Ethical Values

• We comply with legal regulations and internal policies and procedures.
• We ensure that we apply high quality standards at every stage of the production process.
• We immediately report any concerns about product incompatibility.
• We immediately report customer complaints about our products to the Quality Management System Representative and Quality Control Officer.

• We do not offer or provide anything to a healthcare professional or an administrator for the purpose of improperly influencing them to recommend, sell or supply our products.
• We comply with local laws and regulations regarding promotion and marketing to healthcare professionals.
• We document our business justifications for our interactions with healthcare professionals.
• We record our marketing and sales expenses in accordance with our financial policies and procedures, accountable to legal authority where necessary.

• We only use approved promotional or educational materials.
• We only promote our products for locally approved uses as determined by local regulations.

• We obtain all necessary licenses and permits before exporting and importing.
• We make sure that all information in our import and export documents is accurate, complete and up to date.

• We conduct business fairly and honestly.
• We select business partners and suppliers based on their ability to meet GBL's interests, values, and needs, free from personal conflicts of interest.
• We follow our company's policies and procedures regarding the selection and management of suppliers and other business partners.
• We ensure that our suppliers understand our ethical expectations.
• We prepare all our offers, orders, and contracts in writing and preferably with wet signatures and stamps.

• We strictly avoid behavior that violates antitrust and similar laws regulating competition.
• Price fixing among competitors directly or indirectly violates antitrust laws and is strictly prohibited.
• We never agree not to participate in business competition, including agreements with competitors on how to divide markets (by region, product line or customers).
• We never discuss or agree to a request from a competitor or two or three distributors to divide territories, products, or customers.
• We h5ly oppose obtaining competitive information through illegal or unfair channels. We also do not agree to receive confidential information belonging to a third party without that person's express consent.
• We do not allow the use of comparisons of GBL products with similar competitive products in promotional or advertising campaigns unless the comparison is based on actual objective studies or data.

• We refuse to engage in corruption or any form of bribery.
• We must ensure that all parties doing business with us are aware of and adhere to our ethical standards with respect to corruption and bribery.

• We comply with internal financial policies and procedures.
• We do not make false, misleading, or deceptive entries.
• We provide accurate accounts, analysis, and information to relevant representatives so that assets and liabilities can be properly assessed.
• We ensure that we work with legitimate business partners who do not engage in criminal activity.
• We cooperate with our internal and external auditors.
• To avoid external fraud schemes, we always question the source of the request from a Legal, Ethical and Compliance perspective.

• We ensure that all commitments between GBL and third parties (individuals or companies) are documented in a written agreement, order form or other appropriate legal document.
• We ensure that the review, verification, final approval and signing of legal documents is in accordance with GBL's existing processes and procedures.
• We preserve and dispose of documents according to local legal requirements and our internal records retention policy.
• We carefully consider whether a record (such as an email) is necessary before writing. We remember that we must take responsibility for all documents we create.
• We create factual and objective information and documents that are not misleading or exaggerated.
• We think about all audiences (media, government, or our trading partners) who might read a record, intentionally and unintentionally.

• We process personal data in a lawful, fair, and transparent manner.
• We process the data we collect for specified, explicit and legitimate purposes.
• We process personal data in a manner that ensures its appropriate security.

• We perform our work safely.
• We do not put ourselves or others at risk.
• We know and apply the laws in areas subject to safety and environmental regulations and our relevant company policy.
• We strive to continuously improve health, safety, and environmental performance.
• We report hazardous conditions and other health, safety, or environmental conditions immediately.

• At GBL, we believe in and promote inclusion and diversity.
• We do not discriminate or harass anyone.
• We do not engage in any offensive behavior or threats against another employee.
• We respect fundamental human rights and labor law.

• Our employees have direct or indirect interests for themselves, their friends, or relatives.
• use their position to provide a personal benefit to the GBL. This includes taking advantage of an opportunity presented to GBL for the employee's personal benefit.
• Receiving gifts, bonuses, fees, commissions, or payments creates a conflict of interest for GBL employees. If a supplier, customer, or other business partner offers our employees something that could interfere with their ability to make a fair and impartial business decision, we will not accept it.
• Our employees do not accept or seek to avoid any situation in which relationships with friends or relatives may influence their ability to make subjective decisions.

• We comply with all environmental laws. We strive to continuously develop and improve our environmental management system to minimize our environmental impact.
• We identify, label, and manage environmentally hazardous chemicals and hazardous substances to ensure their safe handling, transportation, storage, recycling or reuse and disposal.
• We identify internal systems for early detection and assessment of potential environmental risks and take measures to mitigate or eliminate these risks where possible.

• We follow our Ethical Values when representing GBL in outside activities.
• We do not donate or pledge to donate personally or on behalf of GBL to a cause to gain a business advantage.
• We remember that donations made at the request of healthcare professionals or government officials are subject to special scrutiny.
• We do not force any employee or business partner to support a specific charitable initiative.

• We only share confidential information with internal employees who have a legitimate "need to know".
• We avoid discussing or disclosing confidential information in areas where it could be obtained by people who do not have an "information need".
• We comply with all internal and external security rules regarding information technology and facility access.
• We use this information appropriately and prevent its misuse or destruction in any way.
• We recognize that the data we create on GBL systems remains the property of GBL, except for information protected by local privacy regulations. We promptly report any incidents that could jeopardize the confidentiality of sensitive information.

• We protect our company's information systems access codes by not sharing them in any way.
• We do not apply malicious, pirated, or unapproved software to GBL information systems.
• We do not participate in security breaches or corruption of Information Systems components.
• We only send and store confidential information outside GBL if it complies with confidentiality rules.
• We do not use GBL information systems to actively participate in the provision or transfer of information or materials that violate our country's local regulations and laws.
• We do not lend our laptop to anyone without physical presence and control.

• We respect intellectual property rights.
• We respect the privacy and rights of third parties.