Business Ethics and Code of Conduct

MEGA’s approach begins with a clear Code. The Business Ethics and Code of Conduct is the foundation document for MEGA’s governance policy suite and serves as a guide for responsible conduct across the Company.

Compliance with the Code is mandatory for Directors, Executives, Management and employees of the Company, Subsidiaries, Associates and Joint Ventures, including those on deputation in or out of the Company. The Code also connects to employees in the value chain where MEGA has laid down the Supplier Code of Conduct.

New employees are required to read and acknowledge the Code. The Code is hosted on MEGA’s official website in English and Thai and has been translated into local languages in Myanmar, Cambodia and Vietnam to support understanding across key markets.

Non-compliance with the Code may lead to disciplinary action, including termination of employment in accordance with the laws of the territory where the individual is employed. This makes the Code not only a statement of values, but also a practical standard for accountability.

Responsibilities of Employees and Leaders

Every employee has a role in protecting MEGA’s ethical culture. Employees are expected to understand the framework of the Code in general and the sections that apply to their job specifically. This means understanding the issues, the Company’s position and the policies that guide daily work.

Leaders have an additional responsibility to create a culture of compliance. Senior Managers are expected to help build an environment where people understand the Code, raise concerns when needed and see that those concerns are handled responsibly. Leaders also share responsibility for gathering feedback and taking remedial actions when concerns are raised.

This leadership responsibility is important because ethical conduct is not created by policies alone. It depends on how managers communicate expectations, handle questions, respond to concerns and support fair treatment in practice.

Anti-Bribery and Responsible Marketing

MEGA follows a principled stance on bribery and marketing conduct. The Anti-Bribery Policy and Marketing Code of Conduct provide practical guidance for higher-risk interactions and help ensure integrity in business dealings.

The Anti-Bribery Policy covers procedures and limits for gifts, entertainment, donations, dealings with government officers, conduct with healthcare professionals and hospitals, employees with links to government, prohibition of political activities, prohibition of facilitation payments, accounting and reporting for gifts, audits and whistleblowing.

The Marketing Code of Conduct provides guidance on gifts to healthcare professionals, promotional aids, items of medical utility, samples, conduct and association with patient organizations, patient education and support, medical representatives, promotional materials, product-related claims, off-label claims, symposia and congresses.

Together, these policies help MEGA ensure that healthcare-related engagement is conducted responsibly and that business growth is supported by ethical and transparent relationships.

Conflict of Interest and Insider Information

Conflicts of interest can affect trust and decision-making. MEGA expects employees to disclose situations that result, or may result, in a conflict of interest. Employees are expected to disclose to their superiors any suppliers, customers or third parties doing business with the Company who are related to the employee.

MEGA strictly prohibits and discourages undisclosed conflicts of interest. Employees are expected to address such situations by disclosing the name of the party, the nature of the relationship and details of the contract with such party.

MEGA also maintains expectations on insider information. Directors, executives and employees must not disclose confidential or internal information for personal benefit or for the benefit of others, and must not trade securities of the Company by using confidential or internal information in a way that could cause damage to the Company.

Human Rights, Fair Treatment and Workplace Conduct

MEGA respects human rights and seeks to create an environment of equal opportunity. The Company strives to create relationships with suppliers and customers who promote human rights and provide equal opportunity to employees from different sections of society.

MEGA’s Human Rights Policy is aligned with internationally accepted principles, including the Universal Declaration of Human Rights, the United Nations Guiding Principles on Business and Human Rights, and fundamental conventions identified by the International Labour Organization.

The policy covers key expectations such as prohibition of child labor, forced labor and modern slavery; prohibition of sexual and other harassment; right to collective bargaining; environment, health and safety at the workplace; community engagement; workplace security; drug safety; data safety; non-retaliation and whistleblowing.

Workplace Conduct and Human Rights Topics

Data Protection and Confidentiality

Responsible conduct also includes protecting information. Customer data, trade terms, commercial details, business strategies, internal documents and other confidential information are treated as proprietary information.

Employees are expected to follow MEGA’s IT policies and ensure data secrecy and privacy of personal data. Confidential and internal information must not be disclosed or used for personal benefit, and employees are expected to maintain confidentiality even after leaving MEGA.

Ethics Training and Awareness Map

Handling Concerns and Protecting Reporters

MEGA supports the proper handling of concerns through its Business Ethics and Code of Conduct, Whistle Blower Policy, Non-retaliation Policy and investigation procedure. Employees and affected persons may raise concerns through secure and confidential reporting channels, and reported matters are handled through a defined process, including investigation and reporting to the Audit Committee within 30 days or within an agreed extension.

To ensure that concerns are handled properly, MEGA also provides training and guidance to managers and relevant responsible persons on how to receive, escalate and manage reports raised by employees or affected persons. This includes concerns relating to workplace conduct, discrimination, bullying, harassment, conflicts of interest, business ethics violations and other misconduct. The training emphasizes confidentiality, impartiality, protection against retaliation, appropriate escalation, documentation, investigation procedures and timely follow-up, so that reported concerns are handled in a fair, ethical and accountable manner.

This approach helps strengthen trust in MEGA’s reporting system. It also supports a workplace culture where employees and affected persons can raise concerns responsibly, while managers and relevant responsible persons understand their role in protecting confidentiality, preventing retaliation and escalating matters through the appropriate channels