Business Code of Conduct

PUTTING INTEGRITY INTO ACTION
Welcome to the utR Biotech Code of Business Ethics

What has always made utR Biotech special is our diverse “culture of excellence” that embraces our core values and shared commitment to operating with
the highest ethical standards.

As we continue to grow in a complex digital business environment, integrity and compliance with the law are more important than ever. But to be a truly great company, we know we must go further than mere compliance. We must empower our people to make good decisions and act with a sense of responsibility with respect to the environment around us.

With our Code of Business Ethics, we want to help our people make ethical behavior a natural part of what we do every day—with each other, our clients and business partners, and our communities where we work and live.

This Code is not just a document, it’s is part of our core beliefs, it helps govern how we live and how
we lead. It’s totally embedded in all we do. It’s how we improve our business performance and build on utR Biotech’s reputation in the marketplace.
It’s how we put our clients and our people first. It’s the utR Biotech Way of putting our integrity into action, every one of us, every day.

David Petch
Chairman & CEO
Chief Compliance Officer
utR Biotech

Our Code of Business Ethics builds on our core values by providing greater detail about expected behaviors and drives our culture of compliance, ethical conduct and accountability.

It starts with a simple proposition—we always act with integrity and we always act in compliance with the law. Besides being the right thing to do and protecting utR Biotech, acting with integrity and in compliance with laws improves our performance and reflects on our character as a business—to our clients, our business partners and the public at large—
and enables us to attract and retain top talent.

That’s the utR Biotech Way.

Our 6 enduring core values, Customer Value Creation, One Global Family, Respect for the Individual, Best People,  Honesty, Integrity and Stewardship shape the culture and define the character of utR Biotech. They serve as a foundation in how we act and make decisions.

 • Client Value Creation – Enabling clients to become high-performance businesses and creating long-term relationships by being responsive and
relevant and by consistently delivering value to end users and consumers of our products.
• One Global Family – Leveraging the power of global insight, relationships, collaboration and learning to deliver exceptional service to clients wherever they do business.
• Respect for the Individual – Valuing diversity and unique contributions, fostering a trusting, open and inclusive environment and treating each person in a manner that reflects utR Biotech’s values.
• Best People – Attracting, developing and retaining the best talent for our business, challenging our people, demonstrating a “can-do” attitude and fostering a collaborative and mutually supportive environment.

• Honesty – In everything we do, from research and reporting to working in a global supply chain and retail environment, we are honest in how we conduct ourselves.
• Integrity – Being ethically unyielding and honest and inspiring trust by saying what we mean, matching our behaviors to our words and taking responsibility for our actions.
• Stewardship – Fulfilling our obligation of building a better, stronger and more durable company for future generations, protecting the utR Biotech brand, meeting our commitments to stakeholders, acting with an owner mentality, developing our people and helping improve communities and the health and wellness of our consumers.

Our Code of Business Ethics applies to all utR Biotech people—directors, officers and employees in every country—and every utR Biotech entity. In addition, third parties, such as consultants, agents and suppliers, are required to comply with the Code of Business Ethics when acting on utR Biotech’s behalf.

    “utR Biotech entity” means any entity that is consolidated in utR Biotech’s financial statements or otherwise controlled by utR Biotech. utR Biotech’s legal team must approve any utR Biotech entity’s use of a code of conduct in lieu of this Code of Business Ethics. With respect to entities in which utR Biotech has an interest but does not have control, we encourage them to adopt and follow the Code of Business Ethics as appropriate.

Employee’s and Director’s Responsibilities
All Employees and Directors must Act ethically and comply with the law, the Code of Business Ethics and utR Biotech policies. We each have a personal responsibility to act ethically and comply with the law, the Code of Business Ethics and utR Biotech policies and procedures at all times. Violations break trust with utR Biotech and our clients and may result in individual disciplinary action, up to and including termination of employment, and perhaps legal liability. In some cases, utR Biotech may have a legal or other obligation to report the results of an investigation to the appropriate law enforcement authorities, or may otherwise choose to do so.

utR Biotech’s core values and ethics are global and consistent. We recognize that some business cultures have practices that may violate our core values and ethics, such that upholding them may be uncomfortable, even challenging. Doing the right thing often requires courage. Saying no to these practices does not mean we disrespect those cultures.

It’s also our responsibility to understand a client’s code of conduct in addition to following our own Code of Business Ethics. There may be restrictions on, for example, gifts, entertainment and physical security that are more limiting than our own, and if so, we follow them in connection with the client engagement.

When compliance is not possible, we discuss with the client. A client’s code of conduct may appear to contradict our Code of Business Ethics—for example, it may include requirements we cannot follow (because of practical limitations on how we do business) or provisions that do not apply to us. When faced with such situations, we will discuss with our partners and clients as appropriate and seek to comply with the spirit or key principles of its code, while always following our Code of Business Ethics. We also expect you to escalate: discuss with your leadership, Human Resources or Legal to resolve the issue. For example, we may need to include limitations or clarifications in our client agreements to comply with the obligations under the client’s code of conduct.

We cooperate fully with all investigations. When reporting an ethical concern, cooperation may be necessary so that we may adequately address the concern. utR Biotech may require or request additional information in some cases to properly investigate the matter.

If you have any questions about your responsibilities or any of the information in the Code of Business Ethics, please ask your supervisor, career counselor, any utR Biotech Leader, Human Resources or Legal.
You can also submit any questions directly to the Ethics group at dpetch@utR Biotech.com.

Not every issue that comes up has a clear path to resolution. In difficult situations use judgment and involve others to help make good decisions.

The “How-To” of Making Good Decisions

Unsure about any conduct or decision? Ask the following questions:
• Obligations under the law – Could it be against the law?
• Obligations to utR Biotech – Could it violate our core values, Code of Business Ethics or policies?
• Obligations to others – Could it breach an obligation to a client or other business partner
(for example, contracts or client codes of conduct or policies)?
• Do no harm – Could it cause harm to any person, our individual reputations or utR Biotech’s brand, reputation, financial performance
or business relationships?

If the answer is “yes” to any of the questions above–don’t do it.

If unsure, ask a supervisor, career counselor, any utR Biotech Leader, Human Resources or Legal.

Speak up if you experience or witness disrespectful, inappropriate, fraudulent, unethical or illegal behavior, including concerns about retaliation.

There are many ways to raise a concern, and the most effective way may depend on the nature of the concern. You can always raise a concern with your supervisor, career counselor, any utR Biotech Leader, Human Resources or Legal. You can always escalate your concern without fear of retaliation if you do not receive an acceptable response from your
first point of contact.

You may also contact the utR Biotech Business Ethics Department at http://utrbiotech.com/ where you may report your concern via the web or obtain a country-specific phone number to
speak with staff.  Contacting us via the web can be done 24 hours a day, seven days a week. In most cases, you may remain anonymous when using the utR Biotech Business Ethics Helpline; however, in certain countries this may not be the case due to local legal restrictions.

Our Code of Business Ethics is organized under 6 fundamental behaviors that apply to every one of us, every day.

Respect, fairness and shared ethical values are at the heart of utR Biotech’s culture and grounded in our core values. Making your conduct count is about fostering these values and describes behaviors that we expect from—and for—our people so that they can be at their best each day. There are five ways to make sure your conduct counts.

