Introductory Notes

The code of conduct applies to all employees of Avelo and parties who work on behalf of Avelo. It sets requirements for business conduct and serves as a foundation for our company policies, procedures, and guidelines, all of which provide additional guidance on expected behaviors. It shall serve as a guide in a world that is increasingly complex to navigate through and to take the right decisions.
We hold ourselves and how we do business to a high standard. Therefore, we make this code transparent to all our stakeholders, internal and external ones alike, to be held accountable for our actions. When faced with a difficult decision about business conduct, ask yourself the following questions:

• Is the conduct a violation of Avelo’s Code of Conduct, company policies or the law?

• Will the conduct appear unethical to stakeholders inside or outside of our company?

• Is the conduct in conflict with our values?

• Could the conduct harm my or Avelo’s reputation?

If the answer to any of these questions is “yes”, ask Human Resources (HR) or our Senior Management for help.

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General Principles

All employees should be treated with respect and courtesy. In addition, all employees are expected to behave in a professional manner, exhibiting understanding and respect at all times.

Responsibilities of Employees and Supervisors
All employees and those who work on our behalf have a responsibility to:

• Comply with this code of conduct.

• Pay attention to their own and their colleagues’ behaviors and address inappropriate behavior, speak up if harassment is observed

• Offer support to anyone who is being harassed and let them know where they can get help and advice (they should not, however, approach the harasser themselves).

• Maintain complete confidentiality if they provide information during the investigation of a complaint. Employees should be warned that spreading gossip or rumors may expose them to a defamation action and is also considered harassment.

• Avoid retaliating against another person for raising an integrity concern

 

Supervisors have a responsibility to:

• Ensure that all employees understand and act according to this code of conduct.

• Model appropriate behavior, promote these standards within their team(s) and create a team environment where concerns can be raised and issues can be discussed.

• Treat all complaints seriously and take immediate action to investigate and resolve the matter.

• Refer a complaint to another supervisor or HR if they do not feel that they are the best person to deal with the case (for example, if there is a conflict of interest or if the complaint is particularly complex or serious).

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What to Do in Case of Violation
If employees experience or observe a violation of this Code of Conduct, they should immediately report the matter to their supervisor. If that person is not available, or if they feel it would be unproductive to inform that person, they should immediately contact HR. Once the matter has been reported, it will be promptly investigated, and any necessary corrective action will be taken where appropriate. All such complaints will be handled in a discreet and confidential manner to the extent possible given the circumstances. 

In addition, Avelo will not tolerate reprisals against employees who have raised a complaint or who have given information in connection with such a complaint. Nevertheless, the company will also not tolerate accusations that are unfounded and without basis.

The procedure for reporting violations is not intended to impair, replace, or limit the rights of any employee to seek a remedy under available laws by immediately reporting the matter to the appropriate authorities, agencies, or institutions.

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Consequences
Any employee engaging in improper behavior will be subject to disciplinary action, including the possibility for employment termination.

 

Discrimination and Sexual Harassment

Discrimination of employees or candidates on grounds of gender, skin color, religion, race, nationality, sexual orientation, marital status, socio-economic status, age, pregnancy, political views, health (mental of physical), or any other legally protected characteristic will not be tolerated. 

Avelo condemns any form of sexual harassment at work, whether by employees, consultants, advisors, clients, customers, partners, or suppliers. The company is committed to provide victims of sexual harassment with any help and support suitable to restore normal working conditions as soon as possible. Offenders will be subject to disciplinary and/or legal consequences. Employees, who feel they are being sexually harassed, are encouraged to confront their offenders openly. They may turn to their supervisors or to an internal person of their trust. Such notification must not lead to the persons affected suffering any disadvantages. 

Employees are encouraged to exercise judgment in assessing what constitutes discrimination and/or sexual harassment. HR can help in providing guidance in this. While Avelo shall provide support to all victims, it shall also institute disciplinary action against employees who accuse others of discrimination and/or sexual harassment without basis, with intent to abuse regulations in their favor.

 

Mobbing & Bullying

"Mobbing" refers to all activities which are intended to exclude certain individuals and in which the working environment is systematically disturbed. Avelo aims to create a working environment based on tolerance towards different thinking and behavioral patterns that should leave space for individual solutions to evolve and be implemented. Supervisors have a special responsibility in this respect. In their areas of responsibility, they ensure a working environment that respects the privacy of the individual, provides them with equal opportunities, as far as possible, and also handles mistakes constructively. Victims of mobbing should report such activities to her or his supervisor or to HR. By doing so, they will not experience any disadvantages as a consequence. Like in the case of discrimination and sexual harassment, Avelo will not tolerate false accusations, especially where this is intended to gain an advantage.

