Amgen's Commitment to Business Ethics

We embrace ethics and transparency, from the way we treat our staff and patients, to our emphasis on human rights, to our partnerships with suppliers. We are committed to conducting our business ethically and helping ensure that Amgen complies with the laws and regulations that govern our business and industry in all markets in which we operate.

Our Code of Conduct and Corporate Compliance Policies apply to all Amgen locations, affiliates and subsidiaries. All new staff are required to complete training on our Code of Conduct within 60 days of joining Amgen. Additionally, all staff receive annual training on the Code of Conduct to help ensure continuous understanding and adherence to our standards. Training and regular communications include instructions on how employees can raise concerns, ask questions or obtain guidance through various mechanisms including our Business Conduct Hotline.

Failure to comply with our Code of Conduct, Amgen policies or applicable laws can result in disciplinary action up to and including termination. Disciplinary action may also be taken when managers ignore misconduct or fail to correct it. In addition, managers provide feedback on employees' conduct in line with Amgen's Values – including Be Ethical – in annual employee performance reviews, which is a component of annual compensation decisions.

Speak Up Culture

Fostering a speak up culture is integral to our commitment to ethical business practices and transparent communication. We have multiple channels for employees to voice their concerns and ask questions confidentially (where permitted by law) and without fear of retaliation, including a dedicated Business Conduct Hotline. Our training programs and internal communications emphasize the importance of speaking up and provide guidance on how to raise issues. We thoroughly investigate reports as appropriate and are committed to ensuring there are no negative consequences for employees who voice concerns in good faith.

Risk Assessment and Assurance Activities

Amgen's Enterprise Risk Management (ERM) program operates to identify, assess, manage, report, and monitor enterprise-level risks that may affect our ability to achieve the Company's objectives. The ERM program is overseen by our Executive Vice President and Chief Financial Officer and is chaired by our Chief Compliance Officer. Annually, we evaluate the greatest risks to our business, their underlying risk drivers, and the associated mitigation activities, maturity and controls. Our Enterprise Risk Council, composed of senior leaders from all key functions, works to identify, assess, and monitor potential enterprise-level risks. Cross-functional teams use the results of these assessments to develop assurance plans, such as audit plans, and to implement mitigation procedures, as necessary.

In addition, Amgen conducts a Corporate Audit planning process which considers multiple inputs, including interviews and/or surveys with key operational and senior management leaders, scans of the external environment for emerging risks and industry trends, and results from investigations and regulatory and compliance reviews. We focus on the most significant risks for Amgen, including those areas that are experiencing large changes in staff or process. We use a risk-based approach to develop our annual audit plan. Within risk assessments, audits are assigned a frequency that correlates to risk ratings. The plan focuses on covering medium and high-risk areas generally over a three- to five-year cycle.

Supplier Due Diligence

Amgen is committed to a global supply chain that reflects our mission and values. In line with this commitment, we expect all third-party product and service providers with whom we engage to conduct their business in a sustainable and ethical manner that is in compliance with applicable laws and regulations and aligned with Amgen's Supplier Code of Conduct.

Our Supplier Code of Conduct is a requirement for all our third-party product and service providers and is incorporated into all purchase order terms and conditions, and contracts. We periodically perform additional due diligence and assessments (e.g., anti-bribery/anti-corruption) on select third parties throughout the year to ensure on-going alignment with our Supplier Code of Conduct. These activities help Amgen identify and address potential sustainability-related risks in our supply and product value chain. Amgen reserves the right to audit third parties against these expectations and to take additional actions, when necessary.

Letter from Nancy A. Grygiel, Amgen's Chief Compliance Officer

Nancy A. Grygiel,
Amgen's Chief Compliance Officer

As Amgen's Chief Compliance Officer and leader of our Worldwide Compliance & Business Ethics organization, I am humbled and honored to be responsible for helping shape our company's culture of ethics and integrity. At Amgen, we are driven by our mission to serve patients and we are guided by our Values.

We are privileged to be part of a company that develops and delivers medicines to treat seriously ill patients. That privilege comes with great ethical and legal responsibilities. We support our mission by conducting business ethically and ensuring compliance with the laws and regulations that govern our business and industry. Amgen's leadership, including its Board of Directors, is committed to promoting an ethical culture. We know it's not just what we do, but how we do it that matters.

There are a number of resources available to help everyone at Amgen do the right thing and act ethically, including: our Code of Conduct – which all staff are required to complete training on annually; compliance websites and additional role-based training courses; our compliance policies; and the Business Conduct Hotline which provides a direct connection to raise concerns, ask questions, or obtain guidance.

I invite you to learn more about our Worldwide Compliance and Business Ethics program by visiting the links below.