Ethical Standards

Ethical Standards

We are committed to conducting our business with integrity and the pursuit of excellence in all that we do. Our management team and our Board of Directors are committed to honesty and compliance with all laws, rules, regulations and corporate policies that apply to our business, and we expect the same commitment from our employees, consultants, business partners and service providers. In particular, we are committed to acting responsibly, safely and with transparency in our interactions with patients, doctors and other stakeholders in the healthcare system.

Everything we do at Jazz is focused on three things: Putting patients first, being a great place to work and living our values:

values

Compliance Hotline

Jazz Pharmaceuticals has established various methods of confidential communication for our employees, vendors and others to report suspected violations of laws, rules, regulations or company policies.

To email us: compliance@jazzpharma.com

North America: 1-800-511-2034
Austria: 0800-291870
Belgium: 0800-77004
Canada (English): 1-800-511-2034
Canada (French): 1-855-350-9393
Denmark: 80-83-00-37
Finland: 0800-413615
France: 0800-902500
Germany: 0800-1016582
Ireland: 1-800615403
Italy: 800-786907
Netherlands: 0800-0226174
Norway: 800-24-825
Poland: 0-0-800-1211571
Portugal: 8008-12499
Spain: 900-991498
Sweden: 020-88-85-98
Switzerland: 0800-564-839
United Kingdom: 0800-032-8483

To write to us: Jazz Pharmaceuticals plc
c/o Jazz Pharmaceuticals, Inc.
3170 Porter Drive
Palo Alto, CA 94304
Attn: Chief Compliance Officer

Comprehensive Compliance Program

Compliance with applicable laws, rules and regulations in the countries where we do business is an overriding principle of Jazz Pharmaceuticals’ corporate culture. The company’s commitment to ethical behavior is implemented through comprehensive compliance policies, employee training and monitoring programs and an open-door policy for reporting suspected violations. Read more about our Compliance Program below.

Comprehensive Compliance Program

For questions about our Comprehensive Compliance Program or to obtain a copy, please contact us at compliance@jazzpharma.com.

Code of Conduct

On February 14, 2019, the Board of Directors of Jazz Pharmaceuticals plc amended and restated the Code of Conduct that applies to all of Jazz Pharmaceuticals’ directors and employees (“Covered Personnel”). The principal purpose of the amendment and restatement was to provide additional guidance to Covered Personnel regarding the appropriate process to follow to disclose potential conflicts of interest, remove provisions related to disclosure of related party transactions, add a section on “Privacy and Information Security,” revise the section on “Competitive Intelligence” to more clearly describe the company’s policy, clarify certain provisions related to corporate political contributions and activities, allow for delegation by the General Counsel and Chief Compliance Officer of certain responsibilities, eliminate policy statements that are now captured in other corporate policy documents and make certain other technical and administrative changes. The revisions to the Code of Conduct did not relate to or result in any waiver, explicit or implicit, of any provision of the Code of Conduct in effect prior to its amendment and restatement.

Code of Conduct (English Version)
Codice di Condotta (Versione Italiana)

Anti-Corruption Policy

Jazz is committed to comply with applicable anti-corruption and anti-bribery laws, including the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act (UKBA). To help ensure compliance with these laws, Jazz has adopted a global Anti-Corruption Policy that applies to all employees of the company, its subsidiaries and affiliates, and third party vendors and other agents acting on our behalf.

Anti-Corruption Policy

Supply Chain Transparency

Slavery and Human Trafficking Statement – 2021
Jazz Pharmaceuticals plc and its subsidiaries (“Jazz” or “the Company”) are committed to operating our global business with integrity and upholding a high level of ethical conduct among our employees and business partners. We expect that suppliers which provide materials for use in our tangible goods for sale (“Product Suppliers”) to adopt sound human rights practices, to treat workers fairly, with dignity and respect and in all cases to eliminate human trafficking and slavery in their workplace.

Verification: Jazz has existing procedures for assessing our Product Suppliers and has enhanced these procedures to include steps for evaluating whether our Product Suppliers comply with applicable laws related to eradication of human trafficking, slavery and illegal child labor. Our Supply Chain and Quality Assurance teams oversee these verification procedures using an internally-developed multi-part assessment. In addition, Jazz has adopted written Standards of Conduct for Supply Chain and will request that our Product Suppliers certify that they comply with applicable laws concerning human trafficking, slavery and illegal child labor in the countries in which they do business.

Audits: Jazz conducts periodic and regular announced audits of its Product Suppliers to evaluate their compliance with Jazz’s policies and applicable legal and regulatory requirements. Jazz typically conducts such audits using its own personnel, although it reserves the right to engage an independent third party auditor. Jazz’s current Contract Manufacturer Assessment Guidelines establish procedures for audits of potential and existing Product Suppliers, including their training, experience and qualifications, adherence to legal and regulatory requirements, and evaluation of the suppliers’ compliance with quality systems. Jazz tracks any observations and/or non-compliance in its Audit Follow Up & Close-Out procedures to ensure that instances of non-compliance are properly remediated. Jazz has updated its Contract Manufacturer Assessment Guidelines to expressly address human trafficking, slavery and illegal child labor in its auditing protocol.

Materials: Jazz is in the process of implementing procedures that will require Product Suppliers to certify that materials incorporated into Jazz’s products comply with the laws regarding human trafficking, slavery and illegal child labor in applicable countries.

Accountability Standards: Jazz is in the process of establishing internal accountability standards and procedures, including disciplinary action for its employees and contractors with procurement responsibilities who fail to meet Jazz’s standards regarding identification and elimination of human trafficking, slavery and illegal child labor in its supply chain.

Training: Jazz has developed and conducts training for its employees and management who have direct responsibility for supply chain management, particularly with respect to mitigation risks of human trafficking, slavery and illegal child labor within the supply chain.

Tax Strategy

Jazz Pharmaceuticals is committed to compliance with tax law and practice globally. We understand that we have a responsibility to pay the appropriate amount of tax in each jurisdiction in which we operate. At the same time, we seek to balance this with our responsibility to our shareholders to deliver value by structuring our tax affairs in a tax efficient manner.

Jazz Pharmaceuticals has prepared and published its tax strategy in compliance with Schedule 19 to the UK Finance Act 2016.

Jazz Pharmaceuticals Tax Strategy

ANZ Industry Guidelines

Jazz ANZ adheres to the requirements of MA Code of Conduct and MNZ Code of Practice.

Medicines Australia: https://www.medicinesaustralia.com.au/.

Medsafe the New Zealand Medicines and Medical Devices Safety Authority: https://www.medsafe.govt.nz/.