CODE OF CONDUCT · 4 PPD Policy No. 11-104r04 Eflective Date: 1 anuary 2020 DO THE RIGHT THING Our code of conduct is a guidebook to all kinds of work situations: conflicts of interest,

CODE OF CONDUCT

DO THE RIGHT THING

PPD Policy No. 11-104r04 Effective Date: 1 January 2020

Document Number: 11-104r04

DO THE RIGHT THING2 PPD Policy No. 11-104r04 Effective Date: 1 January 2020

CONTENTS AN INTRODUCTION TO OUR CODE

We Commit to Ethical Behavior 6

We Abide by our Code of Conduct 9

We Accept Responsibility 11

We Report Potential Violations of Law, this Code or Other Policies 12

OUR PEOPLE AND OUR COMPANY

We Respect Each Other and PPD 14

We Work Together Respectfully 15

We Maintain a Safe and Healthy Workplace 17

We Comply with Health and Safety Laws 17

We Avoid Conflicts of Interest 18

We Maintain Confidentiality 22

We Recognize Privacy 23

We Keep Accurate Records 23

We Report Accurate Financial Statements 23

We Comply with Tax Laws 23

We Comply with Securities Laws 24

We Expect More from Our Officers 24

We Use Company Resources Responsibly 26

We Access Social Media Responsibly 26

OUR CLIENTS AND OUR VENDORS

We Keep our Clients’ Proprietary Information in Confidence 28

We Prohibit Bribery and Do Not Tolerate Corruption 30

We Offer and Accept Appropriate Gifts and Entertainment 31

We Treat Our Vendors Fairly 32

OUR MARKETPLACE AND COMMUNITIES

We Abide by Antitrust Laws 34

We Follow the Rules of Government Contracting 34

We Comply with All Applicable Drug Development Laws 35

We Respect Our Environment and Give Back to Our Communities 36

We Participate in Politics Responsibly 37

We Respond to the Media Appropriately 38

OUR CORPORATE COMPLIANCE PROGRAM

Our Corporate Compliance Code 40

Code Waivers, Amendments and Information for Directors 41

SEEKING GUIDANCE AND RAISING CONCERNS

We Ask Questions 43

We Learn and Continuously Improve 46

We Are Part of the Team 47



LETTER FROM OUR CHAIRMAN AND CHIEF EXECUTIVE OFFICER

Dear Fellow Employees and Directors:

Since our founding more than 30 years ago, PPD has set high

expectations for the conduct of business Operating with integrity

became a cornerstone of our culture and an integral thread of what

has been called PPD’s DNA We maintain that commitment to

integrity today as our employees work in more than 45 countries

around the world to help our clients accelerate delivery of safe and

effective therapeutics to patients

Our commitment to strong ethical behavior is outlined here in our

code of conduct and included in our defining principles: we do the

right thing So, what does doing the right thing mean to us as

employees and directors? It means we hold ourselves to high ethical

standards in our daily work The code and our corporate compliance

program are a frame-work for conducting ourselves and operating

our company ethically

Our compliance program is not just a set of rules—it is a guide to operating with integrity Before

we act on a particular issue where the proper course of action is unclear, we should always ask:

+ Is it legal?

+ Does it follow PPD policy?

+ Is it right?

+ How does it look to others—both inside and outside of PPD?

BEFORE WE ACT ON A PARTICULAR

ISSUE WHERE THE

PROPER COURSE OF

ACTION IS UNCLEAR,

WE SHOULD ALWAYS ASK:

Is it legal?

Does it follow PPD policy?

Is it right?

How does it look to others—both inside and outside of PPD?

DAVID SIMMONS CHAIRMAN AND CHIEF EXECUTIVE OFFICER



Our code of conduct is a guidebook to all kinds of work situations: conflicts of interest,

gifts, entertainment, and compliance with the laws and regulations that apply to our

business, among others By understanding the code and looking at the specific policies

that it references, we should be able to have a clear understanding of what is and is

not expected of us

Of course, no code or compliance program can cover every situation We encourage you

to raise any questions you have about the Code and the compliance program with your

manager, the human resources compliance liaison or the independent hotlines that are

part of our program Please know you won’t be retaliated against for raising a question

or concern in good faith

In my experience, we only get better by addressing problems when they arise All of us have a

duty to speak up when we see things that are not right Sometimes little problems grow when

they aren’t addressed We should address compliance issues immediately when they arise—if

we don’t, that puts PPD at risk and goes against our values

It is the responsibility of each of us to know and understand PPD’s code and policies

Be proud of the work you do and, remember, our integrity defines who we are We do

the right thing

Thank you for your continued commitment to PPD and ethical behavior

David Simmons

Chairman and Chief Executive Officer

PPD


AN INTRODUCTION TO OUR CODE

DO THE RIGHT THING



6 DO THE RIGHT THINGPPD Policy No. 11-104r04 Effective Date: 1 January 2020

WE COMMIT TO ETHICAL BEHAVIOR

PPD is committed to ethical and lawful behavior,

and to acting professionally and fairly in all

business dealings and relationships We seek to

maintain high ethical standards and to comply

with all applicable laws and regulations



ETHICAL RESEARCH AND BUSINESS CONDUCT ARE THE FOUNDATION OF OUR BUSINESS THIS COMMITMENT TO INTEGRITY IS REFLECTED IN OUR DEFINING PRINCIPLES: WE DO THE RIGHT THING



WHAT IS INTEGRITY?

