Business Partner Code of Conduct

Since the actions of our business partners reflect directly on Medentic, we expect our partners to uphold the highest standards of conduct and to be aligned with our values. An unethical act or violation of the law can have serious consequences for Medentic.

Because we place a priority on integral and legal conduct, we require all of our business partners (domestic and international) to read, understand, and comply with our Business Partner Code of Conduct.

Business Partner Code of Conduct

Our Expectation

At Medentic, we are committed to conducting business ethically and with integrity, and we expect our business partners to share in this commitment.

This Medentic Business Partner Code of Conduct (“Code”) articulates our own commitment and outlines the standards and practices that Medentic expects our business partners to follow while conducting business with or on behalf of Medentic. This Code applies to all of our business partners, including agency partners, technology partners, service provider partners, and any vendors, service providers, suppliers or other parties providing goods or services to or on behalf of Medentic. All Medentic business partners are required to read and comply with these standards and to ensure that the requirements are communicated, understood, and followed by their employees, agents, contractors and consultants.

Applicability

This Code defines the minimum standards of business conduct and acceptable business practices we expect of all of our business partners.

All business partners are required to have effective policies, documentation and controls that, at a minimum, incorporate the requirements contained in this Code and the laws and regulations applicable to your business.

If local laws and regulations are more permissive than this Code, you are expected to comply with the Code. If local laws and regulations are more restrictive, you must always comply with those legal requirements.

Financial Integrity and Accurate Record Keeping

The accuracy of books and records is essential to Medentic to meet legal and regulatory obligations. Business partners must maintain accurate and complete books and records related to their agreements with Medentic and all transactions with respect to any Medentic-related business. Any documentation, information and submissions that business partners provide to Medentic and/or our joint customers must be complete, accurate and not misleading in any way. Business partners must not facilitate the creation or preparation of any false, misleading, or inaccurate records or documents. Business records must be maintained in accordance with all applicable laws and regulations.

Anti-Bribery Compliance

Business partners must comply with all applicable anti-corruption and anti-bribery laws and regulations, including but not limited to the United States Foreign Corrupt Practices Act (“FCPA”), the U.S. Federal Procurement Integrity Act, the U.K. Bribery Act, as well as relevant EU and Bulgarian anti-bribery regulations and guidelines. Business partners must not, directly or indirectly (through a third party), make, offer or authorize the payment of any money, gift, bribes, kickbacks or anything of value (including gifts, travel, meals and entertainment), to anyone, including foreign or government officials, employees, or representatives of any government, company, or public or international organization, or to any other party, if such payment is intended, or could be perceived as intended, directly or indirectly, to improperly influence or obtain any unfair competitive advantage. Business partners must fully comply with any rules regarding tender and bid processes.

Honest and Accurate Dealings

Medentic business partners must not make any false or inaccurate representations in connection with any Medentic transactions, including, but not limited to, oral misrepresentations of fact, the promotion or utilization of false documentation such as fraudulent or forged contracts, or other false or inaccurate records.

Antitrust and Competition Laws

Business partners must comply with all applicable antitrust and competition laws and regulations. These laws are designed to protect consumers and competitors against unfair business practices and to promote and preserve competition. For example, it is not permissible to do or attempt to do any of the following:

• 1) Agree with other partners or companies to fix or control prices for offerings.
• 2) Agree with other companies to boycott suppliers or customers.
• 3) Agree with other companies to divide or allocate markets or customers.
• 4) Coordinate bids with other companies.

Conflicts of Interest

Business partners will not engage in any activity that could interfere with its contractual responsibilities to Medentic or that may be perceived as a conflict of interest that could reasonably be likely to interfere with such responsibilities. Conflicts of interest may include, but not be limited to, Medentic personnel being an officer, director or shareholder of business partner, payment of incentives to Medentic personnel, or any economic or family relationship with Medentic personnel. In the event you become aware of a conflict of interest or potential conflict of interest, you must promptly notify Medentic at integrity@medentic.app.

