Business Ethics Policy

Corporate responsibility
At Lundbeck we are committed to our Core Beliefs and Values, which provide a guide for achieving our business goals in an ethical manner. Lundbeck is dedicated to doing the right thing and we will in the conduct of business maintain a high ethical standard, which means that we will do business with integrity and responsibility.

Compliance with laws and regulations
Lundbeck will comply with any and all relevant, applicable national and international laws and regulations. All managers have the responsibility to ensure, by taking legal or other expert advice where appropriate, that they are aware of all relevant local laws and regulations, which may affect the part of the business in which they are engaged.

In complying with the law we will not accept corruption. Accordingly, all Lundbeck employees must comply with the following integrity principles:

• Lundbeck neither accepts nor offers bribes in any form
• Lundbeck strives to avoid facilitation payments
• Lundbeck does not contribute to money laundering. All financial transactions must be documented
• Lundbeck does not pay protection money
• The value of gifts given and received must not exceed locally defined triviality limits

Lundbeck does not, under any circumstances, accept that any employee violates any law or directs another employee to violate any law on behalf of Lundbeck.

Group Communication Policy
It is our vision to become a world leader in psychiatry and neurology and hereby improve the quality of life of those suffering from central nervous systemdisorders.

We firmly believe that trust between Lundbeck and our stakeholders is a fundamental pillar of the company’s success and future development. We also believe that trust is built on communication and willingness to engage in dialogue.

We want to engage in an open, constructive and continuous dialogue with our stakeholders based on equality and mutual respect.

We encourage our stakeholders to take a positive interest in Lundbeck’s activities and obtain a clear understanding of Lundbeck’s mission, values, strategy and performance.