business in compliance with all applicable laws and legislations and with integrity and focus on business ethics. Competition law is an inherent part of an ethical business, as competition laws monitor the distribution of economic power, to allow undistorted competition and healthy economies to grow.

Mölnlycke believes that fair competition is one of the essential principles of a well-functioning market, which benefits the development, progress and well-being of society. Mölnlycke’s Code of Conduct reinforces this principle by stipulating that “Mölnlycke promotes and protects competition” and that Mölnlycke personnel “shall comply with all competition laws and demonstrate fair and correct behaviour in competition”. To further ensure fair competition we follow our guiding principles:

1. We do not discuss commercially sensitive information

We do not discuss commercially sensitive information, market sharing or market allocation with our competitors. We are aware that sharing, receiving, or exchanging this type of information could be prohibited even when it is informal, such as in conversation with a former colleague or friend, or when it takes place during industry association meetings.

2. We respect fairness

Vertical agreements affect business partners that are not acting at the same level of the value chain, such as a Mölnlycke relationship with a distributor or a supplier. We respect fairness and it is important to us to not exert undue influence over our distributors. For example, in the EU, we do not prevent passive sales (i.e., sales made in response to unsolicited orders) or impose resale prices on distributors.

3. We follow best practice in tender processes

In tender processes, transparency must be maintained throughout the procurement cycle by adhering to all applicable procedures. It is therefore important that decision makers are provided with correct and transparent data. We do not exert any improper influence on the content of the tender documents, nor do we have undue contacts with decision makers in tender processes.

The guiding principles are applicable to all entities that are part of Mölnlycke and compliance with the guiding principles is mandatory for all Mölnlycke personnel and third parties working for Mölnlycke, at all levels throughout Mölnlycke, in all activities related to their positions and functions.

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Raising concerns

Mölnlycke ethics hotline

The Ethics Hotline enables internal and external stakeholders to report concerns and grievances or any other suspected violations of laws, policies and procedures or inappropriate behaviour. Topics of reports can include issues such as, but not limited to, fraud, corruption, working environment issues and discrimination.

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Distributor due diligence

Training to support ethical growth in India

Mölnlycke carries out a screening and due diligence process before entering business relationships with distributors. We also offer training for distributors to give them an understanding of the ethical standards expected from them. As we expand our distribution network in this region of the world, we launched training for its sales teams on compliance rules, ethical decision making, engagement with healthcare professionals and interactions with distributors.

Then key Indian distributors were also invited for dedicated sessions to ensure mutual understanding of the risks linked to the medical technology sector. The sessions covered topics such as ethical decision making, corruption and bribery risks, engaging with government officials and the overall Mölnlycke due diligence process. It was an occasion to explain to distributors what they can expect from our new due diligence process and discuss any questions they may have.

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