Integrity means acting in an honest manner, in

compliance with the law and in accordance with

high ethical standards and the principles set out in

this Code of Conduct

Our company’s reputation depends upon our

integrity and ability as employees and as members

of our board of directors (“directors”) While our

industry is subject to many laws and regulations,

our commitment to quality service and honesty in

dealing with others means we go beyond what is

legally required

WE EXPECT INTEGRITY

in all we do—

and we must

constantly strive

to do what is right



IT IS OUR RESPONSIBILITY TO

DO THE RIGHT THING

WE ABIDE BY OUR CODE OF CONDUCTOur Code is specific to our company It not only includes an overview

of the laws, regulations and policies that we must follow, but also

reflects our values and culture here at PPD When there is a conflict

between U S laws and those of another country, we will try to resolve

such conflict with guidance from our legal advisors If you become

aware of any conflict of laws, you should let the legal department

know immediately

Legal and regulatory requirements are the starting point of what is expected of us

We expect integrity We must make sure that in our dealings with fellow

employees and directors, clients, suppliers and government officials, we

make ethical and legal decisions We need to be familiar with the policies

and procedures that apply to our jobs and positions

We should not be misguided by any sense of loyalty to PPD or a desire

for profitability—we must NEVER disobey any applicable law, this Code

or any other company policy to try to “help the company get ahead ” The

Code delves into a number of different topics and discusses our policies

in each area Essentially though, it all comes down to this: we must avoid

anything that even appears improper or unethical



BEFORE YOU DO SOMETHING, ASK YOURSELF:

+ Is it legal?


+ Is it right?

+ How will it look to others—

inside or outside of PPD?



WE ACCEPT RESPONSIBILITY We must follow all applicable laws, this Code and all other

company policies in performing our duties and job responsibilities

We avoid any activity that:

+ is illegal

+ would involve PPD in any practice that is illegal

+ does not comply with this Code of Conduct or any other

PPD policy

Not following applicable laws, this Code or

other PPD policies, may subject individuals involved

to disciplinary action—

up to and including termination of employment.

It could also lead to criminal prosecution of the

company and the individual.

Therefore, it is critical to understand and comply with

the requirements of your job, and to ask questions

wherever you are unsure



WE REPORT POTENTIAL VIOLATIONS OF LAW, THIS CODE OR OTHER POLICIES We encourage reports of suspected violations of the Code and any other law or policy Our

non-retaliation policy for reports of suspected violations ensures you can make such a report

without fear of retaliation This non-retaliation policy states that you cannot be treated in a

negative way—such as being fired or disciplined—if you lawfully and in good faith report a

suspected crime or a violation of law or policy or if you help in the investigation of such a

suspected crime or violation

If you suspect there is a violation of this Code, any other company policy, or any law or

ethical principle, you have a responsibility to report that information In most cases, you

should discuss a possible violation with your immediate supervisor if you are an employee,

or with the general counsel or the chairman of the board of directors’ audit committee, if

you are a director Of course, if you feel like you cannot discuss the situation with these

individuals, you can report suspected violations in one of the following ways:

The hotline is answered by an independent service that will treat all calls confidentially, as

allowed by applicable law Also, if requested and allowed by applicable law, an anonymous

report may be made If there is a separate policy that includes a method to report a

suspected violation of that policy, you can either follow those procedures or report it

as shown above

+ Call the Code of Conduct hotline: + In the U S and Canada, dial +1 888 898 4087

+ For everywhere else, dial +1 770 613 6324

+ Email the HR compliance liaison: [email protected]


mailto:corporate.compliance%40ppdi.com?subject=

OUR PEOPLE AND OUR COMPANY

DO THE RIGHT THING




WE RESPECT EACH OTHER AND PPD

We have a rich history of working together in

growing our company into the organization we

are today We could not be as successful as

we are without our employees and directors, the

way we treat each other and the way we represent

PPD We must continue to treat others with

respect, both personally and professionally

There are a number of ways that we can show

our regard for each other and our company



WE WORK TOGETHER RESPECTFULLY

Our people are a key part of our success as a company It is important that we take pride in

our workplace, treating our co-workers with respect and actively participating in creating and

maintaining a positive work environment This means, in part, that we do not allow

discrimination and harassment in our workplace

Our company is an equal opportunity employer—meaning we hire, train and promote

employees based on merit, not through illegal discrimination We do not tolerate discrimination

based on race, color, gender, national origin, age, religion, citizenship status, disability, medical

condition, sexual orientation, gender identity or expression, veteran status, marital status, or

any other characteristic protected by law

Similarly, harassment is never tolerated at PPD In general, harassment is any unwelcome

conduct that creates an intimidating, hostile or otherwise uncomfortable work environment

Whether it occurs verbally or physically, or is sexual or nonsexual in nature, harassment is never

acceptable If you feel you have been a victim of harassment or discrimination, in the U S you

have an obligation to report the situation to your immediate supervisor or HR representative

If you cannot report this to him or her, contact the hotline or email the compliance liaison

In any of our offices, if you feel you have been harassed or discriminated against, please

contact your supervisor, HR, the HR compliance liaison or the hotline Remember, PPD’s

non-retaliation policy prohibits anyone from treating you in a negative manner because of

your reporting or cooperating in the investigation of a potential violation of the law, this

Code or any other PPD policy

Copies of a selection of applicable equal opportunity laws and regulations, including the U S

Equal Employment Opportunity and Affirmative Action Policy and the U K Equality Act 2010

are available on the intranet Here, you can also view the sexual harassment policy

OUR PEOPLE ARE

A KEY PART OF OUR SUCCESS

It is important that we take

pride in our workplace,

treating our co-workers

with respect and actively

participating in creating

and maintaining a

positive work environment



SCENARIO Collette’s co-worker Robert came into her cubicle and rubbed

her neck and shoulders. Collette was very uncomfortable and

asked him to stop. She did not want to report Robert to her

supervisor because she was embarrassed. But what if Robert

does it again?

Sexual harassment can be humiliating, and it’s understandable

that Collette might feel uncomfortable talking to her supervisor

about the incident But it is important that the behavior not be

allowed to continue—with Collette, or with another co-worker

There are several other ways to report this incident: Collette

can contact HR, contact the hotline or email the compliance

liaison It doesn’t matter which resource she chooses—Collette’s

report will be investigated with discretion and she will be safe

from retaliation



WE MAINTAIN A SAFE AND HEALTHY WORKPLACEOur company supports our total health and well-being That is why PPD maintains strong

wellness programs, employee assistance programs and social committees These promote not

only individual wellness, but also positive professional and social engagement among us

PPD is also a “drug-free” workplace This means that we are required to work without being

impaired by drug or alcohol abuse Having or using unauthorized or illegal drugs, drug

paraphernalia or substances, or abusing or misusing legal drugs, alcohol or other substances

while on PPD business or during working hours is prohibited

In addition, being a safe, healthy place to work requires us to resolve our conflicts peacefully and

professionally We must never tolerate or resort to violence or threats of violence against our

co-workers or others with whom we interact during the course of our work

WE COMPLY WITH HEALTH AND SAFETY LAWSPPD is committed to complying with all applicable safety and health laws–which is why each of

us receive safety information and training when we first join the company If you work in a PPD

laboratory, you also receive more specialized training in health and safety compliance If you

have questions concerning any issues of safety compliance, please refer to the health and safety

intranet site or contact the hotline

OUR COMPANY SUPPORTS OUR

TOTAL HEALTH & WELL-BEING

That is why PPD

maintains strong

wellness programs,

employee assistance

programs and social

committees



WE AVOID CONFLICTS OF INTERESTA conflict of interest occurs when we allow our personal interests to interfere with our responsibility to PPD It is crucial that we act to benefit our company and avoid situations that might cause such conflicts or be perceived as such by others When we allow outside activities or relationships to cloud our judgment, or interfere with our responsibilities to PPD, we harm not only our company, but also our co-workers, clients and others who rely on or place their trust in us The same holds true for interests or investments held by members of

our families

EXAMPLESThough it may not be possible to cover every possible conflict situation, here are a few of the most common examples of possible conflicts of interest.

+ Holding, or having a family member who holds, any ownership interest (other than a “nominal” amount of securities in a privately held or publicly traded company) in any client, supplier or competitor

+ Having a personal consulting or employment relationship with any client, supplier or competitor

+ Participating in any way (for example, as an advisor, consultant or member) in an expert network, expert committee or similar group for an investment bank, hedge fund or similar business in your individual capacity—note: because this activity is a potential conflict of interest and also has inherent risks relating to the disclosure of confidential information and violation of insider trading laws, participation in these expert networks or groups is prohibited

WILL BE CONSIDERED “NOMINAL” ONLY IF:

+ It is less than 1 percent of the outstanding securities of such client, supplier or competitor and

+ It has a value of less than 5 percent of the total assets of you or your family member


AN OWNERSHIP INTEREST IN A CLIENT, SUPPLIER OR COMPETITOR


+ Competing in any way with our company’s business

+ Exchanging gifts or gratuities (other than an occasional inexpensive item) or excessive entertainment with any company with which we have business dealings—see the anti-corruption compliance policy for more on this

+ Taking on any outside employment that interferes with our work for and commitment to PPD

+ Having a personal relationship with our immediate supervisor without the approval of the HR department

+ Selling anything to the company or buying anything from the company (other than at arm’s length and/or on terms available to unrelated third parties)

+ Using non-public or proprietary information learned in the course of service or employment for personal investment or gain or the personal investment or gain of any other person or party, including family members

+ Taking opportunities to benefit yourself that are discovered through the use of PPD property, information or position

KEEP IN MIND THESE RULES APPLY to our family members as well—that includes spouses, children, parents, grandparents, siblings, in-laws or any other members of our households