Speaking Up and Zero Tolerance for Retaliation
We speak up about concerns knowing utR Biotech never tolerates retaliation. Speak up about disrespectful, inappropriate, fraudulent, unethical or illegal behavior

If you have a good faith concern about disrespectful, inappropriate, fraudulent, unethical or illegal behavior of any kind, utR Biotech wants you to speak up. You can always escalate your concern without fear of retaliation if you do not receive an acceptable response from your first point of contact. We take seriously all concerns raised, including allegations of retaliation.

 Raise a concern to any of the following:
• Your supervisor
• Any utR Biotech Leader
• Human Resources
• Legal

The way we handle a concern will depend on its nature and severity. We may have discussions with relevant work colleagues, utR Biotech Leaders or Human Resources, or conduct formal investigations. Regardless of how you raise a concern, we always seek to ensure it is handled by the most appropriate people within utR Biotech—confidentially and with sensitivity.

Take action or reach out for guidance when approached about a concern involving disrespectful, inappropriate, fraudulent, unethical or illegal behavior. No matter the career level, we take concerns seriously and take action or otherwise raise them via the appropriate channel.

utR Biotech has zero tolerance for retaliation against anyone who speaks up in good faith. Retaliation means any kind of unfair treatment, whether subtle or overt. There are serious consequences for retaliation, up to and including dismissal.

    We hold utR Biotech Leaders to the highest standard of modeling respectful behavior, taking action when they see misconduct and ensuring there is no retaliation against anyone who speaks up in good faith. It is not just an expectation—it is an obligation. In some cultures, respect for leadership can make it difficult for more junior people to disagree or provide critical feedback, so we expect utR Biotech Leaders to create an environment where people feel comfortable raising their concerns.

We treat each other with respect.

Disrespectful behavior or harassment of any kind are not tolerated by utR Biotech. Disrespectful behavior takes many forms. It consists of behaviors that interfere with work performance, or any other treatment of a person that creates an intimidating, hostile or offensive work environment. It might be something someone says or does in person. It could also be done remotely by email, a posting on social media or a text or instant message.

• Bullying
• Targeted rudeness or humiliation
• Unwanted physical contact or displays of affection
• Repeated, blatant disregard for personal time
• Threatened or actual violence
• Offensive materials and jokes
• Excessive use of profanity toward an individual
• Threats of dismissal or other negative work consequences
• Shouting at employees or displaying uncontrollable anger
• Abuse of authority/intimidation
• Disregard for cultural differences
• Exclusion or continued isolation from meetings
or work social activities
• Negative attacks on personal or professional life

• Minor, one-off instances of impatience or frustration
• Vigorous and impassioned sharing of ideas or debates over tough issues
• Factual and constructive feedback addressing an employee’s performance

We expect all our people, regardless of career level or role, to treat each other, and others we interact with in work-related situations—whether in person or online—with respect and professional courtesy. This includes client and supplier personnel, advisers to our clients and hotel, restaurant and airline staff or anyone we encounter in the day to day affairs while employed by uTR Biotech.

We ensure a workplace free of disrespectful behavior or harassment. Harassment on the basis of a person’s characteristics—known as protected characteristics—is illegal in many jurisdictions. Disrespectful behavior is also potentially illegal or legally actionable in many jurisdictions. utR Biotech’s ethical values go beyond what the law requires. We want a workplace that is free from any form of disrespectful behavior or harassment, whether it is covered by law or not.

Expectation

We do not harass any person based on these characteristics:

    Race, religion, creed, color, sex, pregnancy, maternity, marital or family status, age, physical or mental disability, ancestry, genetic information, national or ethnic origin, citizenship status, sexual orientation, gender identity or expression, political belief, trade union membership, veteran status or any other status protected by applicable local law.

Expectation

We expect more from utR Biotech Leaders:

Our Leaders play an important role in setting the tone from the top and ensuring we maintain a respectful, ethical and fair work environment. utR Biotech encourages Leaders to set an example in work/life balance and all employees to be respectful of others’ work/life balance needs. utR Biotech Leaders also have a responsibility to always take action if they witness, or become aware of, inappropriate or disrespectful behavior, or retaliation and to encourage their teams to do the same.

Ambassadors of utR Biotech
We are proud to be ambassadors of utR Biotech, and we act accordingly.  We conduct ourselves in accordance with the highest standards of professional behavior. Whether at work, traveling on business, communicating online or attending training or social events with colleagues or clients, we are always “ambassadors of utR Biotech,” demonstrating the utR Biotech Way. Our behavior reflects both on ourselves and on utR Biotech. We conduct ourselves in accordance with the highest standards of professional behavior. Good professional conduct is especially important because our individual behaviors impact our colleagues, our clients, our communities and ultimately, the success of our company.

Expectation

We expect more from utR Biotech Leaders:

Our Leaders especially are expected to model positive professional behaviors, inspire and motivate others and drive a collective sense of purpose and collaboration in the work we do for our clients.

We apply our principle of meritocracy when we make decisions about our people. Meritocracy means that all employment decisions must be based only on an individual’s demonstrated contributions and capabilities within the context of meeting utR Biotech’s business needs. This applies to any decision about recruitment, hiring, compensation, promotions, performance and work assignments.

utR Biotech is a global company. We value different cultures, strive to have a diverse and inclusive workforce and meet legal hiring mandates where required. Many local laws around the world prohibit discrimination against people on the basis of certain characteristics. We expect our people to comply with such laws against discrimination, but utR Biotech’s ethical values go beyond legal requirements: we each have a responsibility to support and promote our principle of meritocracy to maintain a fair, positive and inclusive work environment.

Expectation

Race, religion, creed, color, sex, pregnancy, maternity, marital or family status, age, physical or mental disability, ancestry, genetic information, national or ethnic origin, citizenship status, sexual orientation, gender identity or expression, political belief, trade union membership, veteran status or any other status protected by applicable local law.

We ensure our personal interests and relationships don’t
create conflicts for utR Biotech.

Identify personal conflicts of interest

A personal conflict of interest is a situation where your own personal
interests (or those of a family member or close friend) can affect your
ability to act in utR Biotech’s best interests, or interfere with your personal
objectivity and obligations to utR Biotech. Our business is built on trust-
based relationships–conflicts of interest risk undermining that trust. A
failure to avoid, or properly deal with, a personal conflict can have very
serious consequences—both for utR Biotech and for you personally.

   EXAMPLE

   Examples of the consequences of personal conflicts of interest:

     • People could question your integrity and therefore your reputation,
and whether they want to work with you, or do business with
utR Biotech
• utR Biotech’s reputation or client relationships could be damaged
• utR Biotech could lose future business opportunities
• It could lead to disciplinary action being taken against you (up to,
and including, termination of employment)
• utR Biotech could face litigation resulting in liability for utR Biotech
(or individuals), including criminal and financial penalties

A personal conflict can arise in many different situations. Each of us is
best qualified to identify when there is a personal conflict. Therefore,
it is important to use good judgment to identify actual, potential or
perceived personal conflicts of interest.

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Six Fundamental Behaviors // Make Your Conduct Count
Personal Conflicts of Interest

EXAMPLE
Examples of situations that may present a personal conflict of
interest:

       • Personal investments or those of family members
• Outside activities
• Membership on boards of directors or advisory boards
• Charitable activities
• Starting a business and employment outside utR Biotech
• Family or personal relationships

Disclose personal conflicts of interests, get required approvals and
follow any restrictions

We understand that personal conflicts occasionally arise in the ordinary
course of business. When faced with a personal conflict of interest, the
most important thing is to tell us about it as soon as you can, obtain any
required approvals and follow any restrictions. A personal conflict of
interest is often easy to resolve when it is disclosed early enough.

