Corporate Compliance Program

BeiGene, Ltd. and its affiliates (“the Company”) is committed to conducting our business in an ethical and legal manner with the highest level of integrity.

To foster compliance with the laws, industry guidelines, and BeiGene standards applicable to the development, manufacturing, marketing, and sale of our products, the Company has established a comprehensive Compliance Program. Our Compliance Program has been structured to reflect the legal and regulatory requirements, industry guidance and best practices in the countries where we operate, such as those recommended by United States Department of Health and Human Services Office of Inspector General’s ("OIG") "Compliance Program Guidance for Pharmaceutical Manufacturers" ("OIG Guidance").

The purpose of our Compliance Program, which is codified in our Company’s Global Code of Conduct, is to (1) prevent, detect, and remediate violations of laws, rules, regulations, as well as BeiGene policies and procedures and (2) promote a culture of the highest ethics within the organization. We have tailored our Compliance Program to fit the unique environment and risks of our Company. The Company has appointed a Chief Compliance Officer with primary responsibility for developing, operating and maintaining the effectiveness of the Compliance Program, including the provision of periodic reports to senior Company leadership.

As the OIG Guidance recognizes, however, the implementation of a Compliance Program cannot guarantee the elimination of improper employee conduct. As such, the Company seeks to continually improve our Compliance Program and encourages open lines of communication with both internal and external stakeholders. Accordingly, the Company offers a global helpline and web portal to report suspected violations of Company policies, laws or ethical concerns. Reports can be made anonymously and without fear of retribution 24 hours a day, seven days a week. All allegations or reports are reviewed, and where appropriate, investigated so that appropriate corrective action can be taken when warranted.

Our Compliance Program is designed to meet our culture of quality and ethics and remains dynamic to meet our evolving compliance needs.

Click here to download a copy of BeiGene’s Global Code of Conduct.

California Declaration of Compliance

As part of BeiGene’s commitment to corporate compliance, we declare that, to the best of our knowledge, and based on a good faith understanding of the statutory requirements of California Health and Safety Code § 119400 and 119402, that BeiGene has developed a Global Compliance Program for our commercial operations as required by the Code. To the best of our knowledge, as of November 1, 2020, BeiGene believes that it is in compliance with its Comprehensive Compliance Program and its good faith understanding of the requirements of California Health and Safety Code § 119400 and 119402.

BeiGene has also established a total annual dollar limit on items of value (including meals) that the Company may provide to California Healthcare Providers (“HCPs”) in accordance with California Health & Safety Code § 119400 and 119402. Our established annual aggregate limit per California HCP is $2,500. This annual limit may be revised by the Company from time to time. Per California Health and Safety Code § 119400 and 119402, the annual aggregate limit does not apply to drug samples provided to HCPs that are intended for free distribution to patients and payments for legitimate professional services provided by an HCP.

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

Compliance Helpline

BeiGene is committed to fostering an environment of open communication that encourages employees to ask questions about the Code of Conduct, Company policies and procedures or concerns about suspected improper business practices. Our employees understand they have an obligation to speak up when they have questions or concerns about potential violations, unethical behavior or any other alleged contravention of our Code of Conduct and company policies.

Employees are encouraged to ask questions about compliance issues or make reports of potentially problematic conduct to their managers. Employees can report concerns to leadership, as well as Human Resources, or Legal and Compliance. We maintain a helpline available 24 hours a day, 7 days a week, 365 days a year to employees and the public globally, subject to local law, online at BeiGene Ethics Point. BeiGene’s helpline is administered by an independent outside contractor whose employees are trained to handle such calls.

BeiGene expressly prohibits retaliation or retribution against any employee for making any good faith report of suspected misconduct or improper behavior.