+ Tony is a CRA with PPD His family owns a catering business that caters all of the office

meetings This may be a conflict of interest and should be disclosed and reviewed

+ Olga worked for Sergei for four years before marrying his son This may be a

conflict of interest, as Olga is now part of Sergei’s family and is still being

supervised by him Both Olga and Sergei should discuss this situation with HR

+ Jose works full time with PPD during the day, then heads to his role as a night-shift su-

pervisor for the local police department from 5:30-12:30 at night The 35-hour

commitment required of Jose’s second job creates a conflict If Jose were required to

stay late for PPD, he may not be able to do so because of the second job His long hours

might also cause him to be tired and less attentive to his responsibilities at PPD

+ Sarah is a Vice President of Clinical Management She was approached by an investment

banker to serve as a market research adviser regarding the pharmaceutical industry

Individually acting as an adviser for an investment banking firm is an actual conflict of

interest and prohibited by the Code

+ Joe is an employee who works in PPD’s medical writing department He also has a job

providing medical writing services to PPD’s competitor, Big CRO, after hours Working for

a direct competitor of PPD is an actual conflict of interest and a

violation of this Code

+ Maria used to work for a big pharma company They recently asked that she consult with

them on Saturdays and Sundays, instead of hiring PPD to perform the same consulting

services This is an actual conflict of interest as Maria is taking business away from PPD

SCENARIOS



HOW DO YOU REPORT A POSSIBLE CONFLICT OF INTEREST?

+ If you are an employee, let your supervisor know and contact the legal department at GeneralCorporate LegalSM@ppdi com

+ If you are a director, talk to the general counsel or the chairman of the audit committee

+ In any circumstance, you may contact the hotline for assistance

If you are giving or receiving a gift or entertainment or being entertained by a client or supplier, you should:

+ submit these items for advance approval via the PPD Gifts and Hospitality Register, as required

+ see our anti-corruption compliance policy for details

REMEMBER,it is always best to have

the situation reviewed

in advance This helps us

all avoid even the

appearance of

a conflict

NOTE: Potential conflicts of interest will be reviewed with either the corporate compliance committee or the board of directors:

+ If you are not an executive officer: the corporate compliance committee will

review your situation and decide if a conflict of interest exists, and if so, they

may choose to grant you a waiver

+ If you are a director and executive officer: only the board of directors may

grant a waiver of a conflict of interest


mailto:[email protected]


WE MAINTAIN CONFIDENTIALITYWe invest a large amount of time in dealing with important

and sensitive information—employee, financial, medical, client,

procedural and other important propriety information We are

expected to keep all of this information in confidence

As employees or directors, we have access to our company’s

proprietary information for work purposes only We must keep

this information confidential, and agree to do so, both while

working for PPD and after our employment or service ends

unless local law does not permit such an agreement regarding

post-employment activities However, even if you did not sign

such an agreement, you are expected to keep our proprietary

information and inventions in confidence in accordance with

local laws

We also have an obligation to keep our clients’ proprietary

information confidential This is discussed in detail later in

this Code

Please note that PPD does not restrict any current or former

employee from communicating, cooperating or filing a complaint

with any governmental authority with respect to possible

violations of law

IMPORTANT & SENSITIVE INFORMATION:

+ employee

+ financial

+ medical

+ client

+ procedural and

+ other important propriety information



WE RECOGNIZE PRIVACYWe respect each other’s privacy Any personal employee information we collect, store, maintain or use must be handled responsibly Everything from names, contact information, government-issued identification numbers and medical records needs to be protected, and must not be shared with anyone inside or outside of PPD that does not have a business need to use it The same goes for any information we collect about others with whom we interact, like study participants Our privacy policy is available both on our intranet and the external PPD website It outlines the data protection principles we observe We also comply with all applicable privacy laws and regulations

WE KEEP ACCURATE RECORDSIt is crucial to maintain accurate books and records of our financial performance, tax payments, payroll, expense reports, legal issues, reports to government agencies and customer files, in accordance with accounting rules and pronouncements as well as other laws and regulations Failing to maintain accurate records or retain those records in accordance with PPD’s records management policy can violate our anti-corruption and compliance policy and, in some cases, may be illegal Our company depends on us to help ensure the information we provide is correct and reported in a timely fashion

WE REPORT ACCURATE FINANCIAL STATEMENTSWe provide full, fair, accurate, timely and understandable financial reports Many people rely on these reports: management, customers, investors, regulatory agencies and the general public We comply with all applicable accounting and financial standards as well as securities laws and regulations

If you have any concerns or suspect any accounting or audit issues, you are responsible for reporting this information to your supervisor, the Code of Conduct hotline or the HR compliance liaison as outlined in this Code, or as set out in the Financial Whistleblower Policy

WE COMPLY WITH TAX LAWSWe adhere to applicable tax laws We have a zero tolerance approach to criminal activities including tax evasion or the facilitation of tax evasion Our policy on UK anti-facilitation of tax evasion is available on our intranet