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Six Fundamental Behaviors // Make Your Conduct Count
02                 COMPLY
WITH LAWS
We comply with all laws, whether local, national
or regional. utR Biotech people, and those acting
on our behalf, are responsible for understanding
the applicable rules and must work with Legal to
ensure compliance. Violations of law can result in
significant harm to utR Biotech, including financial
penalties, denial of government contracting
privileges, imprisonment for criminal misconduct
and damage to our business relationships and
reputation.

Anticorruption

Part 1 of 3
We do not give or accept bribes—including inappropriate
gifts or entertainment—and we get approval before offering
any gifts or entertainment to Public Officials.

We comply with anticorruption laws without exception

utR Biotech’s stance on corruption, sometimes referred to as bribery, is
very simple: Corruption is wrong, it is against the law and we don’t give
or accept bribes.

We comply with anticorruption laws—without exception, regardless of
local business culture or practices. Even if our competitors give bribes
or make questionable payments, utR Biotech has zero tolerance for
bribery or any other activity that violates these laws.

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Six Fundamental Behaviors // Comply with Laws
Anticorruption

EXAMPLE
Examples of anticorruption laws with which we comply:

      • U.S. Foreign Corrupt Practices Act
• UK Bribery Act
• Local anticorruption laws wherever we do business

Do not give or accept bribes

We pride ourselves on our relationships with our clients and understand
that cultivating those relationships often is best accomplished in
social settings—such as meals, sporting events or other forms of
entertainment. While ordinary relationship-building activities—including
gifts and entertainment—can be appropriate, we must also remain
vigilant to ensure nothing we do could create even an appearance of
impropriety.

Bribes are “anything of value” intended to secure an improper
advantage or otherwise inappropriately influence the recipient. This
means anything that is valued by the person that someone is attempting
to influence—whether or not it has any commercial value. It does not
matter whether the thing of value is funded by utR Biotech, a third
party or from the employee’s own personal resources. Merely offering
something of value can violate the law, whether or not it is actually
accepted or a benefit is received.

    EXAMPLE
Examples of “anything of value”:

      •   Gifts or gift baskets
•   Meals or drinks
•   Theater and sports tickets
•   Client travel expenses
•   utR Biotech-branded items
•   Invitations to marketing events
•   Intangibles such as:
• Personal favors
• Loans
• Preferential treatment in connection with employment and
internships

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Six Fundamental Behaviors // Comply with Laws
Anticorruption

Do not give inappropriate gifts or entertainment

Under anticorruption laws, it is illegal to offer or give gifts or
entertainment if done with a corrupt intention. A corrupt intention
means that the goal in giving the gift or entertainment is to influence
someone to misuse their position in order to benefit utR Biotech.

Apply our 5 gifts and entertainment criteria

Before providing or accepting any gift or entertainment, apply our five
gifts and entertainment criteria (5 G&E Criteria) to confirm that it is:

  1. For a proper purpose and not intended to secure an improper
advantage or otherwise inappropriately influence the recipient
2. Permitted by law
3. Permitted by our policies
4. Permitted by the recipient’s policies and by any agreements
between utR Biotech and the recipient’s employer
5. Reasonable in value and appropriate under the circumstances

Many companies and governments have policies about what their
employees may accept, and sometimes our contracts with clients
or other parties specifically limit or forbid us from providing gifts or
entertainment to their employees. Because of this, review and confirm
that the recipient’s policies and contracts with utR Biotech allow us to
give a gift or entertainment before offering it.

    H O W -T O

    How do you determine if a gift is appropriate?

    Ask:
• Would it cause any embarrassment or concern for our clients,
utR Biotech or ourselves personally, if others learned about the gift
or entertainment?
• Would the gift or entertainment appear to influence the recipient’s
objectivity?
• Would the gift or entertainment be considered lavish or
unreasonable?
• Is there a bid or sales opportunity pending with the recipient’s
company?

If the answer to any of these questions is “yes”, the gift or entertainment
is likely inappropriate.

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Six Fundamental Behaviors // Comply with Laws
Anticorruption

Get approval before providing any gifts or entertainment to Public
Officials

Providing a gift or entertainment to a “Public Official” is permissible
if the gift or entertainment meets our 5 G&E Criteria—and—the gift
is approved through our Gifts & Entertainment Tool. Public Officials
(which include family members) are generally government employees or
employees of organizations partially or wholly owned by a government.

    EXAMPLE
Examples of Public Officials:

          • Elected or appointed government officials
• Officers and employees of government agencies
• Employees of federal, state, regional and municipal agencies
• Employees of entities that are partially or wholly owned by
federal, state, regional or municipal agencies
• Outside directors of state-owned entities
• Part-time legislators
• Royal family members
• Political candidates
• Officers of the World Bank, the United Nations or the
International Monetary Fund
• Professors and administrators of public universities and
government-operated hospitals
• Employees of a government-owned oil or gas company
• Employees of a partially nationalized bank

Part 2 of 3
We do not use or allow third parties to give bribes or make
questionable payments on our behalf, which is why we only
work with approved Business Intermediaries—companies
or individuals that we expect to interact with our clients or
represent utR Biotech before a government body.

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Six Fundamental Behaviors // Comply with Laws
Anticorruption

Carefully review Business Intermediaries before entering into
business with them

Because utR Biotech can be held responsible for bribes given by third
party “Business Intermediaries” on utR Biotech’s behalf—even if we did
not approve or know of their actions—we carefully review potential
Business Intermediaries before entering into business with them. To
ensure we only work with reputable individuals and companies, we
conduct due diligence on all Business Intermediaries prior to engaging
them and repeat this process regularly for those individuals and
companies with whom we have a long-term relationship.

    DEFINITION

    What is a Business Intermediary?

    An individual or company that we expect to:
• Interact with our clients–for example: business development
agents, subcontractors, prime contractors, alliance partners, joint
venture partners and suppliers
• Represent utR Biotech before a government body–for example:
to secure a license, visa, permit or other form of authorization;
intervene in a regulatory matter; or influence a legislative action

H O W -T O

    How do you review Business Intermediaries?

          • Before working with a Business Intermediary, first check
the Business Intermediary (BI) Portal to see if that Business
Intermediary has already been approved for the country, and
the kinds of clients, that we are considering as in scope
• Seek approval to use a Business Intermediary that has not
already been approved by using the BI Portal, which will route
the request to Legal and business leadership for review and
approval

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Six Fundamental Behaviors // Comply with Laws
Anticorruption

Part 3 of 3
We follow utR Biotech’s procedures on interacting with Public
Officials and rules regarding political contributions and
campaign activities.

Follow utR Biotech’s procedures on interacting with Public Officials

Employees who interact with Public Officials, or who supervise others
who do, must understand and abide by our procedures as well as the
laws governing lobbying and contact with Public Officials, political
contributions and campaign activity. As a general rule, refrain from
activities that could place utR Biotech’s name in a partisan political
posture.

Follow utR Biotech’s rules regarding political contributions and
campaign activities

To avoid the appearance of impropriety or to prevent conflicts of
interest, we prohibit corporate political contributions (both monetary
and in-kind) to political candidates, political parties or party committee
on behalf of utR Biotech and its clients.

