2020-02-17

To our stakeholders:

I am pleased to confirm that Atlas Antibodies AB reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,
John Daicic
CEO

Atlas Antibodies AB operates and employs staff within the UN member state of Sweden which, through its UN membership, is bound to follow the Universal declaration of Human Rights in national legislation and politics. As a company we support the universal declaration of Human Rights and respect our national laws.

Our written policy on respecting Human Rights is included in our Code of Conduct effective 2018-06-18. This policy also includes our whistleblowing function for reporting potential abuses

All of our supplier and partnership agreements are updated to include our requirements for suppliers to follow our Code of Conduct upon their renewal.

A company overall risk analysis was performed in the end of 2018, on all factors that could affect our business negatively. This risk analysis is a living document that is continuously updated within the management team.

In Q3 of 2018 top critical suppliers were identified and supplier visits were performed in connection to follow-up on these suppliers. No risks to Human Rights abuses were identified during these supplier visits.

Specific goals in the area of Human Rights for the upcoming year (2020) are:
1) The company risk analysis will be revised for completeness of risks related to Human Rights within our operations through our procurement, operations and distribution processes. Risks will be mitigated in accordance of criticality based on an assessment of probability, impact and detectability.
2) Formal processes for supplier qualification and performance evaluation of suppliers will be put in place in 2020 through our ISO 9001 QMS implementation that is scoped to also include sustainability factors.

As a way for any of our stakeholders to report any suspected Human Rights abuses or grievances, our code of conduct encourages employees to report to management but there is also a whistleblowing function to an external law firm.

Our employees are all located within our operations within Sweden where Human Rights are generally adhered to as these are governed by law. Employees that are in contact with external operations, that may pose risk for Human Rights abuses, have been trained in sustainability, sustainable supply chains and supplier visits and audits.

For us to be able to understand the expectations of our stakeholders a stakeholder matrix has been created within our ISO 9001 QMS implementation initiative, which is scoped to also include sustainability factors. This matrix is a living document that is continuously revised.

The CEO is internally responsible for protecting Human Rights within the company and the Quality Assurance function is externally responsible for stating requirements for suppliers and performing periodic evaluation of supplier performance with regards to our requirements and contracts.

A revised work environment policy is to be approved by our board of directors, for subsequent implementation in Q1 of 2020.

Our most critical suppliers have been identified and contracted under terms to follow our Code of Conduct.

Identification of suspected Human Rights violations is made possible through informing our employees and training them on how to deal with Human Rights violations through implementation of the company Code of Conduct that was put in effect on 2018-06-18. All new employees receive training in the Code of Conduct as part of their on-boarding.

There have been no investigations, legal cases, ruling, fines or other relevant events related to Human Rights during this reporting period.

Senior management review has not yet been implemented but implementation is planned for Q3 of 2020 through our ISO 9001 QMS implementation.

In Q3 of 2018 we performed a supplier visit to our most critical suppliers without any identified Human Rights abuses.

External audits of our company's compliance with the UNGC and company policies may be performed in the future, though the focus for 2020 is to create a more detailed risk assessment and put effective actions in place to be fully compliant with the UNGC and our new policies on sustainability.

UNGC principles 3, 4, 5 and 6 are all governed by Swedish law to be complied by all companies that are operating in Sweden, which includes Atlas Antibodies AB.

At Atlas Antibodies, work environment requirements are implemented through a setup of policy, reporting and handling of work environment risks and incidents, participation from employee work environment representatives and a quarterly safety committee meeting where all relevant work environment functions and topics are included. Managers are delegated work environment tasks to be performed within their respective teams. We perform internal work environment risk analysis and inspections of our facilities to ensure that our work environment conditions are compliant and safe.

Our company policies on Labour Rights include our Code of Conduct effective 2018-06-18, together with new policies for work environment, equal treatment and sustainability that are to be approved by our board of directors in Q1 of 2020.

