Supplier Code of Conduct

At Landcent, we accelerate the fight against diseases of poverty, starting with malaria. We develop and deliver impactful solutions to prevent, diagnose, and treat these diseases—addressing both local realities and systemic barriers to health. This Supplier Code of Conduct sets out the standards we expect from every organization contributing to our supply chain. Grounded in our values of honesty, compassion, and accountability, this Code reflects our commitment to ethical conduct, respect for human rights, environmental stewardship, and responsible business practices. We expect all suppliers and subcontractors to uphold these principles and operate with transparency, responsibility, and respect across all interactions.

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1. Purpose and Scope

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This Supplier Code of Conduct outlines Landcent’s expectations regarding ethical behaviour, legal compliance, environmental responsibility, and labour practices. It applies to all suppliers, subcontractors, service providers, and business partners (“Suppliers”). Suppliers must ensure that their employees, agents, and subcontractors comply with the standards defined in this Code. Updated versions of the Code will be communicated through official channels and made available on Landcent’s website.

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2. Legal Compliance and Ethical Conduct

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Suppliers must comply with all applicable laws, regulations, and industry standards. Where Landcent’s standards exceed legal requirements, these standards must prevail.

2.1 Anti-Bribery, Gifts, and Facilitation Payments

Landcent maintains a zero-tolerance policy for bribery and corruption. Suppliers shall not: offer, promise, give, or accept any payment, gift, or advantage intended to influence business decisions, provide facilitation payments, except in cases required to prevent loss of life or physical harm, offer gifts or entertainment exceeding EUR 50 to any Landcent employee, contractor or representative, or engage in extortion, embezzlement, or improper financial conduct. All suspicious activity must be disclosed promptly to Landcent.

2.2 Political Contributions and Donations

Suppliers may not make political contributions on behalf of Landcent. Charitable donations must never be made to secure or appear to secure a business advantage.

2.3 Fair Competition

Suppliers must conduct business in compliance with competition laws. Price fixing, market manipulation, bid-rigging, or any anti-competitive practices are strictly prohibited.

2.4 Anti–Money Laundering and Sanctions Compliance

Suppliers must prevent involvement in money laundering or terrorist financing, verify the identity of business partners, ensure that all funds originate from legitimate sources and comply with applicable sanctions imposed by the UN, OFAC, OECD, and other authorities.

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3. Conflicts of Interest

Suppliers must avoid situations where personal or business interests could conflict with Landcent’s interests. Any actual or potential conflicts must be disclosed to Landcent without delay. Suppliers are prohibited from offering personal benefits, gifts, or incentives to Landcent employees, contractors or representatives that could improperly influence business decisions.

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4. Human Rights and Labour Practice

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Landcent expects all suppliers to uphold the Universal Declaration of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. Suppliers must ensure equal opportunity and prohibit discrimination based on personal characteristics, respect freedom of association and the right to collective bargaining, where permitted by law, prohibit all forms of forced, bonded, trafficked, or child labour, ensure no one under 15 (or legal school-leaving age, if higher) is employed,  prohibit any form of harassment, abuse, coercion, or inhumane treatment, and foster workplaces where all individuals are treated with dignity and respect. Suppliers must provide safe and healthy working conditions, including adequate protective equipment, training on safety procedures, measures to prevent injury or illness, and emergency response plans.

5. Environmental Protection and Sustainability

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Landcent is committed to environmental responsibility. Suppliers must comply with all environmental laws and regulations, obtain and maintain necessary environmental permits, minimize waste, emissions, and pollution, implement sustainable practices and resource-efficient processes, protect wildlife, ecosystems, and biodiversity, and train workers in emergency response procedures. Innovation and continuous improvement in environmental performance are encouraged.

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6. Confidentiality, Data Protection, and Use of Assets

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Suppliers must safeguard confidential information belonging to Landcent and its partners. Personal data must be processed in compliance with GDPR and applicable data protection laws. Company assets, information, and intellectual property must be used only for legitimate business purposes.

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7. Reporting, Whistleblowing, and Non-Retaliation

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Suppliers are encouraged to report suspected violations of this Code, unlawful behaviour, or unethical practices. Reports will be handled confidentially, and investigations conducted fairly. Landcent prohibits retaliation against individuals who report concerns in good faith. Suppliers must extend the same non-retaliation protection to their own employees. Landcent will designate a dedicated reporting channel, such as a compliance email or hotline. Details can be found on its website.

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8. Monitoring, Audits, and Breach Consequences

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Landcent reserves the right to monitor compliance with this Code through audits and assessments, document reviews, inspection of facilities, worker interviews, and supply-chain due diligence. Suppliers must cooperate fully and provide accurate information.

Violations of this Code may result in the requirement to implement corrective measures, suspension of business, termination of contracts, and potential legal action. Landcent may also require suppliers to correct deficiencies within a defined period.

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9. Continuous Improvement

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This Code is reviewed regularly to ensure continued alignment with evolving legal and ethical standards. Suppliers are expected to adapt their practices accordingly and proactively to work toward improvements in labour, safety, environmental performance, and ethical conduct.

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10. WHO Prequalification programs and Global Tender Compliance

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Annex A forms an integral part of this Supplier Code of Conduct and is mandatory for all suppliers, subcontractors, and business partners involved in WHO Prequalification programs and Global Tenders. Suppliers must ensure full adherence to the requirements outlined in Annex A when participating in any procurement, manufacturing, or distribution activities related to these programs.

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11. Acknowledgment and Acceptance

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I acknowledge that I have received, read, and understood the Landcent Supplier Code of Conduct and agree to comply with its principles and related policies. I understand that failure to comply may result in corrective action or termination of business relations.

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Annex A: WHO Prequalification and Global Tender Compliance Provisions

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1. Purpose and Applicability

This Annex forms an integral part of the Landcent Supplier Code of Conduct and applies to all Suppliers involved in the production, testing, storage, or distribution of products or components intended for:

• WHO Prequalification (WHO PQ) assessment or maintenance
• Inclusion in international or national tenders supported by WHO, UN agencies, Global Fund, or other global health partners, or
• Regulatory submissions or donor-funded projects requiring compliance with WHO or UN procurement standards.

These provisions supplement, and do not replace, the obligations set out in the core Code.

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2. Regulatory and Quality System Compliance

Suppliers shall operate in accordance with current Good Manufacturing Practices (cGMP), Good Distribution Practices (GDP), and other applicable Good Practices (GxP) as recognized by WHO, relevant national authorities, or ICH guidelines.
Suppliers must:

• Maintain quality management systems that meet WHO PQ expectations and applicable ISO standards (e.g., ISO 9001, ISO 13485).
• Ensure that raw materials, intermediates, and finished products are fully traceable throughout the supply chain.
• Provide timely access to documentation, validation data, and quality records when requested by Landcent or WHO Prequalification team representatives.
• Promptly notify Landcent of any product deviation, out-of-specification (OOS) result, or regulatory inspection finding that may impact product quality, safety, or compliance.

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3. Cooperation with WHO and Regulatory Audits

Suppliers shall cooperate fully with audits, inspections, or assessments conducted by Landcent, WHO PQ inspectors, or relevant authorities. This includes:

• Granting access to facilities, personnel, records, and quality systems upon reasonable notice;
• Implementing agreed corrective and preventive actions (CAPAs) within defined timelines;
• Informing Landcent immediately of any pending or completed regulatory inspection relevant to WHO PQ products.

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4. Product Integrity and Data Management

Suppliers must maintain complete, accurate, and contemporaneous records in compliance with WHO data integrity guidance and GxP principles. Electronic systems must ensure:

• Data accuracy, security, and audit trails;
• Restricted access and accountability for changes;
• Retention of manufacturing and testing data for the period required under WHO PQ and national regulations.

Any falsification, concealment, or alteration of data is strictly prohibited and will result in termination of business relations.

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5. Post-marketing Pharmacovigilance and Incident Reporting

Suppliers involved in the manufacture or supply of medical products must:

• Establish systems for monitoring, documenting, and reporting adverse events, product complaints, and recalls in accordance with WHO and national requirements;
• Notify Landcent of any safety-related concern or event or regulatory alert without delay;
• Cooperate in root cause analysis, recall coordination, and post-market surveillance where applicable.

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6. Ethical Conduct in WHO and Donor-Funded Tenders

Suppliers must conduct all tender-related activities with honesty, transparency, and fairness. Specifically, Suppliers shall:

• Abstain from bid-rigging, collusion, misrepresentation of qualifications, or offering inducements to officials;
• Adhere to the UN Supplier Code of Conduct (latest edition) and WHO’s Guidelines on Ethical Principles for Procurement;
• Disclose any potential conflicts of interest that may arise during tender or evaluation processes.

Any violation of tender ethics may result in disqualification and reporting to relevant authorities or donor organizations.

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7. Environmental, Health, and Safety (EHS) Compliance

Suppliers shall maintain EHS standards aligned with applicable ISO standards (ISO 14001, ISO 45001) to ensure a safe and healthy workplace in addition to achieving smooth manufacturing operation of medical products in the scope of WHO prequalification. This includes:

• Safe handling and disposal of hazardous substances;
• Wastewater and emissions control;
• Pollution prevention, energy efficiency, and resource conservation measures;
• Occupational safety programs that protect employees and local communities.

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8. Supply Chain Transparency

Suppliers must disclose the use of subcontractors or critical third-party manufacturers involved in WHO PQ or tender-scope activities. All subcontractors must meet equivalent standards as set out in this Code and Annex. Suppliers shall not source from entities prohibited or sanctioned by the United Nations or national authorities.

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9. Continuous Quality Improvement and Training

Suppliers are encouraged to establish internal training and continuous improvement programs on GMP, ethics, data integrity, and EHS compliance. Landcent may offer or recommend training modules to strengthen supplier capacity in WHO PQ-related compliance.

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10. Breach and Corrective Action

Failure to comply with this Annex constitutes a breach of the Landcent Supplier Code of Conduct and may result in:

• Corrective action requests,
• Suspension or termination of contracts,
• Reporting to WHO PQ, donor agencies, or regulatory authorities where required.

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Suppliers must cooperate fully in investigating and rectifying any non-conformance.

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11. Acknowledgment and Acceptance

This Annex shall be read and signed together with the Landcent Supplier Code of Conduct. By signing below, the Supplier acknowledges understanding of and commitment to comply with the additional requirements applicable to WHO PQ and tender-related activities.