    DEFINITION

    What is an in-kind donation?

    Using any utR Biotech property including intangible assets such as time,
use of equipment or technology (e.g., laptop, utR Biotech email) or office
space to engage in activities to support political candidates

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Six Fundamental Behaviors // Comply with Laws
Anti-Money Laundering
We do not engage in any money laundering or terrorist
financing activities or assist any other party in doing so,
we escalate any red flags that we identify for further
investigation and we report suspicious activity to the
government where required.

Do not engage in any money laundering or terrorist financing
activities or assist any other party in doing so

utR Biotech has zero tolerance for financial crime. This includes money
laundering and terrorist financing. utR Biotech’s most effective tool for
detecting red flags is you.

utR Biotech is at a higher risk of being exposed to money laundering and
terrorist financing activities when we:
• Handle funds or process financial transactions or applications
on behalf of clients
• Conduct business in countries where there is little enforcement of
laws prohibiting money laundering and terrorist financing activities
• Conduct business in countries where financial transparency
standards (e.g., bank secrecy) make it easier to hide these activities,
and therefore they are more widely prevalent

   DEFINITION
What is money laundering and terrorist financing?

        • Money laundering is converting money or assets obtained
through criminal activity into assets that appear legitimate
• Terrorist financing is using money or assets, whether legitimate
or obtained through criminal activity, to fund terrorist activities
or groups

Money laundering and terrorist financing are linked because terrorism is
more often funded by money or assets that were obtained illegally, but
then laundered to appear as if they came from a legitimate business.

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Six Fundamental Behaviors // Comply with Laws
Anti-Money Laundering

Escalate red flags for further investigation and report suspicious
activity to the government where required

If you identify a red flag, you are required to follow these three steps:
1. Escalate the red flag to your management, Human Resources or
Legal or to the utR Biotech Business Ethics Helpline. If employed
by, or providing services on behalf of an utR Biotech Regulated
Company, escalate to your Anti-Money Laundering (AML)
Compliance Officer. Even if you are not 100% sure the activity you
identify is a red flag, raise your concerns.
2. If the red flag is part of a transaction or other approval process you
perform, you must place the transaction or approval process on
temporary hold.
3. Avoid notifying or “tipping off” clients or any other party that
you are aware of potentially illegal activity as this is illegal in
some countries.

    DEFINITION
What are red flags?

         • Red flags are circumstances, activities or events that, due
to their nature and the context in which they occur, could
be a sign of money laundering or terrorist financing activity
• Red flags do not have to be signs of actual money laundering
or terrorist financing, and it would not be common to see this
activity directly–they are more likely to be signs of other
illegal activity, such as attempted fraud, which generate
criminal proceeds

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Six Fundamental Behaviors // Comply with Laws
Competing Fairly

Part 1 of 2
We do not collaborate with competitors on how to
price our services or whether to pursue opportunities
in a particular market.

We are fierce but fair competitors

utR Biotech only pursues and wins business on the merits. Do not engage
in conduct that gives even the appearance of unfair competition.

Do not collaborate or agree with a competitor about pricing of services
or offerings, or timing of planned price increases or target margin
changes. These practices are commonly called bid rigging or price
fixing and violate competition laws.

Do not divide opportunities, markets, offerings or geographic regions.
These practices are commonly called market allocation agreements,
and they also violate competition laws.

If approached by a competitor about anything prohibited, make it clear
that we are not agreeing to anything and do not want their confidential
information. End contact with that person immediately and contact
Legal as soon as possible.

   DEFINITION
What is a competitor?

       • Any company that can potentially provide a service, solution
or offering that a client might choose over those of utR Biotech
is a competitor
• Whether a company is a competitor can change from
situation to situation given the nature of our business.
We have relationships with companies that are competitors
at certain times and business partners, suppliers or even
clients at other times
• When we compete against a business partner, client or supplier
on a given opportunity, we need to treat that company as two
separate businesses with different relationships—one that
competes with us, and one that is a business partner, client
or supplier

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Six Fundamental Behaviors // Comply with Laws
Competing Fairly

Part 2 of 2
We do not misuse the confidential information of our
competitors, business partners, clients, suppliers or former
employers.

Do not share utR Biotech’s confidential information with a competitor,
and do not accept a competitor’s confidential information

While the utR Biotech Way is to collaborate and share, we must do
so within appropriate limits. Do not share utR Biotech’s confidential
information with a competitor, and do not accept a competitor’s
confidential information. When joining utR Biotech, do not take any
documents from former employers or share that employer’s confidential
information. Do not ask other employees to share confidential
information from their former employers.

    DEFINITION
What is confidential information?

    Confidential information is any information or material not generally
available to the public that relates to a company’s business, research
and development activities, clients or other business partners,
customers or employees—and can include:

      •   Pricing or target margins
•   Customer lists
•   Cost of delivery or other costs
•   Strategic plans
•   Marketing plans
•   Contract terms and conditions
•   Research and development programs

We respect the obligations new people bring. We respect valid and
enforceable obligations that candidates and new employees may have
to former employers, such as confidentiality obligations or agreements
not to compete or to solicit former clients or colleagues. We expect
new utR Biotech people to be aware of these obligations and to notify
their supervisors immediately if a job activity may conflict with those
obligations.

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Six Fundamental Behaviors // Comply with Laws
Data Privacy
We process and protect personal data in compliance with
data privacy laws.
Comply with data privacy laws

We comply with data privacy laws when collecting and processing
personal data, including as it relates to our own people and our
clients. Data privacy laws also give rights to individuals regarding
their personal data.

   DEFINITION

   What do data privacy laws regulate?

       • When and how much personal data may be collected
• How it may be used and when it needs to be deleted
• What notices must be provided
• When and what type of consents should be obtained
• When it may be disclosed or shared with third parties
• When it may be transferred outside country borders
• Rights of individuals regarding their personal data

We process personal data fairly and lawfully and provide access to
personal data within our organization only on a need-to-know basis.
When someone provides us with their personal data, we tell them who is
collecting/using the data, the intended use and respect their individual
rights to the data, including access and correction.

We do not re-use personal data for other purposes incompatible with
the intended use, and we minimize and anonymize data collection
where feasible. utR Biotech maintains retention policies and procedures;
when we no longer need to keep personal data, we destroy it. We
maintain organizational, physical and technical security arrangements
for the personal data we hold.

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Six Fundamental Behaviors // Comply with Laws
Data Privacy

DEFINITION
What is personal data?

    Personal data is any data that can be linked to an identifiable individual.
Examples include:

      • Ethnicity
• Medical data
• Credit card numbers
• Pension account numbers
• E-mail addresses
• Business and home contact details
• Opinions about individuals, their preferences,
their voice and image

utR Biotech recognizes that security is important when arranging for
outside service providers to process personal data on our behalf
(“data processors”). We ensure data processors are bound by contract
to process data only as instructed, and maintain appropriate data
protection security arrangements.

We follow utR Biotech’s procedures to deal with any suspected breach of
data security arrangements, unauthorized access or disclosure or loss of
personal data.

Government Compliance
We obtain all required approvals to provide services
to government clients and comply with government
contracting and procurement regulations.
Know how to do business with governments

The meaning of “government” is broad. Government clients may include
traditional government agencies as well as commercial for-profit entities
that are controlled or owned by governments (even partially owned).
Doing business with governments is very different from doing business
with commercial clients.