Employee Labour Rights are governed by Swedish law and compensation is governed by employment agreements. There is an employee handbook for management of employee benefits that is complemented by yearly bonus agreements.

All of our supplier and partnership agreements are updated to include our requirements for suppliers to follow our Code of Conduct upon their renewal.

A company overall risk analysis was performed in the end of 2018, on all factors that could affect our business negatively. This risk analysis is a living document that is continuously updated within the management team.

Overall we see little labour-related risks within our internal operations in Sweden but also within operations of suppliers and partners.

Specific goals in the area of Labour Rights for the upcoming year (2020) are:
1) The company risk analysis will be revised for completeness of risks related to Labour Rights within our operations through our procurement, operations and distribution processes. Risks will be mitigated in accordance of criticality based on an assessment of probability, impact and detectability.
2) Formal processes for supplier qualification and performance evaluation of suppliers will be put in place in 2020 through the ISO 9001 QMS implementation that is scoped to also include sustainability factors.

As a way for any of our stakeholders to report any suspected Labour Rights abuses or grievances, our code of conduct encourages employees to report to management but there is also a whistleblowing function to an external law firm.

Our employees are all located within our operations within Sweden where Labour Rights are generally well adhered to. Employees that are in contact with external operations, that may pose risk for Labour Rights abuses, have been trained in sustainability, sustainable supply chains and supplier visits and audits.

To prevent and identify any inconsistencies in comparable pay for comparable work, a yearly salary overview is performed and acted on by management under the lead of HR, as required by Swedish law.

For us to be able to understand the expectations of our stakeholders a stakeholder matrix has been created within our ISO 9001 QMS implementation initiative, which is scoped to also include sustainability factors. This matrix is a living document that is continuously revised.

The CEO is responsible for our operations complying with Swedish labour law and that we have policies and processes in place for our views, tools for management of Labour Rights factors together with our HR manager as advisor.

There are no company specific Labour Rights policies as Swedish labour law supercedes any local policy and is deemed in line with the UNGC principles.

Data on employee diversity factors are kept by the company as long as this data is not considered sensitive data, such as ethnicity or religion.

Any Labour Rights violation incidents are strictly governed by Swedish law and managed through proactive company policies and principles for equal treatment.

There have been no investigations, legal cases, ruling, fines or other relevant events related to Labour Rights during this reporting period.

Senior management review has not yet been implemented but implementation is planned for Q3 of 2020 through our ISO 9001 QMS implementation.

In Q3 of 2018 we performed a supplier visit to our most critical suppliers without any identified Labour Rights abuses.

External audits of our company's compliance with the UNGC and company policies may be performed in the future, though the focus for 2020 is to create a more detailed risk assessment and put effective actions in place to be fully compliant with the UNGC and our new policies on sustainability.

A first assessment of environmental footprint of the company operations has been performed for operations within Sweden, which identified that our environmental impact is relatively low as our batch production volumes are within a millilitre scale and our procurement volumes are on the litre level. Our major environmental impact was initially identified as caused by transport, consumption of energy and separation of waste.

Our company policies on Environment include our Code of Conduct effective 2018-06-18, and a sustainability policy that is to be approved by our board of directors in Q1 of 2020. This sustainability policy includes elevated awareness of environmental impact by management of company vehicles, consumption of resources and energy and management of waste including reusable materials, recycling and separation of hazardous waste.

All of our supplier and partnership agreements are updated to include our requirements for suppliers to follow our Code of Conduct upon their renewal.

Specific goals in the area of environmental protection for the upcoming year (2020) are:
1) To perform a more detailed assessment of the environmental footprint caused by the company.
2) To implement actions to be in full compliance with our sustainability policy mainly focused on the environmental impact of our operations within Sweden.

The new sustainability policy will be implemented through information and training of all staff.
This policy also includes raised levels of environmental requirements for procurement of material, management of waste as well as standards for consumption of energy, paper, water, electricity and use of company vehicles.

