ANNUAL REPORT 2021

LUNDBECK ANNUAL REPORT 2021 = CONTENTS 40/111 BUSINESS ETHICS AND CODE OF CONDUCT https://www.lundbeck.com/global/sustainability/responsible-business-conduct ** https://www.lundbeck.com/global/compliance-hotline We pursue our business purpose guided by our Code of Conduct that forms a fundamental part of our Sustainability Strategy. The Code of Conduct conveys Lundbeck's commitments and the expectations to its employees for areas that are critical to the pharmaceutical industry. In 2021, we consolidated the global standards that assist us in upholding the Code of Conduct into a concise Compliance Program. It outlines the needed governance and continuous activities, for instance the annual assessment of risk, training, and monitoring, as well as management's review of the program's effectiveness. It builds on the trust we have in our employees and is founded on our core belief "Responsible - we act with respect and integrity in everything we do". ETHICS BROUGHT TO LIFE BY PEOPLE Our ethics are formed at the top in the Compliance Committee with Executive Management members and key compliance functions who review and maintain Lundbeck's ethical standards. The translation into operational requirements is driven by our Global Compliance Organization consisting of Headquarter compliance functions and the 17 Regional Compliance Officers who represent our global affiliates. Collectively, they help prevent misconduct, detect compliance issues and take prompt corrective and preventive action. They support Lundbeck's Senior Management who are held accountable for ethics and compliance within their organization. Every year, we invest in the development of global awareness campaigns and specific compliance training. We involve people from the global organization in the development to keep the initiatives relevant, engaging and ensure people know how to act. Our audits and monitoring efforts aim to validate the understanding of the requirements and capture suggestions for improvements of processes and controls. Specific feedback is provided to ensure local management ownership and follow-up. Lastly, our Chief Compliance Officer provides regular briefings on current developments at meetings within the Board of Directors and more detailed within the Audit Committee. STAYING ATTUNED WITH SOCIETAL EXPECTATIONS The regulatory landscape Lundbeck operates in is constantly changing. The Compliance Programs help us stay attuned with societal expectations. As a recent example, we have defined our Data Ethics Policy in response to an update in the Danish Financial Statements Act. Our Data Ethics Policy states the principles we commit to apply beyond staying compliant with current data protection regulations. It is especially relevant in the development or application of fast-moving, innovative digital technologies. The Data Ethics Policy will help us make ethical and responsible decisions on the use of data with maximal benefit and minimal harm for individuals and society. You can read more and find our Data Ethics Policy on Lundbeck.com*. OPEN DIALOGUE AND ACCESS TO RAISING CONCERNS We encourage everyone to have ongoing dialogue on compliance and ethics with their colleagues and manager. However, we realize that some questions, dilemmas or concerns might not be discussed openly. Our Compliance Hotline** is a secure line that is open for everyone to raise concerns about a potential violation of the Code of Conduct. It is a cornerstone in our Compliance Program that helps protecting Lundbeck. All reports are investigated in line with our global procedure that safeguards individuals who report concerns, participate in investigations or are suspected of misconduct. Our investigations are guided by principles that manifest Lundbeck's beliefs, including: • • Protection of good-faith reporters against retaliation • Confidentiality • Cooperation Proportionality • Communication

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