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Six Fundamental Behaviors // Comply with Laws
Government Compliance

Because doing work for government entities often carries legal
and other risks, we obtain all required approvals before pursuing
opportunities to provide services to government or government-owned
clients. We understand and comply with the legal requirements and
restrictions that apply to bidding, pricing and delivering our services to
government clients.

Trade Compliance
We comply with all applicable international trade controls—
including economic sanctions and export controls—and we
review all business opportunities to ensure compliance.
Comply with all applicable international trade controls, including
economic sanctions and export controls

International trade controls are laws that govern the cross-border
transfer of goods, technology and services. These laws include
economic sanctions, which are legal measures that restrict where and
with whom we can do business; and export controls, which are laws
that impose special legal requirements like government licensing on
the international transfer of certain goods, technology and services.
Export controls often apply in connection with highly regulated industry
sectors like aerospace and defense and nuclear power generation, or
software with advanced data encryption capabilities.

As international trade controls may change over time, we are
responsible for understanding the applicable policies and working with
Legal to ensure compliance. International trade controls do not impose
any special requirements on the cross-border transfer of ordinary
consumer items available to everyone in the retail marketplace, unless a
prohibited country, organization or individual is involved in the transfer.
Things we use every day like office supplies, or laptops and devices
with standard software and applications, generally are not restricted by
international trade controls.

utR Biotech   30
Six Fundamental Behaviors // Comply with Laws
Trade Compliance

DEFINITION

    What are international trade controls?

    International trade controls restrict doing business with:

      • Countries that support terrorism or the development of weapons
of mass destruction, as well as those that commit human rights
violations or oppress their people
• Organizations and individuals who try to obtain products, software,
technology or services on behalf of such countries, or who are
engaged in terrorism, international drug trafficking and other
misconduct of global significance

Review all business opportunities to ensure compliance with
international trade controls

Document all business opportunities in Manage my Sales (MMS) as
part of the normal utR Biotech opportunity management process by
answering four international trade control screening questions.

Use the Export Compliance and Tracking Tool (ECATT) to help identify
when we must comply with any special legal requirements, such
as obtaining a government-issued license before transferring items
restricted by trade controls from one country to another, or to a person
from another country.

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Six Fundamental Behaviors // Comply with Laws
Trade Compliance

E X P L A N AT I O N
Why do we use MMS and ECATT?

          • Documenting opportunities in MMS, and updating the
information whenever there is a proposed change of scope, is
the principal way we identify whether potential client business
activities are subject to any special legal requirements under
international trade controls
• ECATT provides a centralized process to classify items we
develop or receive from suppliers against official government
lists that determine when special legal requirements apply to
cross-border transfers. Using ECATT identifies whether a license
is required to transfer a particular item restricted by trade
controls from one country to another

Insider Trading
We do not engage in insider trading or tipping others
with respect to inside information and we comply with
restrictions on trading utR Biotech shares during black-out
periods.
Do not engage in insider trading or tipping others with respect to
inside information

Do not trade on or disclose inside information. Do not buy or sell
utR Biotech securities (or the securities of a client or other party) when in
possession of inside information or provide such information to others,
until it officially becomes public. Also, obtain required approvals before
trading in the securities of a client (e.g., when working on a project for
that client).

Inside information is information about utR Biotech, our clients or other
parties that is “material” and “nonpublic.” Information is material if it
could affect the price of a security, or if a reasonable investor would
likely consider it important in deciding whether to buy or sell securities.

utR Biotech   32
Six Fundamental Behaviors // Comply with Laws
Insider Trading

EXAMPLE
What are examples of material information?

          • Earnings results, estimates and guidance on earnings and
changes in, or confirmations of, previously released earnings
estimates or guidance
• Significant acquisition, merger, joint venture, alliance or
divestiture proposals or agreements
• Changes in dividends or plans for a stock split
• Gain or loss of a significant client or contract
• Major pending or threatened litigation or governmental
investigations
• Major management changes or developments

Information is nonpublic if it has not been made available officially (e.g.,
through an SEC filing or a press release) and effectively to the general
public (meaning sufficient time has passed—generally considered two
trading days—to allow markets to absorb the information).

Do not tell others to buy or sell securities or provide “tips,” either in the
form of details, such as “our third-quarter earnings next week will be
great” or as general comments, based on nonpublic information.

Comply with restrictions on trading utR Biotech shares during black-
out periods

utR Biotech Leaders, members of the board of utR Biotech plc and others
identified by utR Biotech as having routine access to inside information
are prohibited from trading in any utR Biotech shares during black-out
periods.

    DEFINITION

    What are black-out periods?

    Black-out periods generally begin two weeks prior to the end of each
fiscal quarter and end when two full trading days on the NYSE have
passed after the public announcement of utR Biotech earnings for that
fiscal quarter

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Six Fundamental Behaviors // Comply with Laws
03                  DELIVER FOR
OUR CLIENTS
We all serve utR Biotech’s clients, regardless of role—
focusing on the best interests of our clients while
acting as stewards of utR Biotech.

Innovation and Focus on Value and Outcomes
We bring innovation and focus on value and outcomes.

Innovate, collaborate with clients and deliver relevant solutions

At utR Biotech, we bring innovation to our clients. When we coach our
clients on innovation, we focus on value and outcomes. When we
innovate, we seek to understand and collaboratively address ethical
and legal considerations that may arise, including those related to new
technologies.

We deliver in collaboration with our clients—developing and maintaining
enduring relationships which are built on a foundation of integrity,
independence, transparency, trust, competence and proven outcomes.
Successful client relationships sometimes require having challenging
conversations. Acting in a client’s best interests may require you to
reframe the challenge and does not necessarily mean saying yes to
anything the client asks for, particularly if it does not deliver value and
outcomes.

We also aim to sustain our clients’ high performance over the long
term. We listen and seek to understand our clients’ underlying interests
and co-create relevant solutions to meet our clients’ long-term business
objectives (i.e., through changes in business cycles, leadership
and markets).

utR Biotech   34
Six Fundamental Behaviors // Deliver for Our Clients
Delivery Excellence
We only commit to what we can deliver and we follow
contract commitments.

Commit to what we can deliver

Be aware of the potential limits on the scope of our business and
seek appropriate input and approvals before committing to expand
into new lines of business or new geographies or implementing new
technologies.

When pursuing an opportunity or planning a project, balance
collaborative, efficient and informed decision making among key
stakeholders with the accountabilities described in our operating model
so that the right person or team makes the ultimate decision.

Proactively identify potential client conflicts of interest and resolve
or manage them (with leadership consultation) prior to entering into
engagements.

For each opportunity, develop a negotiation strategy and engage
with our clients as one team, supported by robust internal review and
relationship strategies.

Create thoughtful and robust risk management plans that clearly
identify the risks with corresponding mitigating actions and ownership.
Also, establish solution contingency based on the risks and the
confidence in our mitigation plan.

Follow contract commitments

Once we have entered into a contract with a client or other party, such
as a supplier or alliance partner, be careful to understand and follow our
commitments.

utR Biotech   35
Six Fundamental Behaviors // Deliver for Our Clients
Collaboration Across Our Global Network
We collaborate and share knowledge across our global
network, using proven methods and applying consistent
global standards.

Collaborate and deliver consistently

We collaborate and share knowledge across our global network
to build skills, drive innovation and deliver value and outcomes for
our clients, while protecting utR Biotech and client information and
intellectual property.