SCENARIOIn order for us to submit

bills to our customers and

be paid promptly and

correctly for our work,

we must keep accurate records

of the time we work and any

business travel All of us must

therefore complete and submit

approved timesheets on a timely

basis, as well as complete

expense reports in accordance

with the PPD travel policy



WE COMPLY WITH SECURITIES LAWSAs part of our work for PPD, we sometimes see or have access to sensitive, non-public

information about PPD, our clients or our competitors This might be financial information,

or information about products or services under development No matter the type of

information, it is important that we understand our requirements for handling it under

both the law and the PPD Insider Trading Policy Simply put, we cannot use material

non-public information to get any personal benefit Material non-public information is

information that is likely to affect a reasonable investor’s decision to buy, sell or hold the

stock or securities of the company to which it relates This rule applies to not only us, but

to people such as family or friends Keep in mind that you should never share material

non-public information with anyone external to the company, and should only share such

information internally when there is a business need to do so and in compliance with

any applicable agreements Because of the risk for disclosure of material non-public

information and other violations of insider trading laws, serving as a member of an

expert network or committee for an investment bank or other financial entity is not

allowed under this Code

WE EXPECT MORE FROM OUR OFFICERSWe expect our executive officers to exemplify ethical behavior Their roles within PPD mean

they have a special responsibility in maintaining and communicating financial information

That is why we require our chief executive officer (CEO), chief financial officer (CFO) and

chief accounting officer (CAO) or controller to act with honesty, integrity and in good faith

to create and promote accurate, complete and timely financial reports Please report any

concerns you have about a violation of our Code by our officers to the hotline



SCENARIOSue worked on a large clinical trial for DiabetesPharma, a publicly

traded company. She learned while working on the trial that there

were very few side effects and that no significant safety issues were

reported. It appeared the drug would be fast-tracked. Sue told her

father-in-law what she learned, knowing that he would be interested.

She later found out that her father-in-law decided to purchase stock

in DiabetesPharma. Did Sue do anything wrong?

YES. Sue violated our insider trading and proprietary information

policies and our confidentiality agreement with DiabetesPharma, as

well as certain securities laws, when she shared this information with

a member of her family Since Sue learned about the benefits of this

new drug through her work in a clinical trial, she knew the information

was both important, and not publicly available By sharing the findings

of this trial with someone who was external to the company, Sue

violated the law, our policies, and our confidentiality agreement exposing

herself, her family and the company to severe consequences, which

may include fines, damages, and imprisonment

If you are not sure if the purchase or sale of PPD stock or a client’s stock

violates our insider trading policy, contact the legal department before

buying or selling the stock It is always best to ask before taking action



WE ACCESS SOCIAL MEDIA RESPONSIBLY

Our company understands that social

media is a big part of our lives, both

at work and outside of work The PPD

social media policy deals with our

participation in all kinds of social

media, both during working and

nonworking times, and whether we are

using our personal equipment or PPD

equipment In general, our policy gives

you guidelines about using social

media—many of those applicable

guidelines are contained in this Code,

such as confidentiality, privacy and use

of company equipment If you have

questions about the social media policy,

please contact the corporate communi-

cations group or contact the hotline

WE USE COMPANY RESOURCES RESPONSIBLYOur company provides us with computers, telephones, fax machines, printers, copiers and other

office equipment to use for business purposes We are allowed to make occasional personal use

of this equipment, like making personal phone calls or accessing social media This is a privilege,

so it is important that we do not abuse these resources or use them to access illegal or inappro-

priate material Be aware that PPD monitors the use of company resources to make sure they are

being used properly and in line with our policies, where allowed by local law

Please be aware that PPD reserves the right to search any property, personal or otherwise, on our

premises at any time with or without consent, when there is a reasonable belief that our policies

or procedures may have been violated and where permissible by law

SCENARIODirk was involved in a large project with a quick completion date. Many

days, he ate lunch at his desk and spent 15 minutes or so checking the

local news and looking at his football team’s scores and lineups for the

next day. Is there anything wrong with Dirk doing this?

NO. This occasional use of company computer systems is not an

abuse of Dirk’s privilege If Dirk’s personal use started to interfere with

his work or distract others, it could become a problem


OUR CLIENTS AND OUR VENDORS

DO THE RIGHT THING




WE KEEP OUR CLIENTS’ PROPRIETARY INFORMATION IN CONFIDENCE We value our relationships with our clients, and they trust

us to keep the sensitive information they share with us

confidential To formalize this commitment, we sign

confidentiality agreements with our clients and potential

clients Under such agreements, we agree that we will not

discuss a client’s confidential information with anyone, including

another PPD employee or director, who is not authorized to

receive it When authorized to share information, we should take

great care not to discuss it in a manner or location in which it

could be inadvertently disclosed to or overheard by others



SCENARIO Linda, a PPD CRA, was on a long flight after visiting an

investigator site for PharmaInc. On the last part of her

flight, she ran into Bob, another PPD employee, who works

in finance. Bob and Linda had a drink and Linda told Bob

that the PharmaInc study was in trouble. Linda went into

detail with Bob about the study’s difficult protocol requiring

multiple visits and PharmaInc’s failure to enroll study

participants, and told him that the drug was never going to

get approval. An employee of PharmaInc was sitting behind

Linda and Bob on the flight and reported this information to

PharmaInc. Could this get Linda in trouble?