“Bullying” in this context refers to when one or more persons verbally and/or physically harass or intimidate another individual or group in the workplace. Bullying by coworkers, subordinates, or supervisors through creating rumors and using intimidation, humiliation, isolation, violence, and discrediting a person’s abilities or characteristics (like race, religion, nationality, etc.) are all examples of bullying.
 

Equal Opportunity

Avelo is an equal opportunity employer. As such, Avelo will not discriminate and will take affirmative action measures against discrimination in employment, recruitment, advertisements for employment, compensation, termination, upgrading, promotions, and other conditions of employment against any employee or job applicant on the basis of gender, skin color, religion, race, nationality, sexual orientation, marital status, socio-economic status, age, pregnancy, political views, health (mental of physical), or any other legally protected characteristic.

 

Conflict of Interest

A conflict of interest is a situation in which a person or organization has conflicting interests, personal, financial or otherwise, and serving one interest could have an adverse impact on those other interests or responsibilities. It occurs when a personal activity or relationship, in particular one with family members or close friends, could influence the judgment and ability to perform one’s job in an objective way and fulfill one’s duties. Even the appearance or perception of a conflict of interest can place Avelo and its reputation at risk. Divided loyalties or personal gains should not prevent employees from doing what is in the best interest of Avelo.

It may not always be clear whether an activity creates a conflict of interest. However, it is the responsibility of every employee to disclose a potential conflict, either personal or organizational. For this reason, employees are expected to discuss any potential conflict or questions about how best to handle a situation where a conflict might exist with their supervisor or HR. If a conflict or potential conflict exists, it should be documented to help protect the employee and Avelo if the situation ever comes into question.

 

Illegal Drugs or Alcohol

Employees are expected to perform work on behalf of Avelo free from the influence of illegal drugs or alcohol and in a condition that enables them to perform their duties. In addition, they cannot use, possess or sell illegal drugs on Avelo’s property.

 

Clinical Trials

Avelo and its partners adhere to the guidelines and regulations originating in the Nuremberg Code, the Declaration of Helsinki, and the principles of current Good Clinical Practice and Good Clinical Data Management Practice. Specifically, we require our employees and partners to: 

• Ensure the safety, rights, integrity, confidentiality, and well-being of clinical trial patients/healthy volunteers by applying proper scientific and ethical values. 

• Ensure that the interests and well-being of trial patients/healthy volunteers shall always prevail over interests of science, business, and society. 

• Ensure that all trial participants enroll voluntarily in clinical trials through correctly provided information and freely given informed consent. Clinical trial patients and healthy volunteers must always be able to withdraw from trials without justifying themselves. 

• Ensure that special consideration is shown to vulnerable clinical trial patients and healthy volunteers (including elderly, children, unconscious or mentally incapacitated persons). 

• Ensure appropriate qualification of staff involved in executing clinical trials.

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Gifts & Entertainment

Gifts and entertainment are not needed to conduct business with Avelo and might give rise to a conflict of interest. However, in certain cultures, gifts and entertainment are an integral part of doing business. Certain activities are an expression of politeness or a reflection of societal and/or cultural practices which require a response in a culturally sensitive, respectful and thoughtful way. Such activities may include modest forms of hospitality, such as breakfasts, lunches or dinners and occasional gifts of minimal value, which do not influence business decisions. Although it is difficult to define “modest,” the best approach is to exercise common sense or consult with the supervisor or HR. Giving or receiving gifts or entertainment must relate to Avelo's legitimate business. Employee should be aware of these guidelines and respect them at all times.
Generally soliciting or accepting gifts, entertainment, hospitality or other business courtesies and items of value is permissible, if:

• The gift or entertainment is modest.

• The reason for the gift or entertainment is appropriate.

• The gift or entertainment helps to improve business or community relationship.

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Employees who are given or offered a gift, entertainment, or other preferred treatment (especially if it becomes a regular occurrence), that they believe is inappropriate, must refuse such offering as much as possible, and report the event promptly to their supervisor or HR.
The following situations are always inappropriate and are expressly prohibited:

• Giving a gift, entertainment, or preferred treatment with the intention of trying to influence the decision-making objectivity of an Avelo employee.

• Offering a gift, entertainment or preferred treatment intended to influence a purchasing decision.

• Offering a gift, entertainment or preferred treatment while involved in a current purchasing or contracting decision process.

• Offering an opportunity to purchase products, services, or a financial interest under terms not available in the market or available to other Avelo employees.

• Offering a gift, entertainment or preferred treatment to any medical doctors, clinical service providers or hospital personnel involved in any of Avelo’s clinical trials.

• Offering entertainment where the employee will not be present/represented (e.g., sports, event tickets).

• Any gift of cash or cash equivalents.