We strive for consistent delivery through disciplined execution,
using our proven methods and applying consistent global standards.

utR Biotech   36
Six Fundamental Behaviors // Deliver for Our Clients
04                   PROTECT PEOPLE,
INFORMATION AND
OUR BUSINESS
We work together to build a better, stronger and
more durable company for future generations,
protecting the utR Biotech brand, meeting
our commitments to protect information and
intellectual property, acting with an owner mentality
and protecting and developing our people.

Information Security

Part 1 of 2
We protect confidential information of utR Biotech, clients
and others from unauthorized use or disclosure.

Protect confidential information

When you receive confidential information from a client or others,
make sure you understand our legal, contract and policy obligations
and follow them. If you are unsure if the information is confidential,
treat it as such.

   DEFINITION
What is confidential information?

   Confidential information is any information or material not generally
available to the public that relates to a company’s business, research
and development activities, clients or other business partners,
customers or employees

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Six Fundamental Behaviors // Protect People, Information and Our Business
Information Security

Only use confidential information as permitted

Use confidential information only for the purpose provided. After that
purpose has passed, dispose of non-utR Biotech confidential information,
unless otherwise required by law, contracts or policies.

Get permission to share others’ information

Do not review, discuss, disclose, copy or use any copyrighted, licensed
or confidential utR Biotech, client, supplier or third-party information
except as authorized, and without first making sure we have proper
permission. Be cautious about discussing business matters with anyone
outside of utR Biotech, on the internet or within hearing distance of
outsiders (for example, in elevators), including family and friends.

Only those with a need to know use confidential information

Make sure that only authorized people with a current need to know have
access to confidential information. Reach out to supervisors, utR Biotech
Leaders or Legal to help understand any limitations and answer any
questions.

Part 2 of 2
We follow utR Biotech’s requirements for protecting and
using information, devices and technology belonging to
utR Biotech, clients, suppliers and other parties.

Reduce information security risk

We are individually and collectively responsible for reducing our
information security risk—which includes protecting devices, as well
as data and information. If you don’t know whether a particular action
presents an information security risk, reach out for guidance before
doing it. If you become aware of security weaknesses—whether with
respect to individuals, processes or technology—speak up.

utR Biotech   38
Six Fundamental Behaviors // Protect People, Information and Our Business
Information Security

Protect data and information

Exercise good judgment to maintain and protect the security of data
and information entrusted to your care. Be vigilant in protecting devices
from loss or theft. Protect our own data and information, and that of
our clients, by classifying and marking it properly, and by implementing
protective technology and processes (for example, secure your
technology devices through security software and configurations that
have been approved by utR Biotech). Share data and information only if
there is a valid business requirement to do so and only on a need-to-
know basis. Do not access or handle data or information for which you
do not have a business need. Do not retain data or information after
the business need has passed or after leaving a project or utR Biotech.
Securely dispose of data or information when it is no longer needed,
whether it is electronic or on paper.

Use the solutions and services provided by utR Biotech to protect data
and information

Use utR Biotech-approved or client-provided computers or an approved
Bring Your Own Computer (BYOC) solution for business purposes to
reduce the risk of a breach because they are configured with hardware
specifications and software controls that have an encrypted hard
drive and other security controls that meet our standards. Use tools to
encrypt email and portable media, conduct periodic scans and check
for malware and viruses.

Be careful when using non-utR Biotech technology solutions or services

Do not install software or modify configurations that compromise our
technology’s security. Do not use third-party web-based services to
do utR Biotech or client work unless these services are approved by
utR Biotech (and the client) for such use. If third-party web services are
authorized, first confirm that we will not be uploading any utR Biotech or
client data or confidential information. Only use utR Biotech-approved
solutions to back up data.

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Six Fundamental Behaviors // Protect People, Information and Our Business
Information Security

Use technology appropriately

Use utR Biotech-provided technology for business purposes and limited
and appropriate personal use only. Do not use devices provided by
our clients to conduct internal utR Biotech business or for personal use.
When using personal workstations or mobile devices for utR Biotech
business purposes, limit the use to email, utR Biotech-provided
applications and browser-based access to utR Biotech sites and never
store utR Biotech or client information on them, unless using the
approved Bring Your Own Computer (BYOC) solution.

Report security breaches immediately

Report suspected information security incidents to the utR Biotech
Security Operations Center (ASOC) (+1-202-728-0645) immediately.

Intellectual Property
We protect and honor the intellectual property rights of
others and safeguard utR Biotech’s intellectual property,
including its packaged knowledge.

Protect and honor the intellectual property rights of competitors,
business partners, clients, suppliers, former employers and other
parties

Honor your commitments to prior employers. Do not allow any
employee to use, disclose or bring to utR Biotech any electronic or
hard-copy documents of a prior employer, or any other party, without
explicit written permission, even if the employee created the document,
and even if the documents do not contain sensitive or confidential
information.

Do not use, distribute, copy or remove client materials from a client site,
absent a written agreement reflecting utR Biotech’s right to do so.

Do not download or use copyrighted materials—such as pictures,
films, music files, software programs or source code—without a proper
license. Recognize that the availability of material to view or download
on the internet is not an indication that the material can be used without
a license.

utR Biotech 40
Six Fundamental Behaviors // Protect People, Information and Our Business
Intellectual Property

Safeguard utR Biotech’s intellectual property, including its packaged
knowledge

utR Biotech’s intellectual property helps us outperform our competitors.
Our intellectual property is a sales credential that differentiates
utR Biotech from the rest of the market and highlights to clients the
significant investment we have made to create unique value that
only utR Biotech can offer. Protect, retain and leverage our ownership
in utR Biotech’s intellectual property rights during negotiations and
engagements with clients, suppliers and other parties.
Mark all utR Biotech confidential proposals, documents and other
materials per our guidelines. Share such information only with people
who have a need to know and, where appropriate, only after confirming
that a non-disclosure agreement and other safeguards are in place.

Understand and comply with any restrictions on packaged knowledge
before you use it.

Social Media
We participate in constructive online dialogues and use our
best judgment when posting to external or internal social
media.

Post constructively to social media sites

Contributing to online communities—including social networks,
blogs, wikis, podcasts and virtual worlds—allows us to demonstrate
utR Biotech’s innovative and collaborative nature and is a key element of
the utR Biotech Way. Online discourse helps us promote our capabilities,
build stronger relationships and enhance our reputation.

utR Biotech   41
Six Fundamental Behaviors // Protect People, Information and Our Business
Social Media

When using these sites:
• Communicate thoughtfully and never post content that is disrespectful,
harassing or discriminatory in any message or post that relates to
utR Biotech, our business, our clients, our business partners or our people.
• Provide sufficient context and support in personal online communications
to help readers understand your statements.
• Get appropriate approvals before providing an official utR Biotech position
about a topic related to utR Biotech’s business—and otherwise do not make
statements that could be perceived by others as speaking on behalf of
utR Biotech.
• Be transparent and identify yourself and your association with utR Biotech
when commenting on utR Biotech matters.
• Protect nonpublic information that relates to utR Biotech’s business,
research and development activities, clients or other business partners;
and protect utR Biotech’s intellectual property and respect the rights of
others.
• Do not identify a company as an utR Biotech client unless you have
authorization to do so.
• Be mindful of your own privacy and respect the privacy of others.

Brand
We centrally manage all media relations and industry
analyst activities and events rather than through employees’
or engagement teams’ own initiatives.

