Applies to: Employees, Contractors, Directors, Suppliers, and Critical Third Parties

Substance Global is committed to conducting business ethically, responsibly, and transparently. This Code establishes the standards of behaviour expected across our organisation and supply chain, ensuring integrity, accountability, and responsible commercial practice — particularly within regulated sectors such as healthcare and pharmaceuticals.

All employees, contractors, and critical third parties are expected to understand, follow, and uphold this Code.

We commit to:

• Acting with honesty, integrity, and transparency
• Complying with all applicable laws and regulations
• Respecting human rights and fair labour practices
• Operating responsibly within regulated industries
• Promoting ethical marketing and responsible communications
• Preventing corruption, conflicts of interest, and improper conduct
• Providing safe channels to raise concerns without fear of retaliation

Substance Global maintains zero tolerance for bribery, corruption, fraud, or unethical conduct.

We prohibit:

• Offering, giving, or accepting bribes or improper incentives
• Facilitation payments or undisclosed commissions
• Fraud, misuse of company or client resources
• Conflicts of interest not properly disclosed
  

All employees and third parties must act in line with applicable anti-corruption laws and our internal policies.

Substance Global operates independently and does not engage in lobbying or political advocacy on behalf of clients or for commercial advantage.

• The company does not influence pricing, intellectual property, or access to medicines.
• Political contributions or public policy representation must be approved through governance controls.
• Employees must not represent personal political views as those of the company.

Substance Global is committed to ethical, responsible, and compliant marketing practices, particularly in regulated sectors.

We:

• Comply with all applicable advertising and healthcare communication regulations
• Avoid misleading, exaggerated, or unsubstantiated claims
• Do not use aggressive or manipulative marketing tactics
• Promote responsible communication aligned with regulatory frameworks
• Ensure marketing content is accurate, transparent, and socially responsible
  

Our role is to support informed awareness — not to create inappropriate demand or influence clinical decision-making.

Where we work with healthcare or pharmaceutical clients:

• We do not provide medical advice or influence prescribing behaviour
• All communications must comply with applicable healthcare and advertising regulations.
• Engagement with healthcare professionals must be transparent, ethical, and compliant
• We support responsible disease awareness and approved product communication only
• We operate within strict regulatory frameworks and ethical standards

Substance Global promotes responsible commercial practices.

• Incentives and performance measures are not based solely on client sales volume or product uptake
• Commercial success is balanced with quality, compliance, ethical conduct, and long-term value.
• We avoid aggressive marketing or practices that could mislead, pressure, or exploit audiences

Employees and partners must disclose any situation that could create a conflict between personal and company interests, including:

• Financial interests
• Outside employment
• Personal relationships impacting business decisions

Conflicts must be declared and managed appropriately.

This Code is enforced through company governance processes.

Breaches may result in:

• Investigation
• Disciplinary action
• Contract termination
• Legal escalation where required

The Code applies to employees, contractors, suppliers, and partners.

Substance Global encourages all stakeholders to raise concerns safely

• Concerns may be reported through the Grievance & Whistleblower channel
• Anonymous reporting is permitted where feasible
• Retaliation against any individual raising a concern in good faith is strictly prohibited
• All concerns are handled confidentially and fairly

Where retaliation is identified, protective action will be taken.

To ensure this Code is embedded in practice:

• Employees receive training on ethical conduct and responsible business practices
• Refresher training is provided periodically
• Suppliers and critical third parties are expected to comply with this Code
• Training and compliance are documented

This Code is overseen by senior leadership and reviewed annually

The company will:

• Monitor compliance
• Investigate breaches
• Update policies as required
• Maintain transparent and responsible governance

Substance Global is committed to operating with integrity, transparency, and responsibility — supporting ethical business, responsible communications, and positive societal impact.

All employees and partners share responsibility for upholding this Code.