The focus of Badrawy’s Ethics & Compliance Program:

• Strong leadership

It is anticipated that all our teams will guide and promote a culture of ethical and compliantbehaviour. Badrawy has an Office of Ethics and Compliance (OEC) to support us which works on developing and enhancing our compliance programme.

OEC is led by our Chief Ethics and Compliance Officer (CECO), who is a member of our senior management and makes regular reports regarding compliance matters to the Chairman of the Board and Chief Executive Officer, other senior-level leaders and Board of Directors and Public Policy Committee.

The OEC staff provides dedicated support to Badrawy’s leaders, employees andbusinesses.

To assist in the implementation of the compliance program, we have a Compliance Insights Forum (CIF) focused on our Compliance Program. The CIF is chaired by the CECO, includes senior-level leaders, and is accountable directly to the Chairman of the Board and Chief Executive Officer.

Periodic CIF meetings are held to address compliance issues, including compliance with legal and regulatory requirements and agreements, review of our compliance policy, legal and regulatory climate adjustments, risk areas and best practises, and programme enhancements.

Working with OEC staff, the Affiliate Compliance Committees are responsible for the dayto-day function of the compliance program, including monitoring of compliance, providing awareness of and training for the program, revising policies and procedures and providing guidance to local employees. The committees meet on a regular basis to discuss emerging issues and work with the OEC staff as new compliance and awareness programs are rolled out.

Compliance professionals are located throughout the world and provide oversight and guidance to the Affiliate Compliance Committees.

• Effective lines of communication

Creating an area where workers can pose questions and concerns helps evaluate the complaints and when possible, take corrective steps, including firing staff or partnerships with vendors. We report reports about real or possible breaches to senior management, the Board and the government(s), if necessary, in compliance with our internal or legal obligations.

The OEC also creates opportunities to engage in face-to-face interactions with employees by participating in national, regional and local meetings. Issues also are highlighted on our OEC intranet site and through other targeted communications vehicles.

• Relevant training

Employee training and enrichment systems and all related staff increase their knowledge of the precepts of our Code and the legal and ethical ramifications of their acts and activities.

The ethics and compliance staff collaborate with our local business teams to help them conduct training and outreach activities that help ensure compliance and improve the image of Badrawy as a good corporate citizen while strengthening consumer and other stakeholder relationships.

• Accountability

Badrawy employees and other relevant personnel are expected to adhere to our Code as a condition of their continued employment. Anyone who violates our Code, or any policy or procedure, is subject to appropriate disciplinary action.
Disciplinary measures can also be taken against any member who fails to disclose a breach of the AbbVie policy or protocol which he or she is aware of or should have been aware of.

We may not support revenge against someone who makes a good-faith complaint of a breach of our Code, rules or practises, or laws or regulations, or possible violation of them.

These instructions are well advertised and applied.

• Forthright assessment

In order to determine the efficacy of and define opportunities for change in the enforcement policy and related business processes, the OEC uses the findings of internal investigations, performance audits and risk management systems. Furthermore to find potential ways to strengthen the enforcement policy, we consider the external climate, including federal audits, agreements, business codes and regulatory advice.

• Remediation

Investigation, audit and reporting findings are reported to relevant OEC employees and corporate representatives. When an area for change is established, the OEC and other stakeholders in Badrawy are responsible for enforcing corrective measures.