Corporate Compliance Policy

Conducting the Business According to Applicable Law and Company Rules

At Bayer we firmly believe that compliance is our license to operate worldwide. We all share the aim of providing people with innovative solutions that improve the quality of life.

Corporate Policy & Code of Conduct

At Bayer we manage our businesses responsibly and in compliance with the statutory and regulatory requirements of the countries in which we operate. We define compliance as legally and ethically impeccable conduct by all employees in their daily work, because the way they communicate and carry out their duties affects our company’s reputation.

The overriding objective for all communications and marketing activities and materials is to communicate in a manner that is honest, fair and respectful. Bayer will be held accountable for its public statements. Activities that tarnish the Bayer brand can have a strong negative impact on public perception.

Unethical, dishonest or otherwise inappropriate communications or marketing can severely undermine public trust in Bayer and its products, and impact both the Bayer brand and our overall business success.

The attached regulation is intended to guide employees involved in internal and external communications and in marketing at all levels throughout the Bayer Group – whether local, regional or global.

Policy Responsible Marketing & Sales

At Bayer we will adhere to ethical sales & marketing practices that meet the standards set by external regulations, codes of practices as well as company-specific regulations, most of all “The Bayer Corporate Compliance Policy”.

In the marketing of our products and services, Integrity means that we are committed to ethical sales & marketing practices that meet the standards set by external regulations & codes of practices. Furthermore, we commit ourselves to accurate and scientifically substantiated communication as well as to openness and transparency. Implementation and monitoring of procedures, systems and processes complete our commitment.

This Policy is valid for Bayer and all group companies and applies to all marketing activities and sales activities. All Bayer employees are asked to internalize the rules contained in this Policy and implement them fully into their daily business practices.

To comply with laws, regulations and good business practices

We are committed to ethical sales & marketing practices that meet the standards set by external regulations & codes of practices, in particular:

• all laws and regulations dealing with marketing practices
• all applicable global, regional and local industry codes relevant for our business
• privacy of customer or consumer information and data protection
• recommendation and promotion only of lawful uses, e.g. no off-label promotion for medicinal products.

In addition, we are committed to observe company-specific regulations, most of all “The Bayer Corporate Compliance Policy”. It draws attention to a number of principles that are of particular significance in practice and gives guidance to all Bayer employees world-wide.

To be honest and reliable

We are committed to accurate and scientifically substantiated communication, in particular:

• clarity: no misleading statements
• accuracy: all advertising to undergo internal review for accuracy & compliance
• transparency: evaluation of risks and proper information about any risk
  associated to our products in accordance with industry practices and relevant
  requirements.
• consistency of information irrespective of form and forum (e.g. press information,
  social media, customer letter).
• good ethical behavior and transparent business practices

To listen attentively and communicate appropriately

We are committed to openness and transparency, in particular:

• transparent product information
• implementation of efficient, reliable internal management systems
• responsible interaction with all Stakeholders groups
• transparent lobbying activities
• collect feedback and consider outside views

To care about people, safety and the environment

We are committed to implementation and monitoring of procedures, systems and processes, in particular:

• assess risks: regularly review marketing business operations to assure highest
  quality of our products as well as safeguarding people and the environment
• prevent: training in order to help employees understand laws and regulations as well as internal rules
• act: corrective actions where required and transparent reporting on reassessments
• change: adapt (including restrict) marketing of products to the extent required by risk assessments

Crop Science Code of Conduct

• All advertising materials and visual presentations of products
  must be free of sexist and military statements.
• Crop protection agents should never be depicted in the vicinity
  of food or children.
• Advertising must comply with national and international regulations.