YES. This inadvertent disclosure violated PPD’s confidentiality

agreements with PharmaInc and Linda’s own proprietary

information and inventions agreement with PPD As soon as

Linda inadvertently disclosed this information, she should have

reported it to her manager and the legal department to help

manage the situation



WE PROHIBIT BRIBERY AND DO NOT TOLERATE CORRUPTIONWe take a zero-tolerance approach to bribery and corruption We are

committed to complying with anti-corruption laws and implementing

systems to prevent bribery and corruption in our global business—a

commitment set forth in our anti-corruption compliance policy As part

of this policy, we comply with global anti-corruption laws, including the

U S Foreign Corrupt Practices Act and the U K Bribery Act

Abiding by anti-corruption laws means we do not engage in or condone

any acts of corruption or bribery We may not make, offer, promise or

authorize any gift, payment or anything of value on behalf of PPD in

order to gain improper advantage Further, we may not request, agree to

receive or accept any gift, payment or anything of value which you know or

suspect is being offered or provided to you with the expectation that PPD

will provide an improper advantage in return

This policy also applies to business partners, including consultants,

contractors, agents and other representatives who act on behalf of PPD

Please see more information on gifts and entertainment in the

following section

WE COMPLY with global

anti-corruption laws,

including the U S

Foreign Corrupt

Practices Act and the

U K Bribery Act



WE OFFER AND ACCEPT ONLY APPROPRIATE GIFTS AND ENTERTAINMENT

In some countries, it may be customary to provide

reasonable gifts, business meals and entertainment to

government officials and commercial contacts

in connection with business meetings and certain

holidays Our anti-corruption compliance policy

permits such gifts and entertainment if they meet

ALL of the following requirements:

+ Reasonable and customary under the circumstances

+ Given in a transparent manner

+ Not motivated by a desire to influence or an expectation of commercial advantage

+ Meet the other requirements listed in the policy

Please take extra care when considering giving anything of

value to a government official (and remember that in many

countries in which we operate, investigators and other study

staff are government officials) Ensure that you refer to the

anti-corruption compliance policy and comply with all the

conditions set out in it

WHAT IS A GOVERNMENT OFFICIAL?A government official includes all of the following It does not matter

whether it is the U S government or the government of any other country

in the world Remember, in many countries in which we operate,

hospitals are government-owned, and therefore doctors and other

study-staff (employed by the hospital) are “government officials ”

Any officer or employee (at any level of seniority) of a government or any department, agency or instrument of a government

Any person acting in an official capacity for or on behalf of a government or any department, agency or instrument of a government

Any officer or employee of a company or business owned in whole or part by a government

Any officer or employee of a “public international organization”

Any officer or employee of a political party or any person acting in an official capacity on behalf of a political party

Any candidate for political office

1.

2.

3.4.5.

6.



We approve, track and record all relevant gifts and entertainment—given and

received—through our gifts and hospitality register If you are giving or

receiving a gift or entertainment, refer to the rules relating to the register which

are found in the appendix to anti-corruption compliance policy

Excessive entertainment of any kind—whether involving government officials,

clients or vendors—is never allowed Remember, additional policies and

restrictions apply to PPD as a U S government contractor Make sure you are

familiar with these rules

WE TREAT OUR VENDORS FAIRLYWe value our vendors and appreciate our working relationships with them We

treat them fairly and with the respect we show one another here at PPD That is

why we make all purchases on the basis of price, quality and service, and deal

with our vendors fairly, honestly and openly We should avoid any actions during

the vendor selection process that could give others the impression of favoritism

or other improper advantage Giving one vendor an unfair advantage over an-

other is not just bad for the marketplace—it is also not in the best interest of our

company For details about dealing with vendors, please reference our purchas-

ing policy and the vendor code of conduct available on PPD’s external website

This policy covers all our vendors Examples of our vendors include investiga-

tors, couriers, translation providers and meeting planners as well as those who

provide services such as banking, auditing, legal, advertising and construction

and maintenance


OUR MARKETPLACE AND COMMUNITIES

DO THE RIGHT THING




WE ABIDE BY ANTITRUST LAWSAntitrust laws—known globally as “competition laws”—exist to prevent anti-competitive

behavior in the marketplace Ultimately, these laws protect consumers by ensuring they have

access to quality goods and services at fair prices They make it illegal for us to make formal or

informal agreements with our competitors in order to gain an unfair advantage in our industry

As employees or directors, this means we must never enter into agreements to set prices, limit

production or allocate customers, markets or vendors If you believe that you have a situation

that would allow you to legally discuss prices with a competitor that is also a vendor, customer

or associate, you must first discuss it with the legal department

Antitrust or competition laws may also prohibit certain agreements with vendors or

customers—in addition to those with competitors—if they restrict competition For example,

monopolies, tying arrangements, price discrimination, boycotts, reciprocity arrangements

and restrictions on dealing in goods of a competitor are all often illegal Even exchanges of

information among members of a trade association, such as ACRO, are not protected from

antitrust law If you have any questions about antitrust laws, please contact the legal

department Of course, you can also call the hotline

WE FOLLOW THE RULES OF GOVERNMENT CONTRACTINGWe provide services to government agencies and other entities that are conducting

government-sponsored research When we interact with governmental entities, additional laws

and regulations may apply to us We have adopted policies and restrictions that govern our

conduct when providing services as a government contractor of the United States If you have

questions concerning these policies and restrictions or dealings with any governmental entity,

please contact the legal department; of course, you may always contact the hotline

WE FOLLOW THE RULES...

We have adopted

policies and restrictions

that govern our

conduct when

providing services

as a government

contractor



WE COMPLY WITH ALL APPLICABLE DRUG DEVELOPMENT LAWSPPD is a premier provider of drug discovery and development services As a member of

the CRO industry, we are required to conform to regulations and laws with global regulatory

authorities such as the U S Food and Drug Administration (FDA), Medicines and Healthcare

Products Regulatory Agency (MHRA), European Medicines Agency (EMA), as well as to

International Conference on Harmonisation (ICH) guidelines that govern Good Clinical

Practices (GCP), Good Manufacturing Practices (GMP) and Good Laboratory Practices (GLP)

We also must operate in compliance with the Clinical Laboratory Improvement Act (CLIA) in

selected laboratories To ensure that PPD is operating in accordance with these requirements,

we have developed and continuously revise our standard operating procedures (SOPs)

All of us are required to understand all SOPs applicable to our jobs In addition, we are

required to stay up to date on all training on SOPs, working practices documents (WPDs)

and other policies required for our positions at PPD

Our business reputation depends upon the accuracy of the data we report to our clients and

to the FDA and ICH If you suspect the inclusion of fraudulent data in any report, program or

clinical trial, you must report the suspected violation immediately to your immediate supervisor

He or she will then report the incident to the global quality and compliance department, who will

investigate the matter

If you learn of any serious adverse event occurring in a clinical trial, report it immediately to the

project manager for that particular study Be sure to include as much information as possible and

follow up with the project manager to ensure he/she receives the information needed

Remember: You can always report any suspected violations of law, regulation or policies to the hotline



WE RESPECT OUR ENVIRONMENT AND GIVE BACK TO OUR COMMUNITIESWe live and work in a variety of communities and environments around the

world As a good corporate citizen, we want our employees benefit these

communities and help maintain our natural environments

As a company, we comply with all environmental laws and regulations

applicable to our business operations in our locations We seek to preserve

natural resources to the extent reasonably possible in the conduct of

business If you have concerns about PPD’s environmental policies, please

contact environmental health and safety group Of course, you may always

contact the hotline with any questions

Our company also encourages us to participate in our local communities and

to be a good citizen While serving our communities is an important part of

PPD’s philosophy, it is important for us to follow company guidelines and

policies when doing so

WE LIVE AND WORK IN A VARIETY OF COMMUNITIES

While serving our

communities is an

important part of

PPD’s philosophy, it is

important for us to follow

company guidelines and

policies when doing so



WE PARTICIPATE IN POLITICS RESPONSIBLY

As individuals,

we are encouraged

to get involved in our

communities by

voting and participating

in the political process

However, under U S

federal law and some state

laws (including North

Carolina), PPD is prohibited

from making any political

contributions to candidates

Because of these

prohibitions, we cannot

use company funds, tele-

phones, postage, stationery

or offices to support a

candidate for public office

SCENARIO Marley is a strong advocate for health care initiatives. She enjoys her

work with PPD and supports clinical research. She recently spent time

outside the office lobbying for change by supporting a candidate that

she felt was more involved in health care initiatives. In an effort to have

her letters carry more weight, Marley decided to use PPD stationery

and sign her name and title as a PPD clinical employee when asking for

contributions for this candidate. Is this okay?

NO. Marley should not have used company stationery or

referenced her employment with PPD as part of her political

involvement This gives the impression that PPD as a

company is supporting this candidate, which violates PPD’s

policy—and may be a violation of local law as well



WE RESPOND TO THE MEDIA APPROPRIATELYOur company regularly receives questions from newspapers,

magazines, websites and other media outlets about our

business To have a consistent approach with these groups,

we have adopted a media policy Under this policy, we should

direct any questions from the media to the corporate

communications department If you receive questions about

a financial matter or any question from our investors/potential

investors, forward them to PPD’s investor relations department

Never respond on your own to questions from the media Instead, you should politely inform the caller of PPD’s policy and refer them to the appropriate department


DO THE RIGHT THING

OUR CORPORATE COMPLIANCE PROGRAM




OUR CORPORATE COMPLIANCE PROGRAMOur Code is only one part of our overall corporate compliance program

With the support of our senior leadership team and our board of

directors, the program is administered and overseen by the corporate

compliance committee composed of leaders from finance, legal,

quality assurance, human resources and operations

In addition to the Code, remember that our corporate compliance program includes:

+ Anti-corruption compliance policy and gifts and hospitality register

+ This Code and anti-corruption compliance policy training

+ Other specific policies, procedures and training on those

+ Audit systems

+ Discipline for violations

+ Anti-retaliation policy

+ Hotlines and internal reporting mechanisms



CODE WAIVERS, AMENDMENTS AND INFORMATION FOR DIRECTORS For most employees, our corporate compliance committee may grant a waiver of any provision of this Code of Conduct If you are an executive officer or if you are a member of our board of directors, only the board of directors may grant a waiver To request a waiver, you must send the request in writing with detailed information to GeneralCorporate LegalSM@ppdi com Please note:

