The constant relevance of the environment in which SPECIALTY LAB SpA operates, the diversity of markets and healthcare sectors in which it operates, as well as the constant interaction with clients, suppliers, patients, and other market players, expose the company to various risk situations.
The dynamic nature of the environment in which Specialty Lab SpA operates, the diversity of markets and healthcare sectors in which it participates, and its constant interaction with clients, suppliers, patients, and other market players expose the company to various risk situations.

This context creates the need to establish the fundamental principles of an anti-corruption framework that effectively addresses the main legal, reputational, and economic risks associated with the commercialization of pharmaceutical products through our sales representatives and Business-to-Business (B2B) operations.
The purpose of this document is to define the principles that guide the conduct of all employees, officers, and directors of Specialty Lab SpA in the prevention, detection, investigation, and remediation of any corrupt practices within the company.

This policy applies to all employees, officers, and directors of Specialty Lab SpA, as well as to any third parties acting on its behalf.

DEFINITIONS

• Corruption: Any act or omission that, through the abuse of position or authority, seeks to obtain an improper benefit for oneself or a third party.
• Bribery: The offer, promise, giving, solicitation, or acceptance of any financial or other advantage to improperly influence the decision-making of a person or entity.
• Improper benefit: Money, gifts, travel, entertainment, discounts, donations, sponsorships, or any other favor that is not reasonable, proportionate, or legitimate.

GUIDING PRINCIPLES AT SPECIALTY LAB SpA
At Specialty Lab SpA, we are committed to ensuring that our corporate conduct aligns with the following principles:
1. Zero tolerance for any form of corruption or bribery.
2. Strict compliance with the applicable legal framework, particularly Chilean legislation and health regulations governing the sale of pharmaceutical products.
3. Transparency in all commercial and corporate relationships.
4. Shared responsibility, meaning that all employees are accountable for preventing, identifying, and reporting any potential misconduct.

RULES OF CONDUCT

The following rules of conduct are mandatory for all employees, officers, and representatives of Specialty Lab SpA:

1. Absolute prohibition on offering, promising, paying, accepting, or soliciting bribes, directly or indirectly.
2. Prohibition on providing gifts, courtesies, invitations, or benefits that could inappropriately influence a commercial, medical, or regulatory decision.
3. Prohibition on facilitating payments, defined as small payments intended to expedite administrative processes.
4. All interactions with public officials or government authorities must be conducted in strict compliance with the law and documented in writing.
5. All sponsorships, donations, and marketing activities must comply with Chilean regulations and have prior written internal authorization.

RECORDS AND INTERNAL CONTROLS

All expenses, payments, and benefits granted to third parties must be accurately recorded and supported by appropriate documentation. Specialty Lab SpA will maintain effective internal control systems to prevent, detect, and report suspicious transactions or irregularities.

REPORTING AND WHISTLEBLOWER PROTECTION
Specialty Lab SpA maintains a confidential and anonymous reporting channel available to employees, contractors, and third parties through its website www.specialtylab.cl.All reports will be treated with strict confidentiality, and no person who reports a potential violation in good faith will face retaliation.

SANCTIONS
Noncompliance with this Anti-Corruption and Bribery Policy may result in disciplinary measures, including termination of employment or commercial relationships, as well as the initiation of legal proceedings where applicable.

REVIEW
This Anti-Corruption and Bribery Policy will be reviewed at least once a year or whenever regulatory or business model changes occur, to ensure its ongoing adequacy and effectiveness.