New requirements include minimizing consumption of electricity and energy which is mainly caused by lighting and bench-top equipment that are to be turned off at the end of the workday. Full loading of dishwashers and washing machines are stated as requirements to reduce consumption of electricity and water.

Development of technology that is more environmentally friendly is a future aim, though not prioritized for 2020 as we are focusing on new policies, detailed assessments and performing actions to mitigate currently known major risks to sustainability.

A future step is to widen our company ambitions for reducing environmental footprint of our suppliers' operations, though this is not in scope for 2020. We are currently updating supplier agreements with terms where they agree to follow our Code of Conduct which includes the ten principles of the UNGC.

Energy, electricity and water consumption as well as amounts of waste are monitored through billing statements from each service source. These resources will be monitored more closely as actions are put in place to be fully compliant with the new sustainability policy.

Compliance of sustainability factors overall, that are not governed by Swedish law, is the responsibility of the Quality Assurance department.

Management of environmental incident reporting will be introduced in 2020 as an action to be fully compliant with our sustainability policy.

There have been no investigations, legal cases, ruling, fines or other relevant events related to Environment during this reporting period.

Environmental impact factors will be included in the company performance evaluation through management review that is done by senior management.

Future supplier visits and audits will include sustainability topics as required by our company sustainability policy and supplier agreements. A future environmental certification according to ISO 14001 is possible but not prioritized for 2020.

External audits of our company's compliance with the UNGC and company policies may be performed in the future, though the focus for 2020 is to create a more detailed risk assessment and put effective actions in place to be fully compliant with the UNGC and our new policies on sustainability.

Based on our experience of working with our suppliers and partners we have not seen any signs of bribery or corruption. A formal risk assessment for bribery and corruption has not been performed yet, but we will update our company wide risk assessment to specifically address also these risks.

Our employees are all located within our operations within Sweden where corruption and bribery is generally rare in occurrence. Employees that are in contact with external operations, that may pose risk for bribery or corruption, have been trained in sustainability, sustainable supply chains and supplier visits and audits.

Our company policies on Anti-corruption includes our Code of Conduct effective 2018-06-18 and a sustainability policy that is to be approved by our board of directors in Q1 of 2020.

Our company has, through our CEO, clearly stated our support for the UNGC and its ten principles including anti-corruption principles. These principles are implemented in our company policies and in our affected processes.

All of our supplier and partnership agreements are updated to include our requirements for suppliers to follow our Code of Conduct upon their renewal.

Specific goals in the area of anti-corruption for the upcoming year (2020) are:
1) The company risk analysis will be revised for completeness of risks related to corruption within our operations through our procurement, operations and distribution processes. Risks will be mitigated in accordance of criticality based on an assessment of probability, impact and detectability.

As a way for any of our stakeholders to report any suspected corruption, our code of conduct encourages employees to report to management but there is also a whistleblowing function to an external law firm.

The company views on corruption is clearly stated in our Code of Conduct which is implemented by all staff and available for guidance.

The CEO is responsible for our operations complying with Swedish anti-corruption laws and that we have policies and processes in place for our views and tools for management of corruption factors.

So far we have not participated in any industry initiative or other collective actions against corruption but we are open to the possibility of participating in such an initiative. We have so far not seen a need for collective actions within our industry.

The company Code of Conduct clearly states how to deal with suspicion or incidents of corruption, including insider trading, money-laundering, and improper benefits.

Senior management review has not yet been implemented but implementation is planned for Q3 of 2020 through our ISO 9001 QMS implementation.

There have been no investigations, legal cases, ruling, fines or other relevant events related to corruption during this reporting period.

In Q3 of 2018 we performed a supplier visit to our most critical supplier without any identified risks or incidents of corruption.

External audits of sustainability factors and compliance with the UNGC and company policies may be performed in the future, though the focus for 2020 is to create a more detailed risk assessment and put effective actions in place to be fully compliant with the UNGC and our new policies on sustainability.