Code of Ethics and Conduct Policy

The ethical principles and rules of conduct that apply at Critica Solutions, including anti-bribery and corruption and respect for human rights.

Document no.
POL-QM-02
Revision
01
Effective
5 September 2026
Approved by
Firas M. Yahia, Chief Executive Officer

Purpose

This policy sets out the ethical principles and rules of conduct that apply at Critica Solutions, including anti-bribery and corruption and respect for human rights, to protect patients, customers and the company’s reputation.

Scope

It applies to all company employees, managers, drivers and couriers, and to agents, suppliers, carriers, customs brokers and consultants acting on its behalf.

Responsibilities

  • Chief Executive Officer: approves the policy, provides resources for its implementation and decides on violations.
  • Quality Manager: acts as Compliance Officer, makes employees aware of the policy, receives and follows up reports, and presents results at management review.
  • All employees and those acting on behalf of the company: comply with the policy and report any violation.

Definitions

  • Bribery: offering, giving, requesting or accepting any benefit to improperly influence a decision or the performance of a duty.
  • Facilitation payments: small unofficial payments made to speed up a routine government action.
  • Public official: anyone working for a government, regulatory or customs authority or at a port.
  • Conflict of interest: any personal interest that affects, or may affect, an employee’s impartiality at work.

Review

The policy is reviewed annually at management review and upon changes to relevant regulations.

Our Code of Ethics and Conduct

Critica Solutions is committed to conducting its business with integrity and honesty, complying with regulations, and having zero tolerance for bribery, corruption and forced labour. To achieve this, we are committed to:

First: Ethical principles

  • Patient safety first; no commercial interest takes priority over product safety.
  • Honesty and accuracy in records, data and reports, with no falsification or concealment.
  • Compliance with Saudi regulations and the requirements of the Saudi Food and Drug Authority and other regulatory authorities.
  • Fair and transparent dealing with customers, suppliers and authorities.

Second: Anti-bribery and corruption

  • We do not offer, give, request or accept a bribe, directly or through others, and we make no facilitation payments, including those requested at ports and customs.
  • No gift, hospitality or benefit is given to or accepted from any public official or regulatory or customs authority.
  • With private parties, only token gifts (such as promotional items bearing the company logo) and customary business hospitality are allowed, with no cash or cash equivalents, provided they do not influence any decision. Any gift or hospitality outside this is reported to the Quality Manager and accepted only with the approval of the Chief Executive Officer.
  • Agents, customs brokers and carriers must comply with this policy; no business is conducted with a party that refuses to comply.
  • We do not tolerate fraud or money laundering, and all financial transactions are recorded accurately.

Third: Rules of conduct

  • Employees disclose any conflict of interest to the Quality Manager as soon as they become aware of it and do not take part in the related decision.
  • Customer, patient and company information is kept confidential and used only for business purposes, in accordance with the Personal Data Protection Law.
  • Company assets and systems are used for business purposes only, and safety and security rules are followed.

Fourth: Human rights and working conditions

  • We do not accept forced labour, child labour or human trafficking, in the company or its supply chain.
  • Employees’ passports or identity documents are not withheld, workers do not bear recruitment fees, and wages are paid in full and on time.
  • We provide a safe and fair working environment free from discrimination and harassment.

Fifth: Suppliers and partners

  • Suppliers and partners are informed of this policy at qualification, and their compliance is a condition of their approval and continued business.

Sixth: Reporting and non-retaliation

  • Any violation or suspicion is reported to the Quality Manager or the Chief Executive Officer; reports are handled confidentially, and no retaliation is taken against anyone who reports in good faith.

Seventh: Training, acknowledgement and consequences

  • Employees are trained on this policy on joining and annually, and sign an acknowledgement of having read it and agreeing to comply.
  • Violations lead to disciplinary action, up to termination of employment or of the business relationship, and reporting to the competent authorities where required.

References

  • Anti-Bribery Law – Kingdom of Saudi Arabia.
  • Anti-Money Laundering Law – Kingdom of Saudi Arabia.
  • Anti-Trafficking in Persons Law – Kingdom of Saudi Arabia.
  • Labour Law – Kingdom of Saudi Arabia.
  • Personal Data Protection Law – Kingdom of Saudi Arabia.
  • SFDA Good Storage and Distribution Practice (GSDP) – Personnel, item 7.
  • ISO 9001:2015 – Clause 5.1: Leadership and commitment.

Questions about this policy, or want to report a concern? Email info@critica-sol.com. Reports are handled confidentially, and no one who reports in good faith faces retaliation.

This page is the public version of controlled document POL-QM-02, revision 01. The controlled copy is kept in the Critica Solutions quality management system.

Related policy: Quality Policy