CSL Limited Annual Report 2022/23 68 Ethics and transparency While CSL’s Values serve as its directional compass, the Code of Responsible Business Practice (Code) provides a more detailed map to deliver on our promise to patients and public health by exemplifying high standards of conduct throughout the organisation. CSL’s Code aims to foster a culture that rewards high ethical standards, personal and corporate integrity and respect for others. All employees undertake training on the Code and CSL’s new ethics-based decision making tool. These two e-learning modules have been made available in 14 languages to cater for CSL’s global workforce. In certain aspects of CSL’s business, such as the marketing of our products, our relationships with healthcare professionals or healthcare organisations and our research and development, we have made further commitments to comply with both local and internationally accepted pharmaceutical industry codes of conduct. CSL expects its third party partners to comply with the applicable local laws and regulations of the countries in which they operate, and to observe all of the principles set out in our Third Party Code of Conduct. We have internal control systems to ensure financial statements comply with the applicable local laws of the countries in which we operate and to prevent fraud and other improper conduct. CSL’s Code of Responsible Business Practice as well as Third Party Code of Conduct can be found on CSL.com (We Are CSL > Corporate Governance > Code of Responsible Business Practice). Anti-bribery and anti-corruption CSL has an Anti-Bribery and Anti-Corruption Policy that prohibits CSL businesses and employees from directly or indirectly offering, paying, soliciting or accepting bribes or giving or receiving personal favours, financial or other rewards or inducements in exchange for making business decisions. This prohibition applies regardless of the value of the reward or inducement. CSL policy also prohibits facilitation payments. The Board, via the ARMC, periodically receives information regarding material breaches of the Anti-Bribery and Anti-Corruption Policy as a way of maintaining oversight. CSL operates in a diverse and complex marketplace and has a number of commercial arrangements with governments and related agencies across various geographies. Bribery and corruption are risks that could expose the organisation and employees to possible prosecution, fines and imprisonment. Market practices are governed by company-specific policies and procedures. Internal compliance mechanisms and control systems are directly supported by our Global Ethics and Compliance team and subject to additional oversight by CSL’s Global Compliance Committee, regional committees, and CSL’s Audit and Risk Management Committee of the Board. Based on these controls, CSL considers its overall risk relating to corruption to be low and is committed to complying with laws and regulations in the regions in which CSL operates and those that CSL seeks to enter. CSL has a Group Speak Up Policy to encourage anyone to raise concerns about potential misconduct, including in relation to bribery or corruption. CSL staff may raise any concerns internally. Additionally, anyone can make anonymous reports to the Speak Up Hotline, an independent and confidential reporting line available globally. In addition, over the reporting period, an annual assessment of bribery and corruption risk was conducted by the Ethics & Compliance teams. The assessment included asking a cross-section of employees in CSL’s commercial and manufacturing operations to complete a standardised questionnaire. The questionnaire is designed to assist with identifying practices or behaviours that could be in breach of CSL’s Anti-Bribery and Anti-Corruption Policy. Results are provided to the Global Compliance Committee and regional/ local compliance committees for review, and the committees may ask for actions to be taken which could include: to revise regional or local policies or procedures; to deliver further training; for ongoing monitoring; or for a more detailed assessment of the local commercial operation, including any third parties acting on behalf of CSL. The implementation of the committee’s review and actions are supported by the local, regional and global Ethics and Compliance teams. Sustainability performance FTSE4Good CSL’s environmental, social and governance (ESG) performance has been recognised by the FTSE4Good Index Series, a leading sustainability index, for the last 12 years. MSCI In 2023, CSL received a rating of AA (on a scale of AAA-CCC) in the MSCI ESG Ratings assessment. MSCI focuses on companies’ ESG rated performance in each sector to help institutional investors more effectively integrate ESG considerations into their investment processes, as well as manage, measure, and report on ESG mandates. Sustainalytics As of March 2022, CSL’s ESG risk rating overall score is 24.24 with an ESG risk rating category of medium (on a 5-point scale from negligible to severe), ranking 44 out of 436 in the subindustry biotechnology sector (1st equals lowest risk). Sustainalytics provides analytical ESG research, ratings and data to institutional investors and companies. 10 CSL’s Governance
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