Code of Conduct

Each employee of Axovant is expected to follow our Code of Business Conduct and Ethics, and abide not only by its letter but also by its spirit. We have a duty to those we deal with and serve—our patients, our stakeholders, our business partners, and our competitors—and we owe it to them to act with integrity at all times.

Open Door Policy and Non-Retaliation

It is our policy to promote high standards of integrity by conducting our affairs in an honest and ethical manner. Axovant’s integrity and reputation depend on the honesty, fairness, and integrity brought to the job by each person associated with Axovant. Unyielding personal integrity is the foundation of corporate integrity. Axovant expects everyone to understand and obey the law and regulations applicable to their business units and areas of responsibility. Axovant’s Code of Conduct is available below:

AXOVANT SCIENCES LTD. – CODE OF BUSINESS CONDUCT AND ETHICS

Axovant Sciences Ltd. and its affiliated companies (collectively “Company”) are committed to creating an environment where we are able to do our best work while maintaining the highest standards of business conduct and ethics. This Code of Business Conduct and Ethics (the “Code of Conduct”) reflects the business practices and principles of behavior that support this commitment. We expect every director, officer, employee, consultant and independent contractor (collectively, “personnel”) to read and understand the Code of Conduct and its application to the performance of his or her business responsibilities.

The Code of Conduct addresses conduct that is particularly important to proper dealings with the people and entities with which we interact, but reflects only a part of our commitment. From time to time we may adopt additional policies or procedures with which our personnel are expected to comply, if applicable to them. Where there is no stated guideline in the Code of Conduct or otherwise, it is the responsibility of each employee, consultant and independent contractor to apply common sense, together with his or her own highest personal ethical standards, in making business decisions.

By working at the Company, you agree to comply with the Code of Conduct, and to revisit and review it regularly and whenever we notify you of any material updates. If you don’t agree to comply, please let us know immediately. Violations of the Code of Conduct will not be tolerated. Any employee, consultant or independent contractor who violates the standards in the Code of Conduct may be subject to disciplinary action. You should not hesitate to ask questions about whether any conduct may violate the Code of Conduct, voice concerns or clarify gray areas.


View or download Axovant’s complete “CODE OF BUSINESS CONDUCT AND ETHICS” PDF document


Our Open Door Policy encourages all employees to ask questions and raise concerns. Axovant is committed to creating an environment where everyone can do their best work while maintaining the highest standards of business conduct, ethics, and integrity. Violations of the Code of Conduct will not be tolerated. All senior management, including the CEO, are available to employees for questions or concerns, at any time. There will be no retaliation for reporting or raising good faith concerns about a suspected violation of our Code of Conduct.
 

Axovant’s Code of Conduct covers many areas of compliance, including:

  • Insider Trading. Employees and other affiliates are prohibited from trading on or disclosing material non-public information.
  • International Business Laws. Employees and other affiliates are expected to abide by all national and international laws regarding business conduct, including those related to improper payments or gifts.
  • R&D Compliance. Employees and other affiliates must understand and follow healthcare laws, FDA regulations, and other requirements scrupulously.
  • Confidential Information. Employees and other affiliates must treat the confidential information belonging to Axovant or its affiliates, or to third parties, appropriately to avoid improper disclosure or use.1
  • Conflicts of Interest. Employees and other affiliates are required to avoid actual or potential conflicts of interest, and disclose and address them appropriately at all times.
  • Financial Reporting. Employees and other affiliates must ensure the validity, accuracy, and completeness of information in Axovant’s records and public disclosures.
  • Duty to Report. Employees, consultants or independent contractors who become aware of any potential violation of the Code of Conduct have a responsibility to appropriately report their knowledge promptly and appropriately.

 

Axovant is committed to treating others with fairness and respect:

  • Equal Employment Opportunity and Anti-Discrimination Policy. Axovant is an equal opportunity employer. We prohibit discrimination and harassment of any type and are committed to affording equal employment opportunities to employees and applicants, without regard to race, color, religion, sex, sexual orientation, marital status, national origin, age, disability, predisposing genetic characteristics, veteran status or any other factor classification prohibited by applicable federal, state and local laws.
  • Anti-Harassment Policy. Axovant is committed to ensuring that our employees work in an environment free of any type of unlawful discrimination and/or harassment, including sexual harassment.

 


1Nothing in Axovant’s Code of Conduct or policies is intended to prohibit or restrict employees from initiating communications directly with, or responding to any inquiry from, or participating in any investigation or proceeding by any federal or state regulatory authority or self-regulatory authority, without notice to the Company. In addition, pursuant to the federal Defend Trade Secrets Act of 2016, employees shall not be held criminally or civilly liable under any federal or state trade secret law for the disclosure of a trade secret that (a) is made in confidence to a federal, state, or local government official, either directly or indirectly, or to an attorney, and solely for the purpose of reporting or investigating a suspected violation of law; or (b) is made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal.