Business Partners Code of Conduct

Each West team member is responsible for ensuring we are fully compliant with the West Code of Conduct (“Code”) and adhering to our Core Values. The Code, which is available in multiple languages on Westpharma.com and West’s company intranet, underpins our approach to always operating with the highest integrity.

In 2023, we were pleased to release an updated and refreshed Business Partner Code of Conduct for our customers, suppliers and partners. The updated Business Partner Code of Conduct emphasizes our key principles and expectations of ethical business conduct, including environmental responsibility, fair trade, human rights, quality and transparency of supply chain, and other key business practices.

We also overhauled the Global Compliance Risk Assessment & Mitigation Planning (RAMP) in 2023 by leveraging advanced information technology systems and prior regional assessments.

This has resulted in an actionable data driven plan for communication, education and monitoring for 2024 and beyond.

In addition, West actively promotes open communication at all levels of the organization by providing the following avenues for team members to raise questions or report their concerns without fear of retaliation:

  • A manager or shift supervisor
  • Any company manager
  • Any member of Human Resources or Quality
  • Any member of the Business Compliance & Integrity Team
  • Any member of the Law Department
  • Integrity Helpline (www.west-helpline.com or 1-800-461-9330)

In November 2023, West held its annual Compliance and Cybersecurity Awareness Week, with the theme of Awareness, Recognition and Reinforcement, which highlighted these important topics:

  • Awareness about the updated Business Partner Code, West’s Business Compliance & Integrity program, and Speak-Up at West — a program that reinforces the importance of speaking up when something does not look right.
  • Recognition of Data Privacy and Cybersecurity — featuring a dedicated session on Phishing and online safety.
  • Reinforcement of West’s annual Code of Conduct and Mutual Respect training requirements.

While we reinforce Compliance throughout the year, Compliance and Cybersecurity Awareness Week gives us the opportunity to drive awareness on ways to protect West, ensure each team member understands the importance of protecting West and reinforces organizational commitment to operating with integrity.

Data Privacy

West takes its critical responsibility to secure the personal data of its customers, team members and other stakeholders very seriously. We have programs and processes in place to maintain adherence to all applicable data privacy regulations, including the European Union’s General Data Protection Regulation, the California Consumer Privacy Act, the Personal Information Protection Law and many others throughout the world. The number of jurisdictions where data privacy laws have been or will be implemented is constantly increasing. West is committed to protecting personal data and is dedicated to its data privacy program and educating team members on protecting against cyber threats.

Compliance Oversight

The West Business Compliance Committee (WBCC), chaired by West’s Chief Compliance and Privacy Officer and comprised of West’s Executive Leadership Team and the Head of Internal Audit, continue to provide strategic direction for our Compliance and Data Privacy programs and ensure regular reporting to the Audit Committee of our Board of Directors. With guidance from the WBCC,our business teams support our global Compliance structure and its corresponding policies and procedures to support our team members in acting ethically in accordance with West’s high standards.

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