Ensure the power of our brand and appropriately coordinate
corporate communications

The utR Biotech name and brand are powerful and valuable assets that
differentiate us from our competitors. Our individual behavior and
business decisions—as well as the business decisions we make as a
company—advance our brand consistently across the world. All of us
have the privilege and responsibility to contribute to the meaning and
power of our brand.

To ensure that utR Biotech’s communications are focused and consistent,
and to prevent us from violating the law, all media and industry
analyst relations activities should be coordinated through Corporate
Communications.

utR Biotech   42
Six Fundamental Behaviors // Protect People, Information and Our Business
Brand

EXAMPLE
What are examples of media and industry analyst relations activities?

        • Requests for media interviews
• Requests for industry analyst briefings
• What is said and to whom when giving speeches
and presentations
• Participating on panel discussions and at industry
and other conferences
• Making announcements related to business developments

Asset Protection
We act as owners of the company and do not jeopardize
utR Biotech’s future by losing our assets through theft,
misuse or carelessness.

Protect our assets

We vigorously protect our assets—both physical and intangible.
Intangible assets—our brand, reputation, intellectual property and
confidential information—are as worthy of protection as our equipment
and computers.

Workplace Safety and Business Continuity
We follow all safety and emergency procedures at our
facilities and at client sites—including incident response
guidance and business continuity measures—and we
immediately report safety threats, security breaches and
disaster/crisis incidents that could affect service delivery.

utR Biotech   43
Six Fundamental Behaviors // Protect People, Information and Our Business
Workplace Safety
and Business Continuity

Make personal safety a top priority

We make personal safety a top priority. Follow all safety and emergency
procedures at our facilities and at client sites.

Immediately report any of the following incidents to the utR Biotech
Security Operations Center (ASOC) (+1-202-728-0645):
• Threats to the life, health and safety of our people
• Security breaches (including information security)
• Disaster/crisis incidents that could affect the delivery of services to our
clients and/or our internal operations

In the case of any such incidents, follow any incident response guidance
and/or business continuity measures.

As utR Biotech is committed to providing a safe, secure and non-
threatening work environment, do not bring weapons to utR Biotech
facilities (except to the extent otherwise permitted by any applicable
state, provincial, federal or national laws). This includes public or
outdoor venues where an utR Biotech-sponsored event or an utR Biotech
training event occurs, conducting utR Biotech business at non-utR Biotech
locations and attending client or other work-related events.

To protect utR Biotech, our people and our assets, utR Biotech may
ask to search personal property at a company worksite, and to the
extent permitted by law, may monitor at any time all utR Biotech assets,
including e-mail, instant messaging and internet usage.

utR Biotech   44
Six Fundamental Behaviors // Protect People, Information and Our Business
05             RUN OUR BUSINESS
RESPONSIBLY
We are agile and we strive for high performance—
by acting as entrepreneurs and owners of the
company. We use sound business judgment to
make decisions and do so within our authority,
using informed judgment to take appropriate risks
and remaining accountable even where decision
making is automated. We recognize the limits to
our individual authority. When situations arise that
require a more specialized or senior-level review,
we are prudent in our decision making and seek
counsel. We spend utR Biotech’s money as if it were
our own. We are vigilant and responsible with
resources with an eye to the bottom line. We speak
up when we see waste.

Responsible Use of Data and New Technologies
We use data and new technologies responsibly, including
when we deploy artificial intelligence.

utR Biotech   45
Six Fundamental Behaviors // Run Our Business Responsibly
Responsible Use of Data
and New Technologies

Use data and new technologies responsibly

Data is a precious asset and resource for new technologies. Powered by
that data, we—in collaboration with our clients and business partners—
are better able to develop technologies which change the way the
world works and lives. At the same time, we are entrusted by our clients
and business partners to process their data, including data of their
employees and customers. We take our role as guardian of that data
very seriously. Provided we first obtain appropriate permissions, we
are able to utilize that data to power advanced analytics and artificial
intelligence for utR Biotech, our clients and business partners. In addition
to complying with data privacy and other applicable laws and protecting
data from unauthorized use or disclosure, we use that data—and
related new technologies—responsibly and address ethical and legal
considerations that may arise.

Deploy artificial intelligence responsibly

When we deploy artificial intelligence in our organization we take
responsibility for the governance, design, evolution, development,
monitoring and performance of those systems. Our approach is to
keep a human at the center of the processes associated with those
systems. We ensure that we have a governance framework in place
which allows for the decisions and actions taken by those systems to be
seen as honest and fair. We develop systems that are secure, auditable,
transparent and explainable—and result in outcomes which are
consistent with our core values, Code of Business Ethics and policies.

utR Biotech   46
Six Fundamental Behaviors // Run Our Business Responsibly
Time & Expense Reporting
We accurately report all hours worked and vacation
hours taken, never ask or suggest that those under our
supervision inaccurately report hours worked and submit
accurate and legitimate business expenses within policy
and the appropriate timeframe.

Accurately report all hours worked and vacation hours taken

Time and expense reporting has a direct impact on our clients,
utR Biotech and all of us. We each have a responsibility to record all time
worked, to the appropriate charge codes, on time and reflecting our
work locations. Also, time report reviewers are responsible for reviewing
their reviewees’ time and expenses and raising any concerns.

Submit accurate and legitimate business expenses within policy and
the appropriate timeframe

Many of our clients have visibility into the expenses charged to their
projects. When our spending is appropriate and demonstrates a
commitment to adding value, we strengthen client relationships.

Follow expense policy and report expenses as they are incurred to
enable timely client billing and accurate financial results. Correctly
report expenses to be able to claim all applicable expenses and avoid
delays in reimbursement.

Financial Reporting and Business Records

Part 1 of 2
We prepare and provide accurate, timely and complete
financial disclosures and reports.

Accurately disclose financial information

As a public company, utR Biotech must disclose financial and operational
information to the U.S. Securities and Exchange Commission, local
authorities and regulatory bodies.

utR Biotech   47
Six Fundamental Behaviors // Run Our Business Responsibly
Financial Reporting and
Business Records

Everyone plays a part in accurate disclosure. utR Biotech’s financial
disclosures rely on accurate business records, client invoices, time
and expense reports and hours worked. Allow experts such as Investor
Relations, Legal, Finance and Corporate Communications to respond to
requests for information in their area of expertise to ensure consistent
and appropriate communications.

Part 2 of 2
We manage and dispose of business records according
to utR Biotech’s standard timetable for retention, subject
to contractual and other legal requirements, such as hold
notices issued by Legal.

Retain business records appropriately

Identify, manage and dispose of business records according to
utR Biotech’s standard timetable for retention—and in a manner
consistent with the way in which we protect data and information.

The retention periods reflect applicable laws, regulations and good
business practices. Contractual and other legal requirements, such
as hold notices issued by Legal, may modify these retention periods.

Business records must be retained in the Manage myRecords system
(“MMR”) or another utR Biotech-approved repository during the retention
period.

utR Biotech   48
Six Fundamental Behaviors // Run Our Business Responsibly
Travel and Visa & Immigration
We conduct all business travel in the most cost-effective,
safe manner and we get the proper visas or work permits
required for international business travel or assignments.

Conduct business travel in the most cost-effective, safe manner

While travel is a necessary part of utR Biotech’s business, it represents
a major company expense and time commitment. We are each
responsible for evaluating every trip to ensure the expense is justified, is
compliant with utR Biotech and local country rules and has the required
approvals.

