Ethics and Compliance Program

At Lilly, we are committed to upholding the highest standards of corporate conduct in all business dealings around the world. Our global ethics and compliance program supports this commitment and is designed to meet all external requirements including codes issued by the International Federation of Pharmaceutical Manufacturers & Associations, the Pharmaceutical Research and Manufacturers of America, and European Federation of Pharmaceutical Industry Associations.

The Lilly family’s core values of integrity, excellence and respect for people provide the foundation for this program and continue to guide all that we do today.

The fundamental elements of our ethics and compliance program include the following:

Oversight

Our chief ethics and compliance officer reports to the public policy and compliance committee of Lilly’s board of directors, as well as to the CEO. This individual develops, operates and monitors the program managing a diverse organization that works across the business in all geographies.

The compliance and enterprise risk management committee, which includes top business and function leaders, provides oversight of the ethics and compliance program and the enterprise risk management program. The chief ethics and compliance officer provides quarterly reports on both programs to this committee and the public policy and compliance committee of the board of directors. Each year, the board of directors receives a state of compliance report and reviews the enterprise risk management plan.

Written Standards: The Red Book

The Red Book, our code of business conduct, is a statement of principles that guides our operations. These principles are based on 11 corporate policies and are consistent with our company values of integrity, excellence and respect for people. The Red Book sets the expectation for the behavior that we demonstrate every day and provides the ethical framework of our business. Our global procedures, standards and training align with the code of business conduct, and we hold every employee accountable for making decisions with integrity so we can earn and maintain the trust of the people we serve.

Education and Training

We require ongoing training and education of all employees on The Red Book, associated policies and procedures, and applicable legal requirements for specific roles. Employees in some functions and key risk areas may receive targeted training and education.

Communication

We actively promote open communication at all levels of the organization. Our employees understand they have an obligation to speak up when they have questions or concerns about potential violations or unethical behavior that could harm Lilly or the people we serve. Our leaders are expected to support and promote this open communication. Employees can report concerns to leadership, as well as human resources, ethics and compliance, or legal. We maintain a hotline available 24 hours a day to employees and the public globally, subject to local law, via phone at 1-800-815-2481 or online at Lilly Ethics Point. Translation services are available, and reports may be made anonymously.

Auditing and Monitoring

On an ongoing basis, we assess, evaluate, monitor and audit compliance with our ethics and compliance program and associated policies and procedures. We report findings to top leaders, local management and corporate governance committees.

Response to Potential Violations

We investigate all reports of potential violations using a standard process. If a violation has occurred, we determine appropriate disciplinary consequences by evaluating each case individually. We also review our procedures, processes and business practices to establish whether changes are needed to prevent further violations.

Additional Information

In addition to the ethics and compliance program, we maintain separate global privacy and bioethics programs. Our global privacy program is designed to protect and respect the personal information of people who interact with our company, products, mobile applications, and digital services and websites. Our bioethics program is designed to protect the rights and well-being of patients and clinical trial participants, as well as the integrity of the science behind our products.

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Ethical Conduct for Financial Management

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