+ The board must record any waiver granted to you in its minutes;

+ You must sign a separate written authorization of the waiver;

+ The board will review the waiver periodically as to your compliance with its terms and whether or not it will be continued; and

+ We may be required to disclose—publicly or to other parties— any waiver granted to you

The Code may need to be changed from time to time This is done to help us avoid future violations, as well as to clarify our policies and to include new information in our evolving world We have changed our Code in the past, and we will need to review it for changes in the future Please note that only our board of directors can amend this Code We may need to publicly disclose any amendment if it is required by law

Finally, if you are a member of our board of directors, keep in mind that compliance with the Code is subject to the provisions of our certificate of incorporation, bylaws and any stockholder’s agreement with our company




SEEKING GUIDANCE AND RAISING CONCERNS

DO THE RIGHT THING




WE ASK QUESTIONS

If you have any questions about the corporate compliance

program or this Code, help is at hand Feel free to:

+ ask your supervisor

+ contact the HR compliance liaison (Corporate Compliance@ppdi com)

+ the legal department (GeneralCorporate LegalSM@ppdi com)

+ and, of course, the hotline

As a starting point, remember to ask yourself

these questions about any given situation:

+ Is it legal?


+ Is it right?

+ How does this look to others— inside or outside of PPD?

If the answers you get are unclear, follow up with any of the

listed resources in this Code for information and guidance.

and we know we can

deliver To ensure this, we

raise any and all questions,

and do so without any

fear of retaliation


REMEMBER

WE EXPECT INTEGRITY

mailto:Corporate.Compliance%40ppdi.com?subject=

mailto:GeneralCorporate.LegalSM%40ppdi.com?subject=


WE INVESTIGATE Our company, the compliance committee and the board take

reports of possible Code of Conduct violations seriously Concerns

and complaints concerning executive officers and directors will

be investigated as directed by the audit committee of the board,

and those concerning other employees will be investigated as the

corporate compliance committee directs All compliance issues will

be investigated promptly and we will communicate the results

back to the person making the report

While investigations are handled with discretion, we may

disclose the results of investigations to law enforcement or

regulatory agencies, when needed



WE TAKE ACTION Following our Code is a requirement of our work here at PPD

Consequences for violating our Code, company policy or the law

are consistently applied Disciplinary action might include

counseling, oral or written reprimands, warnings, probation or

suspension without pay, demotions, reductions in salary or

compensation, and termination of service or employment

NOTE: Keep in mind that simply following this Code is not

enough. You may be subject to disciplinary action if you:

+ Do not use reasonable care to detect a violation

+ Are asked for information about a violation and fail to

provide that information

+ Supervise someone who violates the Code and approve/

condone that violation

+ Retaliate or attempt to retaliate against someone who

reports a suspected violation



WE LEARN AND CONTINUOUSLY IMPROVE

Our corporate compliance group has its own website On it, you’ll

find this Code, our anti-corruption compliance policy, government

contracting guidelines and many other important documents

You’ll also find the hotlines, a link to training and a link to our HR

compliance liaison

Yearly Code and compliance program training is required of all of us

This includes the policies, procedures, SOPs and WPDs the program

encompasses Sometimes the training includes reviewing the Code,

watching a webcast and/or taking a quiz based on hypothetical

situations From time to time, our corporate compliance committee

sends out real-life examples of questions that come into the

committee and how they were handled This training helps us

better understand and apply the Code at PPD



WE BELIEVE IN A COLLABORATIVE

WORKPLACEOur company

depends on us to

speak up when we

see something that

does not look right to us

WE ARE PART OF THE TEAMWe believe in a collaborative workplace—all of us are part of the PPD team

As members of a team, we depend on each other to do the right thing

in our daily work Our company depends on us to speak up when we see

something that does not look right to us

If you see anything that you think is just not right, please contact your

supervisor, your HR representative, the HR compliance liaison or the

hotline You will not be retaliated against for your good faith report

PPD’s board of directors and senior management thank you for reading,

understanding and complying with our Code Together, we can continue

to grow our company responsibly and ethically and maintain our culture

of integrity that has served us well over the years


For more information, please contact us at

+1 877 643 8773 or +1 919 456 5600

ppdinfo@ppdi com

© 2019 Pharmaceutical Product Development, LLC All rights reserved 01 2019

twitter com/PPDCRO

facebook com/PPDCRO

youtube com/PPDCRO

linkedin com/company/ppd




http://www.twitter.com/PPDCRO

https://www.facebook.com/PPDCRO

http://www.youtube.com/PPDCRO

https://www.linkedin.com/company/ppd

PPD, Inc.

Procedural Document Approval Certificate

This Procedural Document has been reviewed and approved according to PPD processes.

UserName: Hartman, Judd (hartmabj)Title: EVP GC/CHIEF ADMIN OFFDate: Monday, 09 December 2019, 06:44 PM Eastern Daylight TimeMeaning: Document received Management Approval ================================================


Documents

CODE OF CONDUCT · 4 PPD Policy No. 11-104r04 Eflective Date: 1 anuary 2020 DO THE RIGHT THING Our code of conduct is a guidebook to all kinds of work situations: conflicts of interest,