Trade Compliance

Bulgarian and international trade laws control where Medentic may send or allow access to its products, services, and information and to whom Medentic may send or allow access to its products, services, and information. Business partners must strictly comply with all applicable trade compliance laws, including laws that control the import, export, and re-export of Medentic products, services, and information and laws that restrict dealings with sanctioned entities or individuals or in countries subject to trade embargoes or economic sanctions.

Communications Regarding Medentic

All statements, communications, and representations to Medentic customers must be accurate, complete, and not misleading in any way. Similarly, business partners must not make or attempt to make any written or oral agreements or commitments on behalf of Medentic, including product feature commitments, without written authorization from Medentic.

Insider Trading Laws

Business partners must comply fully with applicable insider trading and securities laws governing transactions in Medentic securities. Business partners that possess or have access to material, non-public information about Medentic or other companies including other Medentic partners or Medentic customers as a result of their relationship with Medentic are prohibited by law and Medentic policy from trading securities based on that information. Business partners are also prohibited from communicating such information to others who might trade on the basis of that information.

Government Customers

Activities that may be appropriate when dealing with non-government customers may be improper and even illegal when dealing with government entities as well as businesses that are government-owned, government–controlled or subject to government procurement rules (“Government Customers”). Business partners that sell to Government Customers must observe all laws, rules, procurement regulations and contract clauses that relate to the acquisition of goods and services by such Government Customers, whether such sale is direct or indirect and including marketing or recommendation of Medentic products and/or services.

Intellectual Property and Protection of Information

Business partners must respect intellectual property rights, protect confidential information and comply with all applicable laws and regulations related to privacy and data protection. Business partners must protect all confidential information and personal data they acquire or have access to by virtue of their business partner relationship with Medentic. This includes personal data about or provided by Medentic employees, customers, partners, and other third parties with whom Medentic does business.

Additionally, business partners must meet the requirements in its business partner agreement with Medentic with respect to any intellectual property, confidential information and personal data.

Human Rights of Workers; Health and Safety

Business partners must be committed to upholding the human rights of workers and to treating them with dignity and respect as understood by the international community. Business partners will comply with all applicable anti-human trafficking, forced labor, and modern slavery laws and rules including the UK Modern Slavery Act 2015, the California Transparency in Supply Chains Act 2010 and Australia’s Modern Slavery Act 2018. In short, business partners must engage in fair labor standards that permit freely chosen employment, prohibit child labor and human trafficking, and allow for reasonable working hours and payment of fair wages and benefits, and comply with all applicable employment, health and safety laws.

Business partners must avoid inhumane treatment of workers. Business partners must be committed to a workforce that is free of harassment and unlawful discrimination and which allows for freedom of association of personnel. In addition, business partners must maintain a safe and healthy work environment.

Responsible Business Partner Conduct

Business partners and their representatives must conduct themselves in a professional manner while representing Medentic products and services in the marketplace. This means treating all persons with dignity and respect in a businesslike manner while marketing, selling or supporting Medentic products and services.

Improper Conduct Reporting

You will immediately report events of questionable, fraudulent or illegal nature that are, or may be, in violation of this Code, or other applicable laws or regulations, to Medentic by email integrity@medentic.app. In countries where applicable, reports can be made anonymously, and will be kept confidential to the fullest extent practicable and allowed by law.

Cooperation

Business partners will cooperate with (a) Medentic’s periodic requests for documents and/or information made in connection with Medentic’s business partner onboarding and/or review processes and (b) any investigation or audit by Medentic relating to any suspected or alleged violation of this Code or applicable law. Business partners will provide truthful and accurate responses to all requests for information and respond within a reasonable amount of time.

Violations

Any violations will be reported to the business partner’s management for their attention, and if appropriate, corrective action. Medentic may also enforce violations of this Code by taking other action(s) as it deems appropriate, including suspension or termination of the business partner’s relationship with Medentic.