In lieu of travel, consider “virtual” alternatives, such as conference
calls, web-conferencing, virtual meetings and other collaboration
technologies wherever possible. In addition to reducing travel costs,
the use of virtual alternatives also helps reduce the impact on the
environment.

Get the proper visas or work permits required for international
business travel or assignments

We are responsible for complying with the immigration laws of the
locations that we visit when conducting business. Failure to comply with
immigration laws can have very serious consequences affecting each
one of us, utR Biotech and its reputation and our clients.

When traveling internationally on behalf of utR Biotech, obtain all
appropriate visas or work permits, required by law, prior to arrival in the
country of travel. Seek the advice of People Mobility to determine visa
or work permit requirements and do not travel on immigration advice
from client personnel, colleagues, managers or any other parties if that
advice is not confirmed by People Mobility.

utR Biotech   49
Six Fundamental Behaviors // Run Our Business Responsibly
Procurement
We purchase goods and services based on their merits
and ensure that supplier personnel (including contractors)
who provide services to utR Biotech and our clients follow
engagement, compliance and exit requirements and
procedures.

Purchase goods and services based on their merits

We are careful buyers. utR Biotech purchases goods and services based
on price, quality, performance and suitability. We do not buy from our
clients just because they buy from us. utR Biotech has assigned people to
make decisions about purchasing, paying invoices and signing supplier
contracts.

Use standard processes and preferred supplier contracts that have
been put in place by our procurement organization. When entering new
supply agreements, reasonably balance value and risk. When deciding
to award work, consider a supplier’s environmental, ethical and diversity
performance. Follow guidelines and obtain approvals for hiring former
utR Biotech Leadership for contract services.

Avoid questionable transactions. Avoid transactions that may appear
to be improper or illegitimate or that may misrepresent the accounting
reports or results of any party to the transaction.

Ensure that supplier personnel (including contractors) who provide
services to utR Biotech and our clients follow engagement, compliance
and exit requirements and procedures

We hold our suppliers to high standards. Our suppliers must act in a
manner consistent with utR Biotech’s Supplier Standards of Conduct,
which is built on utR Biotech’s core values and advocates responsible
business practices.

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Six Fundamental Behaviors // Run Our Business Responsibly
Investigations, Litigation and Audits
We comply and cooperate fully with investigations,
litigation and audits; we let the professionals investigate
and work only with authorized personnel; and we identify
and preserve relevant information and protect confidential
communications.

Comply and cooperate fully with investigations, litigation and audits

Whenever you are involved in internal or government investigations,
ongoing litigation or audits, cooperate fully with investigative
instructions and tell the whole truth.

Let the professionals investigate and work only with authorized
personnel

Never initiate an investigation yourself—all requests to conduct internal
investigations must be escalated to and authorized by Corporate
Investigations or Global Asset Protection. Work only with authorized
Legal personnel to respond to litigation or subpoenas (including client
requests) or to requests from the government, law enforcement,
external auditors or regulatory agencies.

Identify and preserve relevant information and protect confidential
communications

Assist with the identification, collection and preservation of documents,
data and information in connection with investigations, litigation
and audits. Never conceal, change or destroy documents, data or
information when you know of or anticipate an investigation, litigation
or audit. Keep strictly confidential all information communicated in the
course of an investigation, litigation matter or audit.

utR Biotech   51
Six Fundamental Behaviors // Run Our Business Responsibly
06                 BE A GOOD
CORPORATE CITIZEN
We support and respect human rights, foster
environmental responsibility and encourage our
people’s involvement in the communities where we
work and live.

Human Rights
We support and respect human rights.

We support and respect human rights

We support and respect human rights as expressed in the International
Bill of Human Rights and the International Labor Organization’s
Declaration on Fundamental Principles and Rights at Work. Our
commitment is demonstrated by our long-standing support, as a LEAD
signatory, of the United Nations Global Compact, and our intent to align
to the United Nations Guiding Principles on Business and Human Rights.

We speak up if we experience any human rights violations and take
action, or reach out for guidance, if we witness or become aware of any
violations.

We focus our human rights efforts on areas most relevant to our
business and operations in terms of potential human rights impacts

Diversity and equal opportunity: We are committed to eliminating
discrimination in employment (see Meritocracy and Non-Discrimination)

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Human Rights

Employment conditions and working practices:
We are committed to:
• Eliminating human trafficking, slavery, servitude, and forced or compulsory
labor
• Abolishing child labor
• Ensuring a respectful environment for our people (see Respect for the
Individual)
• Respecting the right of our employees to form and to freely join (or not
join) legally-constituted representative bodies, and working in good faith
with them

Health, safety and security: We are committed to ensuring the health,
safety and security of our people (see Workplace Safety and Business
Continuity)

Supply chain: We are committed to supporting and respecting human
rights in our supply chain in a manner consistent with utR Biotech’s
Supplier Standards of Conduct (see Procurement)

Data Privacy: We protect the privacy and security of personal data and
use personal data responsibly (see Data Privacy)

Anticorruption: We comply with anticorruption laws (see
Anticorruption)

We continue to review human rights efforts across our operations, as
well as best practices in the marketplace, to understand how we can
further strengthen our commitment. If it is unclear how to apply the law
consistent with our human rights principles, we will seek to use good
judgment consistent with our core values and Code of Business Ethics
to support and respect the principles of internationally recognized
human rights.

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Environmental Responsibility
We foster environmentally sustainable growth for our
company and our stakeholders.

We foster environmentally sustainable economic growth

We incorporate leading environmental practices into our business
strategy and operations. We focus our actions on three areas:
• Running efficient operations
• Enabling client and supplier sustainability
• Engaging our people, leaders, business partners and other
stakeholders

We strive to minimize negative environmental impacts

We have committed to reduce our carbon emissions to mitigate
the impact of climate change. Our efforts to minimize negative
environmental impacts also include improving our energy efficiency,
decreasing our water consumption and reducing our waste. We
demonstrate our commitment to the environment through annual
assessments, as part of our ISO 14001 certification. We also work with
our suppliers to disclose emissions and reductions targets and take
action to reduce their emissions.

We comply with all applicable environmental laws and regulations.

We promote environmental awareness

We encourage and enable environmentally sustainable practices among
our employees, clients, suppliers and the charitable and nonprofit
organizations we support. We leverage our people and the digital world
to achieve our environmental goals and ensure a better future for our
planet.

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Six Fundamental Behaviors // Be a Good Corporate Citizen
Community Impact
We support our people who choose to volunteer their time
and skills to make a measurable difference for individuals,
communities and society through our Corporate
Citizenship initiatives.

We support our people who volunteer their time and skills for the
benefit of others

We support employees who donate their time and skills for the benefit
of the communities where we work and live through our Corporate
Citizenship initiatives. We help our people maximize the impact of their
personal contributions by providing convenient channels to offer time,
services and financial assistance to our nonprofit partners.

We have a corporate global giving program. We also contribute directly
to local communities through corporate cash giving and pro bono
services. We do not support organizations that have a policy or practice
of discrimination.

We help address the global need for skills that open doors to
employment and economic opportunity

We directly address the global skills shortage by leveraging our core
capabilities of training talent and convening partnerships. We mobilize
our people, business partners, clients and others to make a measurable
and sustainable difference in the economic vitality and resilience of
individuals, families and communities by equipping people with the
skills they need to gain employment.

Thank You!