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Prohibition of Bribes, Kickbacks, Unlawful Payments & Other Corrupt Practices

While Avelo respects local business customs and market practices, we do not participate in any corrupt practices such as taking bribes, kickbacks and other unlawful payments and corrupt practices. Employees must not use an agent or representative to do anything that is prohibited by Avelo’s policies. All employees and any party acting on behalf of Avelo must follow the laws of the country, in which they operate, and the applicable Swiss laws, and keep accurate business records worldwide to ensure the records reflect actual transactions and payments. More specifically, they must not offer, make, or authorize payment of money or anything of value, directly or indirectly, to:

• Influence illegally the judgment or conduct or ensure a desired outcome or action of any individual, organization, or authority.

• Win or retain business or to influence any act or decision of any governmental official, political party, candidate for political office or official of a public international organization.

• Gain an improper advantage.

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Fair Competition, Antitrust and Trade Compliance

At Avelo, we are firmly committed to the ideas of free and competitive enterprises. Employees or any individual acting on behalf of Avelo are expected to comply with applicable local, regional, and international laws and regulations regarding fair competition and antitrust.

Employees or other individuals acting on behalf of Avelo are expected to comply with the letter and spirit of all applicable import/export controls and trade compliance laws of Switzerland and of the host country where Avelo does business. In addition, we respect trade sanctions and import/export restrictions if applicable.
 

Health and Safety at Work

At Avelo, it is our collective priority to provide a safe and healthy workplace for employees, contractors, partners, and visitors working within, or visiting our facility. All employees and visitors are responsible for keeping safety and health top of mind and should immediately report unsafe or hazardous conditions to the supervisor and HR. Employees must comply with our policies, standards and procedures relating to workplace health and safety and with all applicable workplace health, safety laws and regulations.

We aspire to create a strong and healthy culture where individuals and teams can strive and encourage everyone to contribute. Physical and mental health are pre-requisites for a healthy work relation. Thus, every employee has the right to be “offline” and should not feel under pressure to constantly monitor messages. To ensure proper communication and collaborations, teams and workgroups should mutually agree on “reachability expectations”.
 

Use of Social Media

Social media includes any digital communication channels that allow individuals to create and share content and post comments including but not limited to LinkedIn, Facebook, Twitter etc. Employees should be mindful of the content created, shared, and posted, remembering that the internet is a public place. They should always use common sense when engaging in social media activity and be aware of the difference between social and business communication. In particular, they must not share any confidential information.

In personal activities on social media, employees should be respectful and aware that their conduct may impact the way others view Avelo and what our company stands for. Permissions must be granted, and releases obtained, when images or video of our work results are to be featured.
 

Use of Company Assets and Property

We rely on Avelo assets and property to support our work. Computers, mobile devices, information technology hardware and software, facilities, machinery, raw materials, inventory, supplies and any other assets are placed in our care and should be used only for legal, appropriate reasons. When working with company information technology tools (such as laptops, email, apps, databases, etc.), employees should set up complex passwords that cannot be easily guessed and should never share passwords. Company information should not be stored with unapproved internet or cloud services that may not be protected and may be accessed by unauthorized people. 

Communication and information media such as internet, e-mail, telephone, etc. provided by Avelo are to be used primarily for job-related purposes. Private use is tolerable to a reasonable extent but should never interfere with professional obligations. Misuse of the media and equipment, including but not limited to visiting illegal websites, could result in disciplinary action, and may even result in the termination of the employment agreement or lawsuits. Avelo may monitor access to the internet, e-mail, telephone, etc. on an as-needed basis.
 

Intellectual Property (IP) and Confidential Information

Intellectual property includes copyrights, patents, trademarks, product and package designs, brand names and logos, R&D results, inventions, and trade secrets. The intellectual property and confidential information of Avelo are irreplaceable, crucial assets, which must therefore be secured, preserved, and protected at all times. Therefore, it is very important that proprietary documents, information, and data stay strictly within Avelo, or, in specific cases or projects, that they are only shared on a need-to-know basis with trusted partners who are themselves under strict confidentiality obligations. Employees or any individual acting on behalf of Avelo should avoid talking about or sharing confidential information in public places like airports and restaurants. 

At Avelo, we not only protect our IP but also preserve confidential information and trade secrets of other companies and individuals. We may collect and share information such as market, competition, scientific literature etc. from the public domain, but do not allow for collection and disclosure of others’ proprietary information without their prior written consent. At conferences, industry meeting or any other professional meeting, we avoid discussions of competitive information with employees of competitors in all circumstances. Employees must speak truthfully, and never misrepresent who they are or whom they work for to learn about competitors or gather any other confidential information unlawfully.

Any suspected theft of intellectual property, unauthorized disclosure or threatened disclosure of, or access to, our company information should be immediately reported to one’s supervisor or HR. The same rule applies to any breach or threatened breach of a confidentiality agreement.