Swedish Orphan Biovitrum AB

The Corporate compliance committee, consisting of the CEO, CFO, General Counsel, and Chief Compliance Officer, oversees compliance investigations. This ensures both non-retaliation against whistleblowers and organisational fairness in applying sanctions. In 2024, 11 (14) cases were reported and investigated. Training on the Code of Conduct, anti- corruption and anti-bribery are mandatory every second year. In 2024, 99 per cent (95) of eligible Sobi employees completed the Code of Conduct training, and 99 per cent (91) completed the recently updated anti-corruption and anti-bribery training. [...] The Partner Code of Conduct outlines Sobi's sustainability requirements for all its partners globally. The requirements of the Partner Code of Conduct include aspects such as human rights, protection against child and forced labour, environmental protection, anti-corruption, research ethics and protection of information. The policy furthermore mandates conducting risk-based due diligence on third parties.

#### 3.4 Governance

The Board of Directors oversees management's role in ensuring that Sobi's environmental commitment is communicated and met across the Group in a responsible and sustainable manner.

The Environmental organisation is responsible for setting the environmental agenda, recommending policy decisions, and monitoring and following up the development of Sobi's environmental priorities. This includes consistent development and implementation of this Policy across the group, initiating an annual review and reporting on progress. This is done in line with the sustainability agenda.

The Head of each Business Unit or Group Staff Function is responsible for ensuring that activities are carried out in accordance with this Policy.

The Corporate compliance committee consisting of the CEO, CFO, General Counsel and Chief Compliance Officer has oversight of compliance investigations, ensuring both non-retaliation against whistleblowers, and organisational fairness in regard to how sanctions are applied. During the year, a new global operating procedure governing compliance monitoring and self-inspections was implemented, and an updated global Investigations policy was launched in accordance with the EU Whistleblowing Directive. In 2022, 12 cases were reported via the hotline. To capture all cases, events reported outside the system can also be entered by proxy. [...] Sobi's compliance programme is designed to be proactive and follows the elements and principles for effective compliance programmes established by regulators. All new employees are introduced to compliance as part of the induction programme. Other means of training and communication include general and topic-specific e-learning, videos and articles on Sobi's intranet, InsideSobi. The Global Compliance Governance Charter ensures the management oversight of the compliance programme, including a governance structure with compliance committees, compliance accountability at different levels of the organisation and a network of country compliance subject-matter experts. The Chief Compliance Officer reports directly to the General Counsel, and regular updates on the compliance programme are provided to the Corporate compliance committee and board.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes