1the protocol

The Life Technologies ProtocolWe are responsible

the protocol

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3life technologies

life technologies enables people to accelerate scientific exploration, driving to discoveries and developments that make life even better.

our success depends on passion, intellectual curiosity, and a sense of urgency. We will strive for excellence and act with unyielding integrity in everything we do so that we can serve as responsible stewards in the global life science community and all of society.

shaping Discovery, improving life

life technologies, like every company, needs a quest—a common understanding of what we stand for now and what we want to become. our quest is our internal rallying cry and our external promise. it encompasses our past and addresses the promise of our future. it is what we strive to achieve for ourselves, our stakeholders, and our broader communities. our quest is shaping Discovery, improving life.

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contents 6. protocol overview

8. A note from Mark stevenson, coo

9. A note from greg lucier, ceo

12. commitment to integrity

14. integrity in the workplace

17. competition laws

20. competitive information

23. records and data integrity

27. insider trading

29. conflicts of interest

32. communications

35. transacting international business

39. Quality and regulatory compliance

41. Working with governments

45. environmental stewardship and workplace safety

50. living the protocol

54. protocol for reporting concerns

58. resource directory

59. Appendix

62 . index

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6 the protocol

the life technologies protocolWe are responsible

hi, i am John skousen, compliance officer. i think we are all excited about the combination of Applied Biosystems and invitrogen and the formation of life technologies. We have an opportunity to truly revolutionize the development of science. As a compliance officer, i am further encouraged to note that both companies have a strong culture of legal and regulatory compliance. this document is a joint effort by the two companies to create a synthesized code of ethics and conduct to help guide the actions of employees in the combined company.

this document, which we refer to as the protocol, can be viewed as a moral compass to guide our actions as we conduct business around the world. As a company with a significant presence in the biotech arena, we will be held to a higher standard of compliance and ethics.

leaders and employees of life technologies (the company) have a responsibility to be vigilant and ensure that our actions are above reproach. We must maintain a reputation of trustworthiness. We must be mindful that how we conduct ourselves will have an impact on how the company is perceived in the market. i am proud to be working for a company that values integrity and conducts its business in an ethical manner. i look forward to working with each of you to maintain the high standards we have set.

John Skousencompliance officer

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7life technologies

contact your HR manager, the Compliance Officer, the Legal Department, your Ombudsperson, or the confidential Protocol Helpline.

What if i learn of a violation?You should report it through one of the methods outlined after the question/answer section, and also under “Protocol for Reporting Concerns.”

consequences of noncomplianceThe following lists potential consequences for the Company and its employees due to employee noncompliance and/or not reporting suspected noncompliance:

consequences for life technologiest Penalties and/or fines for the inappropriate behavior of employees→→t Damage to reputationt Loss of investor confidencet Damage to new business opportunities and customer relations

consequences for employeest Penalties and/or fines for inappropriate behaviort Damage to personal reputationt Loss of bonus or incentive payt Termination of employmentt Prosecutiont Other forms of disciplinary action

important: the materials in the protocol and the policies and procedures referenced in it do not constitute an express or implied contract between the company or any of its affiliates and any individual or entity.

this guide does not alter the employment relationship of any company employee, whether such relationship is at will or contractual.

About the protocolThe Protocol provides direction for conducting business consistent with our legal obligations, global values, and core business principles. It is a resource to help you understand how the Company’s commitment to integrity relates to your daily work for the Company. The Protocol does not describe all applicable laws that govern our conduct or give full details of any individual or country-specific laws. It is a set of guidelines to help each of us conduct business in an ethical and honest manner.

Does the protocol apply to me?The Protocol applies to all directors, officers, and employees of the Company and its subsidiaries around the world. We also require consultants, contractors, agents, and distributors, acting on behalf of the Company, to follow the policies that are applicable to their representation.

What if i live outside the Us?Because the Company is organized and headquartered in the United States, most sections of The Protocol focus predominantly on US law. However, most of it is applicable in other countries as well, either directly or because of comparable local laws. Please refer to the section titled “Transacting International Business” for additional information.

What are my responsibilities and obligations regarding the protocol?It is your obligation to read The Protocol thoroughly, focusing particularly on the issues directly related to your job, and refer to it whenever you have questions. You will be required to certify annually that you are following its principles.

Where can i find more resources?Each section includes a cross-reference to additional materials. Additional materials are also available on the Ethics and Compliance Community on Integration Central, the Company’s intranet (integrationcentral.net).

What if i have a question?We welcome questions about The Protocol. If you have one, please check out The Protocol FAQs on Integration Central or

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8 the protocol8 the protocolfollowing the path of truth, wherever it leads

one of the pleasures of working in the life sciences is that this field attracts a very high caliber of person: bright, highly educated, intellectually stimulated, and emotionally drawn to the opportunity for creating new knowledge and improving the human condition. one of the strengths of this kind of person is innate integrity and ethics. i’ve had extremely positive contacts with Applied Biosystems employees over the years possessing these very attributes, and i’m sure this will continue as we build a new company with life technologies.

When you work in science—and work alongside people in the sciences—you naturally adopt a respect for the truth. in science and in business, you must have an honest, sober perspective, and fearless dedication to identifying the problem, following the data, and building a solution that will last. respect for the truth is an excellent basis for a moral compass. having the personal honesty to stand by the truth is a great demonstration of integrity.

our customers, our stockholders, and our fellow employees expect no less of us. We are not in the frivolous business that changes on a whim. our business is to help scientists unlock fundamental truths about how life works. We create science-based applications that work in the customer’s hands, give true and reliable results, and support a deeper understanding of life.

our stockholders expect us to communicate accurate and complete financial results. our employees only prosper when we treat them fairly and equitably and provide open, honest feedback. i know of no other way to achieve this than by working and living in a culture that is based on respect for the truth and a commitment to personal integrity to follow that truth, wherever it leads.

responsibility is at the core of our traits as a company, and the protocol guides us in pursuing responsibility in every aspect of our business. it is, essentially, our moral compass, and i hope you use it as a guide in all of your work and interactions as we move forward to make life even better.

Mark Stevensonpresident and chief operating officer

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9life technologies 9life technologies

the combination of invitrogen and Applied Biosystems is complete, and this union presents us with unprecedented opportunities. As life technologies, with a prod-uct portfolio that spans the spectrum of life science solutions, a presence in more than 100 countries, and greatly expanded research and development capabilities, we will use the power of innovation to improve the human condition and make life even better. our path forward is exciting, and i am confident we will deliver for our shareholders, our employees, and our customers as we bring biology into society and accelerate discovery in all areas of science and medicine.

to truly achieve success, life technologies must be known not just for being a great company, but also a good company—one that is responsible in its dealings and ethical in its interactions. ethics and integrity were integral parts of the cul-tures of our legacy organizations, and i expect those personality traits to be equally well repesented by all of us in our new company.

the purpose of the protocol is to provide each of us with guidelines on how to con- duct business responsibly and to represent life technologies in an appropriate and ethical manner. i ask that you each take the time to read and thoroughly under- stand this document. Be sure you are familiar with the various standards, laws, and regulations that govern our work so that you will always be able to evaluate your direction and know that you are following the right path.

As you read the following pages, and as you commit yourself to the outlined prin-ciples, recognize that we have a great opportunity to change the world of science—but our success depends on a continued commitment to our values. We must be responsible stewards, acutely aware in everything we do that we have the opportu-nity to transform human understanding of life itself. our reputation must precede us, and our dealings must always make us an example for others to follow.

Greg Lucierchairman and chief executive officer

toward responsibility— the right path and the right direction

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commitment to integrity

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→→Commitment to integrityWe strive to create an atmosphere that supports the highest standards of ethics and integrity. We expect honesty in all that we do and make decisions empirically, without bias.

We are committed to compliance with all applicable laws and regulations wherever we operate throughout the world.

We value our people and seek to provide an environment that encourages collaboration and teamwork, open debate, honest communication, and individual achievement.

We require accountability and reward fairly and in accordance with performance.

We allow people to take risks, explore ideas, and find solutions.

We value cultural differences and believe that all employees are entitled to fair employment practices. We seek to operate with mutual respect and trust, and without conflicts of interest.

We seek to conduct our business in a sustainable manner, aggressively protecting the environment and promoting the health and safety of our employees, our customers, and the citizens in the communities in which we operate; and engaging in sound, reliable business and financial practices.

We have a passion for improvement that infuses our compliance programs, as well as the rest of our business.

→→Commitment to integrityWe strive to create an atmosphere that supports the highest standards of ethics and integrity. We expect honesty in all that we do and make decisions empirically, without bias.

We are committed to compliance with all applicable laws and regulations wherever we operate throughout the world.

We value our people and seek to provide an environment that encourages collaboration and teamwork, open debate, honest communication, and individual achievement.

We require accountability and reward fairly and in accordance with performance.

We allow people to take risks, explore ideas, and find solutions.

We value cultural differences and believe that all employees are entitled to fair employment practices. We seek to operate with mutual respect and trust, and without conflicts of interest.

We seek to conduct our business in a sustainable manner, aggressively protecting the environment and promoting the health and safety of our employees, our customers, and the citizens in the communities in which we operate; and engaging in sound, reliable business and financial practices.

We have a passion for improvement that infuses our compliance programs, as well as the rest of our business.

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13life technologies

Making the right decisions

if you are not certain that your actions are appropriate from a legal or regulatory point of view, a simple way to check is to ask yourself the following questions:

t is the action inconsistent with the protocol?

t Does it appear to violate any law, regulation, or accounting rule?

t Does it make me uncomfortable on ethical or legal grounds?

t Would i feel uncomfortable reading about it in the newspaper?

t Would our customers, business partners, government regulators, the communities where we work, our shareholders, or the general public look at it negatively?

t Does it risk the safety of others, the reputation of the company, my personal credibility, or the financial integrity of the company?

if you answered “yes” to any of the above questions, then your internal alarm should be sounding, and you should seek assistance. if in doubt, ask for help. We’ll bring to bear the right legal expertise to help answer the question.

if in doubt, ask!

the whole idea is to speak up, ask questions, and get answers. Bring the concern into the open so that any problems can be resolved quickly.

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14 the protocol

integrity in the workplacesummarythe company is committed to fostering workplaces that are safe and professional and that promote teamwork, diversity, and trust. We value the vibrant work environment that comes from having a diverse employee population, making employment decisions based on merit, and promoting the equal opportunity and fair treatment of all individuals. We expect our employees to follow a simple standard: All employees and others we encounter in the workplace must be treated fairly and with respect. our policy prohibits all forms of unlawful harassment, discrimination, retaliation, or intimi-dation, and employees are required to follow the governing laws of the land where they reside.

At the company, we strive to be an employer of choice by creating an environment in which people do their best work. We encourage collaboration and teamwork, open debate, personal integrity, honest communication, and individual achievement. We require accountability and reward fairly in accordance with performance.

We allow people to take risks, explore ideas, and find solutions. We value original thought, innovation and creativity, and provide the process, structure, and tools to support these values.

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15life technologies

Basic principlesEmployees must abide by all applicable laws and regulations relating to employment matters and all employment decisions should be based on merit and/or other legitimate, lawful factors. Hiring, promotion, termination, and other employment decisions should not be based on race, religion, national origin, gender, sexual orientation, age, disability, veteran status, or any other characteristic protected by applicable law. We expect the work environment to be free from any type of illegal harassment, including, but not limited to, racial, sexual, and religious harassment and that the respect and privacy of all employees will be maintained as required by law.

If you think you are the subject of prohibited discrimination, harassment, or other inappropriate conduct, report it immediately to your supervisor, employee relations, or the other individuals identified in the section titled “The Protocol for Reporting Concerns.”

comments about othersWe expect all employees to exercise professional discretion when making any comments about our competitors, customers, suppliers, strategic partners, or other employees—both current and former. Only appropriate Human Resources (HR) representatives are permitted to provide references or any other information to outsiders relating to current or former employees.

practical examplesQ: One of my supervisors always puts his arm around me whenever possible and stares at the private parts of my body whenever we have a conversation. Can I tell him that this behavior makes me feel uncomfortable?

A: Absolutely. All Life Technologies employees deserve to be treated in a professional and courteous manner. You should tell him this type of behavior makes you feel uncomfortable. If the behavior continues, it should be reported immediately to your HR representative or Legal Department.

Q: A Life Technologies coworker repeatedly sends me emails with religious and ethnic jokes even after I have requested that no more be sent. What responsibility do I have to report this situation? Does this present any Protocol issues?

A: Your coworker is violating The Protocol and the Company’s Electronic Communications Policy. This matter should be reported to your local HR representative. Any material that could be construed as constituting a hostile working environment is against Company policy and will not be tolerated.

Q: One of my work colleagues always makes racial jokes at our staff meetings. My supervisor not only tolerates this behavior, but she encourages it. When I have spoken to her about how uncomfortable these jokes make me feel, she just laughs and tells me I have “thin skin.” She says it is a way to loosen up the team and create a spirit of collaboration. What should I do?

A: Telling racial jokes is against The Protocol and several other employment-related policies. The Company is dedicated to creating an environment that is free from any form of hostile working conditions or harassment. This is a matter that should be addressed immediately with employee relations or your local HR representative.

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16 the protocol

Q: Sexual harassment is a big deal in the US. What standards exist outside of the US?

A: We expect our employees to follow a simple standard: All employees and others whom we encounter in the workplace must be treated fairly and with respect no matter the country or physical location of the facility. Please contact your local HR representative if you feel any conduct is not following this policy.

Q: I recently applied for a position in another department but was turned down. I have learned that the employee hired has far less experience than I do. What can I do?

A: You should contact your HR representative and the hiring manager. It is important that all Company employment opportunities be based on merit and equal opportunity for all employees.

Q: Lucy is an hourly employee working in the manufacturing area. Due to the tremendous push to improve efficiency in the production process, Lucy feels that she needs to always shorten her lunch and meal periods to be a team player and return early to the production line. Is this appropriate?

A: You should always follow the local and national laws that govern employment issues. In many jurisdictions, it would not be appropriate to return early and violate employment laws.

Additional reference materials (found on integration central)

Workplace Harassment PolicyEqual Employment Opportunity PolicyElectronic Communications Policy

Live and dead bacteria visualized on freshly isolated human cheek epithelial cells

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17life technologies

competition lawssummaryWhile all employees are expected to work vigorously to outperform our competition and compete in the marketplace, only legal and fair methods may be used to do so. our policy is to conduct business in strict compliance with all applicable competition (or antitrust) laws. these laws promote free enterprise by eliminating artificial restraints on competition and generally prohibiting restraints of trade and other unfair methods of competition.

the competition laws are complex. Many of the general principles in this field are subject to intricate qualifications that depend on the facts of each case. it is important, therefore, that you are able to recognize potential competition law problems and bring them to the attention of the company’s chief legal officer. no company employee will be disciplined for reporting a competition law concern. A knowing violation of these laws, however, will be grounds for appropriate disciplinary action, including dismissal.

Basic principlesThe Company employees are prohibited from engaging in the following types of conduct:

price fix, etc.Don’t communicate or agree with any competitor about bids, pricing, costs, allowances, R&D, advertising, credit terms, merchandising strategy or plans, supply or marketing plans—in short, how we go to market.

Market allocationDon’t agree with competitors to allocate market, customers, or territories.

Muntjac skin fibroblasts

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18 the protocol

tieDon’t offer or sell any of our products or services on the condition that the purchaser buy one of our other products or services. The deal may be viewed as an illegal “tying” arrangement.

BoycottDon’t agree to “boycott” or refuse to do business with any supplier or customer.

resale price maintenanceDon’t determine the resale price of products with a distributor or other customer without receiving clear legal advice regarding applicable legal standards.

Meet with competitorst Be careful about the disclosure of information at any meetings at which competitors are present, including benchmarking sessions, seminars, standards-setting organizations, and trade association/industry meetings.

t Review the agenda for those types of meetings in advance with the Legal Department.

t If the wrong topic comes up (see principles above), either change the subject or leave the discussion immediately.

general guidancet Check with the Legal Department before terminating a distributor or customer, or refusing to deal with a distributor or customer.

t Don’t offer different prices or discounts to competing customers in the same general time frame, without proper legal guidance.

t Allowances or payments for promotional or merchandising programs must be offered to competing customers on proportionately equal terms.

t Check with the Legal Department before agreeing to any exclusive arrangement for the sale or distribution of products. Some exclusivity arrangements may be illegal.

t Don’t deal with any broker where any part of the brokerage is passed back to the customer.

→→t Don’t cover up any wrongdoing; if you become aware of any violation, report it promptly to the Chief Legal Officer.

Drafting tipsIt is important to consider competition law carefully in drafting memoranda and other written documents. The Company can be severely handicapped in a lawsuit or a government investigation when lawful conduct is mischaracterized by the misleading or thoughtless use of words that do not fairly express the Company’s position or accurately describe the facts. You can’t change the facts—but you can minimize the chance of unnecessary problems, especially by being careful in the language that you use. Specific guidance in this regard is provided in the Company’s Guide to Compliance with Competition Laws.

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19life technologies

practical examplesQ: One of your grad school buddies is now working for a competitor of the Company. During the last few years the Company and this competitor have competed aggressively on every deal in your region. Product competition has consistently driven margins down. Frustrated, you agree to meet with your buddy and discuss ways that both companies can improve their product margins. Is there anything wrong with having a meeting of this type?

A: Yes. You should never have a conversation with a competitor about pricing or margins. Price fixing is “per se illegal” under the antitrust laws, and if you engage in it you could go to jail. Contact the Legal Department immediately.

Q: At the request of your supervisor, your have been asked to prepare a simple marketing flyer that takes several key, fast-moving Company products and bundles these products with several slow-moving products to improve the sales in your region. Is this flyer appropriate?

A: First, all customer communication must be approved by Commercial Operations before being sent to the customer. In addition, it may be illegal to bundle products in this manner. Selling one product or service on the condition that the buyer purchase a separate product or service might constitute an illegal tying arrangement. The competition laws prohibit tying arrangements under some circumstances because they force consumers to buy an unwanted product or service and effectively limit competition. Any sales arrangement that could constitute an illegal tie must be reviewed with the Legal Department.

Additional reference materials (found on integration central)

Guide to Compliance with Competition LawsMulticolor fluorescence image of mouse testis cross section

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20 the protocol

competitive informationsummarythe company competes aggressively in many global markets, and we need to gather competitive information about those markets to be successful. it is acceptable, of course, to gather information from available public sources. it is against the company policy, however, to obtain proprietary or confidential information of third parties through theft or misappropriation, “pretexting,” or violating confidentiality obligations to third parties.

Who is a “third party” in this context? it could be a customer, supplier, competitor, former employer, research collaborator, business partner, or other person or entity.

Bovine pulmonary artery endothelial cell labeled with probes to visualize mitochondria, peroxisomes, and the nucleus

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21life technologies

“the protocol is a great source of information. personally, when in doubt about a situation, i can always refer to the protocol to help me clarify doubts and make the best decisions for me and my team. ethical principles have a profound impact on employees’ behaviors, especially when those principles are part of everyday life at the workplace, and they are consistently followed at all levels of the organization.”

Maritza Diaz frederick, Maryland

otocol is a great source of information. rsonally, when in doubt about a situation,

rotocol to help

employees’ behaviors, especially when

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22 the protocol

Basic principlesProprietary and confidential information includes trade secrets and copyrighted materials and can be embodied in all types of financial, business, scientific, technical, economic, or engineering information that has economic value. Employees must not take any action that could be construed as theft or misuse of trade secret information, including:

t Taking trade secret information without authorization from the owner

→→t Disclosing trade secret information without authorization from the owner

→→t Receiving trade secret information that has been obtained by someone else without the owner’s consent

t Engaging a third party to obtain trade secret information without the owner’s consent

t Reverse engineering of products is permissible, so long as the product is not provided under an obligation of secrecy or confidentiality.

new employees take note

You must notify the hr and legal Departments if you are subject to any contractual limitations on the scope of your work for the company (for example, limitations based on confidentiality agreements with your former employer) and if you have trade secrets of a former employer that relate to your work for the company.

Do not bring into the company confidential documents of your former employer or otherwise divulge trade secrets of your former employer without proper authorization from the owner.

practical examplesQ: Is it OK to pose as a potential customer to obtain information concerning a competitor?

A: The Company is very interested in obtaining competitive information on our key competitors; however, only if the information is obtained in a legal and ethical manner. “Pretexting,” obtaining information under false pretenses, is not acceptable and is a violation of The Protocol. However, obtaining competitive information that is in the public domain (e.g., available on a public website) is permissible. Any information that is obtained from a nonpublic source should be reviewed by the Legal Department.

Q: You recently hired an employee from a research institute to work on the development of a restriction enzyme. The development project proceeded slowly for six months. Last week, the new employee told you that she had access to key development documents from the research institute. She also said that the institute had abandoned the project and was no longer planning to use the research. With these key documents, the research could be jumpstarted and completed in short order. What should you do?

A: The information is not in the public domain and is probably protected by trade secret or other applicable Intellectual Property law. Its use would require approval by the Legal Department.

Q: What information is OK to obtain from a competitor?

A: Any competitive information in a public domain environment can be obtained and used. Any additional information gathered should be reviewed by the Legal Department.

Newborn mouse cochlea

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23life technologies

records and data integritysummaryone of our most important obligations is that we keep accurate and complete books and records that comply with all applicable laws and are not misleading to the company’s financial auditors. in addition, it is critically important that employees safeguard the confidential and proprietary information of the company and not misuse any such information owned by other parties.

“the benefit of life technologies emphasizing integrity and compliance is that everyone does the right things. it also helps us avoid risk.”

Xiao Fang shanghai, china

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24 the protocol

Basic principlesfinancial recordsAll of the Company’s transactions must be completely and accurately recorded in the Company’s books and records in accordance with Generally Accepted Accounting Principles (GAAP) and in a manner that facilitates proper audit and control. Employees must not make any false or deceptive entries in the financial records or statements to the Company’s auditors. The Company’s funds must be maintained in bank accounts in the name of the Company or the appropriate subsidiary. No secret or unrecorded cash funds or other assets may be established or maintained for any purpose.

government contract recordsOur government contracts typically require us to keep current, complete, and accurate records for specified periods of time. If we fail to keep these records properly, we can incur civil or criminal penalties. The Company policy is to comply rigorously with such requirements.

the company’s proprietary informationConfidential information should not be disclosed to third parties, used by employees for their personal benefit, used to further the interests of third parties, or used in any way other than for the best interests of the Company. All manuals, reports, records, and other documents generated by or for the Company, other than those made generally available for public distribution, are the property of the Company and are to be used solely for its business.

Employees who have access to confidential or proprietary information are expected to maintain the confidentiality of that information and may not make or allow unauthorized disclosures of that information either during or after employment. The duty to preserve the Company’s confidential and proprietary information is not limited to an employee’s period of employment, but continues after he or she has left the Company. Should you become aware of an incident in violation of this policy, please report it immediately to the Compliance Officer, the Legal Department, or the Compliance and Ethics Helpline at +1.866.854.2783.

In addition, it is the responsibility of every employee to be alert at all times to possible attempts by unauthorized persons to obtain the Company’s confidential information, as well as attempts by authorized persons to use data unlawfully. Any such attempts must be reported to the Compliance Officer.

records managementAll employees must comply with all company records management and retention requirements, including the storage and disposition of company records in accordance with the Records Retention Schedule.

The cytoplasm of a live zebrafish embryo

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25life technologies

Under no circumstances should any documents be destroyed or disposed of that are subject to a subpoena, litigation, or government investigation. Any questions should be referred to the Legal Department.

privacy and confidentialityThe Company believes in respecting the privacy and confidentiality of our employees’ personal information. This means that access to personal records will be limited to Company personnel who have appropriate authorization and a clear business need for that information. Employees who have access to the personal information of others must treat it appropriately and confidentially.

Many of the countries in which we do business, especially the European Union, have very strict and far-reaching privacy laws. All employees who handle the personal information of our employees must be aware of, and adhere to, the privacy laws of the jurisdictions where they are located. If you have questions about your responsibilities with respect to these privacy laws, contact your local Legal Department.

Each employee also has a duty to protect the privacy and security of information that customers and consumers entrust to them. Employees who do not have a business reason to access this information should never seek to do so, and those who do have legitimate access shall at all times take active steps to protect against the unauthorized release or use of private customer and consumer information.

All employees must accurately report data and other information. Lab tests, project results, financial data, and other information may not be falsified or otherwise recorded in a misleading manner.

practical examplesQ: Under a Confidential Disclosure Agreement (CDA), you receive some plasmid technical specifications from a university research facility to be used on Project A. Using these technical specs you are also able to complete a critical element of your research on Project B. Is it permissible to use this information as part of your research on Project B?

A: No. A CDA will govern the use of plasmid technical specifications. The Intellectual Property group in the Legal Department should be consulted to ensure proper compliance.

Q: At the end of a slow quarter, a Company Sales Representative invoices and ships a large product order to a Distributor. The Sales Representative and the Distributor have agreed to allow the product to be returned to the Company after the close of the quarter. Is this shipment and invoicing arrangement permissible?

A: No. This is a serious revenue recognition violation and is against The Protocol. This issue should be addressed with Legal, Finance, and Compliance immediately.

Q: You have been requested to review all relevant information on your hard drive and the network shared drive to ensure only the most current and accurate information is stored. You feel this is a waste of time because storage capacity is inexpensive, and you do not have time to review all of the documents you have stored. Is this acceptable?

A: No. It is important that you adhere to the Company Records Retention Schedule. All employees must follow the Schedule to make sure that the appropriate documents, schedules, reports, contracts, etc., are properly stored, archived, and in due course deleted.

Q: Recently, it has come to your attention that the Company price list for antibody detection reagents has been posted on the supply room door of ATC Institute. In addition to the Company price list, several other competitors’ price lists are also posted on the door. What should you do?

A: Request that the customer remove the Company price list posting from the door and remind the customer that the Company price list is confidential.

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Data integrity

26 the protocol

Q: Anjay works in the R&D group and like all research professionals is required to keep an accurate lab notebook of all the research performed. During the last year, Anjay has been extremely busy at work and has not kept his lab notebook up to date. Many of his experiments have not been documented, and some of his notebook entries have not been signed by a colleague. What are the repercussions of not keeping an accurate lab notebook?

A: Accurate lab notebooks are vital to the proper protection of the Company’s intellectual property. In some instances, the Company’s Legal Team has had to go back to lab notebooks prepared over ten years before to support the Company’s legal position on important technology. Anjay must keep an accurate lab notebook or be subject to disciplinary action.

Q: On every expense report Bill adds a little extra to cover the inconvenience of traveling away from his family and for missed expense items he thinks he probably forgets. This is small potatoes compared with the huge expense reports the executives in his department submit every week. Is this OK?

A: Falsifying the Company expense reports is wrong and against The Protocol. All reasonable and documented expenses will be reimbursed. Honesty and an ethical approach to doing business are fundamental principles at the Company.

Q: Last week, Steve and two hourly associates came to work on a Saturday and Sunday to help out their manager who was trying to complete a special project by Monday. At the conclusion of the work on Sunday, the manager told them to take Wednesday and Thursday off and record the usual time. Is this the correct way to account for the overtime work?

A: No. No one should ever falsify payroll or any Company records. This issue should be raised with your HR representative immediately.

Additional reference materials (found on integration central)

Employee Complaint Procedures for Accounting and Auditing MattersIntellectual Property PolicyInformation and Technology AgreementConfidential Information and Trade Secrets New Employee Orientation PolicyPolicy Regarding Proprietary Information of OthersTravel and Expense PolicyRecords Retention Policy See also, “Competitive Information” on page 20

Money laundering

Law enforcement officials around the world are increasingly concerned about “money laundering” enterprises—attempts to conceal illicit funds, or otherwise make the source of illicit funds look legitimate. Money laundering schemes can also be used to avoid duties and taxes. The Company will not condone, support, or facilitate money laundering, and we will take steps to prevent such activities from occurring in company transactions. For example, the Company supports this anti- money–laundering policy by using certain procedures, such as:

t Specifying acceptable forms of payment

t Requiring that all payments be in the currency of the invoice

t Prohibiting third-party payments (where a customer or supplier asks us to pay a rebate or other payment to a different company instead of itself)

t Requiring compliance with all applicable financial reporting and recording rules

t Requiring that payments for each invoice or group of invoices be made by a single instrument promptly report suspicious transactions or activities by any customer to your local finance Manager, legal Department, or the compliance officer.

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27life technologies

insider tradingsummaryemployees must never buy or sell securities on the basis of material nonpublic information. insider trading laws are complex, and the penalties can be severe. if you are unsure about how the law applies in a given instance or you have the slightest question about whether information you possess is material nonpublic information, consult with the legal Department. if in doubt, don’t trade in the company’s stock until you get approval from the company’s chief legal officer.

Basic principlesKey ruleIf you have material nonpublic information, don’t buy or sell Company securities.

MaterialWhat is “material” information? It is information that would be considered important by a reasonable investor. It could include:

t Earnings information→→t Information about a merger or acquisition→→t Information about a favorable or unfavorable ruling by a regulatory agencyt Information about a breakthrough technologyt Actual or threatened litigation or resolution of such litigation

nonpublicInformation is “nonpublic” if it has not been widely disseminated to the general public through a report filed with the SEC or through a major newswire or news service.

Epidermal growth factor (EGF) receptors

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28 the protocol

the no-tipping ruleIf you have material nonpublic information, don’t pass it on to others, or make “buy” or “sell” recommendations based on that information.

→→t Don’t disclose it to nonemployees, including family members.

→→t Don’t even disclose it to other employees without proper authorization.

potential penaltiesA person trading on material nonpublic information may be subject to serious civil and/or criminal sanctions and will be subject to discipline by the Company (including termination for cause). Even the appearance of impropriety could impair investor confidence in the Company; therefore, extreme care must be taken to avoid even inadvertent violations.

special requirements for designated insiderst An “insider” may only buy or sell the Company stock during set time periods called “open trading windows.” Any employee designated as an “insider” will be notified by the Company.

t An insider must refrain from selling any Company securities he or she does not own (e.g., “short selling”), or engaging in any other transaction that includes a short sale as an element of the trade (such as a “hedge” or a “collar” involving a short sale).

t Certain insiders also have been notified that they are subject to the requirements of Section 16 of the Securities Exchange Act of 1934. Under the Company’s Section 16 Reporting Policy, these employees must get preapproval from the Legal Department for trades in the Company’s securities and notify the Company’s Form 4 Team on the day of any such trade.

practical examplesQ: You recently became aware that the Company is acquiring a competitor that will substantially increase earnings and revenue. The acquisition has been kept confidential from other employees and the investing public. Is it permissible to purchase shares in this company? Is it permissible for your spouse to purchase shares in this company?

A: No. This information would be considered material and nonpublic. Using this information and making a stock purchase would constitute insider trading and is illegal, and a violation of The Protocol. Likewise, it is illegal for your spouse, family member, or a third party, to purchase stock with the information that you acquired at the Company.

Q: During an operations meeting, the controller in your business unit tells you that the Finance Department is experiencing a systems problem that will most likely delay the release of Company earnings by several weeks. Concerned about your stock position, you place a sell order before the trading window is closed. You are not on the insider trading list and do not have any access to company financial statements. Is it appropriate for you to place this order?

A: No, any stock trades based on “material”, “nonpublic” information is insider trading. You will violate the Company’s Insider Trading Policy and potentially be subjecting yourself to civil and criminal penalties.

Additional reference materials (found on integration central)

Insider Trading PolicyPolicy on Reporting Insider Transactions in Compliance with Section 16 and Sarbanes-Oxley Act

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29life technologies

conflicts of interestsummaryMake sure your personal interests are not in conflict with the company’s interests. to ensure compliance with this rule, you should not engage in any activity or relationship that even appears to present a conflict of interest, unless it is disclosed as described below and is determined not to be detrimental to the company’s best interests.

Basic principlesConflicts of interest can appear in many contexts. The following is a list of examples that could, depending on all of the facts and circumstances, constitute improper conflicts of interest.

Business transactionsA business transaction between the Company and a business in which the employee or a member of the employee’s family has an economic interest can be an unacceptable conflict. ”Business transactions” include making purchases, leases, or sales of supplies, equipment, and other property; providing services; and entering into contracts. In some cases, a business transaction can be approved by the Chief Legal Officer or Compliance Officer if it is on a competitive, arm’s-length terms and is in the best interest of the Company.

stock ownershipIt is a conflict to have an economic interest in a competitor, other than owning securities indirectly through a mutual fund. Ownership of securities by a family member might also constitute a conflict of interest. If an investment becomes subject

Endogenous alkaline phosphatase enzyme of osteosarcoma cells

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30 the protocol

to these conflict rules as a result of changes in circumstances— for example, we acquire a new business and hence new competitor —you should sell the securities of the new competitor or contact the Chief Legal Officer to discuss other means of handling the conflict. The Chief Legal Officer is authorized to exercise discretion in resolving such issues in a manner that is not unduly burdensome.

competitionProviding service to a competitor, supplier, or customer as a director, officer, employee, partner, agent, or consultant most likely involves an unacceptable conflict.

corporate business opportunitiesDepriving the Company of a business opportunity, or diverting a business opportunity to the employee’s own benefit, is prohibited unless approved in advance by the Chief Legal Officer.

loansAccepting loans from financial institutions that do business with the Company on terms that are not generally available to the public is prohibited.

Use of company propertyUsing Company property or other resources for personal benefit is generally not acceptable.

improper gifts

receiving giftsDo not accept a gift (anything of value) from a vendor or other party seeking to do business with the Company, if the gift is of more than modest value and accepting the gift would be likely to interfere with your impartial judgment in the performance of your duties.

t Company employees are prohibited from accepting a payment or gifts of significant value in exchange for giving Company business to a third party.

t It generally is acceptable to engage in social activities that typically are associated with proper business relationships. These include common forms of entertainment, such as dining and sporting events.

t Employees should use common sense and good judgment in determining what is permissible, and if in doubt, should consult their supervisor or the Chief Legal Officer.

Whom should i ask?if you are in doubt about a potential conflict of interest, you should discuss the situation with your supervisor. if the supervisor is unsure, he or she should raise the issue with the appropriate Business leader, the chief legal officer, or compliance officer.

the ceo is responsible for reviewing potential conflicts of interest involving officers of the company, and the Board of Directors is responsible for reviewing potential conflicts involving the ceo. conflicts involving directors will be handled as described in the company’s governance principles. Depending on all of the facts and circumstances, we might determine that a potential conflict of interest is not detrimental to the company and is therefore acceptable. conflict of interest transactions are prohibited, however, unless they have been approved in this manner.

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31life technologies

Method of analysist Is the gift of modest value or common entertainment, such as a meal or sporting event? If so, no problem.

t If the gift is more than that, ask whether accepting the gift would be likely to interfere with your impartial judgment in the performance of your duties.

t If you think accepting a gift might affect your judgment— don’t accept it. If you think it would not affect your judgment, but recognize that others might disagree, then discuss it with your supervisor and, if necessary, the CLO, before you accept it.

giving giftsYou should not give a gift of more than modest value to any person, if the gift might reasonably be viewed as being a reward for doing business with the Company. This includes giving gifts to family members of customers.

t Promotions that are announced publicly and are available to customers generally are not prohibited—provided that any promotion for government customers is approved by the Government Contracts Department.

t It is generally not a violation to pay for a nongovernment customer to attend or participate in a sporting event, concert, or other entertainment event, pay for a meal with a customer, pay the expenses for a customer to attend a scientific seminar, or make similar payments. However, employees should ensure that any such activity does not conflict with the internal ethical rules of the customer’s employer.

t Government regulations either prohibit or restrict us from offering gifts to government employees or accepting gifts from government employees. If confronted with such a situation, please contact the Government Contracts Department for guidance.

practical examplesQ: Steve has been asked to serve on the scientific advisory board of a small biotech company. The biotech company asked Steve to sign a nondisclosure agreement. Is it permissible to agree to serve on this advisory board? What if the biotech company wants to pay him for his time and services?

A: This is a very touchy subject and must be addressed with your supervisor and the Legal Department. Many questions will need to be answered. Does the Company compete with the biotech company? How much time will Steve be spending as an advisor? If allowed to be an advisor, the Company will advise Steve on the conditions under which he could sign a nondisclosure agreement and the potential terms of employment, if compensated.

Q: One of the Company’s key suppliers of office products has invited several of the office staff to go to a “Day at the Races.” The supplier will provide entrance fees, food, and drink at the races. Should you attend?

A: Ask yourself whether accepting this offer would interfere with your impartiality in dealing with this vendor. Tickets to the races would be considered of modest value and would probably be appropriate. If you feel it would not impair your judgment, but recognize that others might disagree, then discuss it with your supervisor, the Legal Department, or the Compliance Officer, before accepting the gift.

Q: You would like to invest in a company that manufactures a key product that the Company licenses. You just want to buy a few shares (less than 1/10 of 1%). Any concerns?

A: If the company is a competitor, you are prohibited from purchasing the shares. If not, the key question is whether the investment would impair your ability to make an impartial judgment in your work for the Company. There may be a conflict of interest if you have the ability to influence the relationship between companies in the form of purchasing or business development decisions. If in doubt, consult your manager, the Legal Department, or the Compliance Officer.

Additional reference materials

See Political Contributions and Political Activities under “Working with Governments”

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32 the protocol

communicationssummarythe company provides the use of computers (including computer software), voice mail, electronic mail (email), and access to the internet to certain employees for the purpose of achieving the company’s business objectives. employees must use these resources responsibly and in accordance with all legal requirements. communications with the media are limited to certain designated employees.

Basic principleselectronic communicationsThe Company has the right to access, reprint, publish, or retain any information created, sent, or contained in the Company’s computer or email systems or any of the Company machines or equipment. Some incidental, personal use of these systems is permitted. However, abuse of this privilege or use of email or the Internet in a manner that is contrary to ethical or lawful conduct is expressly prohibited. Employees must not post messages regarding the Company on Internet message boards or in “chat” rooms. Actively acquiring or sending any information that is offensive, defamatory, or harassing (including sexually oriented material or material that is discriminatory) is strictly prohibited.

Employees must respect the computer software rights of other companies. Much of the computer software used at the Company was created and copyrighted by other companies and may be subject to nondisclosure restrictions. The Company does not usually own software created by other companies, but receives and uses the software under license agreements. Reproducing software without authorization may violate these agreements and the US copyright laws. No employee should make copies, resell, or transfer software created by another company unless it is authorized under the applicable software license agreement.

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33life technologies

“commitment to integrity is demonstrated at life technologies in consistent ways, from little things to big deals. ethical principles shape everything we do, from the kind of products we sell to the way we approach customers to the way we interact with each other inside the company.”

Rodrigo Schwarcz De Sa Benevides sao paulo, Brazil

Streptomyces antibioticus ETH7451 cultures

mmitment to integrity is demonstrated echnologies in consistent ways,

thical principles shape everything

with each other inside the company.”

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34 the protocol

Downloading copyrighted music, video, or other software without permission from the copyright owner is illegal. Text, computer programs, artwork, music, photographs, film, audiovisuals, and other content items created by a third party are protected by copyright law in the US and other countries. Copyright laws around the world also protect magnetically recorded and electronically transmitted materials, including certain databases and most of the content posted online.

Unauthorized use of copyright material can subject you as an individual, as well as the Company, to legal sanctions. Contact the Company’s Legal Department whenever there is a question about the use of such material.

communication with the mediaAs a publicly traded company, the Company must exercise caution in reporting information about the Company to the public and the media to ensure that all applicable legal requirements are satisfied. Therefore, all communications with the media, the issuance of press releases, similar investor relations activities, and public relations activities are limited to specified individuals as provided in the Company’s External Communications Policy. Other employees are prohibited from engaging in such activities or otherwise issuing public statements on behalf of the Company. A word of caution—Be cArefUl when using email and other systems for personal use and avoid inappropriate material.

practical examplesQ: Recently some breaking news about your area of scientific expertise was published in several scientific trade journals. You have been asked by the trade journals to comment on the articles. What should you do?

A: Nothing. All comments to the media in any format must be coordinated through the Corporate Communications or Investor Relations Department.

Q: My family and friends frequently email me stories and funny cartoons and keep me informed about friends and family members. Is this appropriate? Is any of the information kept confidential?

A: While incidental personal use of the Company computer systems is appropriate, you should have no expectation of privacy relating to the Company’s email system or computers. Because the computer system and network belong to the Company, the Company may review any of the materials at any time.

Q: While you were online yesterday, you came across some very cool shareware software that can help you organize and manage your time. Is it OK to download the software and install it on your computer?

A: No, you should not download or install software on your computer without the involvement of your IT team. The software loaded on the Company personal computers is tested to make sure that applications work together, have appropriate security measures, and are properly licensed. Many consumer software vendors do not write software that will work efficiently or securely in a corporate environment.

Q: Can I “borrow” software from the Company and load it on my home computer? It would sure help me be more efficient when I work from home.

A: No. All of the software at the Company is licensed from the software vendor. It would be against The Protocol to “borrow” the software and load it on your home computer.

Additional reference materials (found on integration central)Electronic Communications PolicyPolicy on Handling Proprietary Information of Third PartiesExternal Communications Policy

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35life technologies

transacting international businesssummaryWe are committed to complying with the applicable laws in all of the countries where the company and its subsidiaries do business. Because our parent company (life technologies) is organized and headquartered in the United states, we must follow certain Us legal requirements in conducting our business in other countries. in some cases the laws of one country may conflict with Us law, and local customs and practices may also vary from country to country.

our policy is to comply with Us law or the applicable law in the countries where we do business, whichever is more stringent.

Basic principlesDoing business in new foreign countriesEstablishing the Company operations in any new country carries important legal and tax implications. Therefore, no employee should expand the Company’s operations or distribution network into any new foreign country without prior consultation with the Company’s Chief Legal Officer.

foreign corrupt practices ActThe Company prohibits any payment to any person in order to obtain an advantage in selling goods or services to a customer.

t The US Foreign Corrupt Practices Act (FCPA) prohibits payments to foreign officials for the purpose of obtaining or retaining business.

t The FCPA applies to the Company, any of its employees, and anyone acting on its behalf.

t It is a felony under the FCPA to give, offer, promise, or

The actin cytoskeleton of a fixed and permabilized Muntjac skin fibroblast

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36 the protocol

authorize a payment to a foreign official, foreign political party or official thereof, or any candidate for foreign political office, in connection with obtaining or retaining business.

t It is also illegal under the FCPA to pay a commission agent, sales representative, or consultant if you know or have a firm belief that the payment will be used to influence a government official to obtain or retain business.

t The FCPA also requires the Company to maintain a system of accounting that ensures accurate and complete records of all financial transactions.

red flags

Watch out for “red flags” that might indicate our products could be diverted to an improper destination, end user, or end use. for example, the company cannot export a product if it has reason to suspect that the product will be used in prohibited nuclear, missile, biological, or chemical weapons proliferation activities. specific red flags might include:

t A customer who is evasive when asked about the end user of the product

t Atypical payment terms (such as cash)

t Abnormal order amounts for the destination

t out-of-the-way destinations

t excessive quantities relative to the customer’s production capabilities

call the company’s regulatory counsel about any suspicious orders.

Antiboycott lawsIn response to the Arab countries’ boycott of Israel, the US enacted the so-called “antiboycott laws.” In general, these laws:

t Prohibit us from refusing to do business with any person because of such a boycott

t Prohibit us from furnishing any information to any boycotting country or to companies in a boycotting country that relate to the Company’s dealings or lack of any dealings with Israel or any other boycotted nation

t Require us to report the mere request for such information to the government

export controlsAll products and technology exported by the Company from the US to another country must either be covered by an export license or a license exception. “Exports” obviously include products, but can also include technical conversations with a citizen of another country, even though that conversation takes place entirely within the United States.

Export control regulations are complex. All employees involved in export transactions must understand these laws and strictly comply with the Company’s Export Policies and Procedures. If there is any doubt, consult the Company’s Chief Legal Officer or Regulatory Counsel.

Apoptotic human keratinocytes

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37life technologies

“the protocol gives me the courage to ‘just ask’ when something seems a bit odd. regularly revisiting the protocol demonstrates that the company has a commitment to integrity.”

Allegra Helfenstein eugene, oregon

embargoed countries and blocked/denied personsUS law prohibits US companies and their foreign subsidiaries from transacting business with Cuba, Iran, Syria, North Korea, and Sudan, as well as certain entities and individuals who are engaged in terrorism or drug trafficking. There are also special restrictions on transactions with certain companies and government entities in Russia, China, India, Israel, and Pakistan.

These restrictions change from time to time. For a current list of prohibited countries, please refer to the Legal Department’s Compliance section on Integration Central or contact the Company’s Chief Legal Officer.

Because export laws are so complex, we have designated specific individuals as export compliance representatives. They can serve as a resource for you on export compliance issues.

For further information, refer to the Legal Department’s Compliance section on Integration Central.

customs, laws, and regulationsWhen we import merchandise into the United States and other countries, we must comply with all applicable customs, laws, and regulations. These generally require us to provide accurate information to the customs agency for all import transactions, pay all duties and charges owed, and maintain all records required by customs law.

The Company employees involved in import operations must be familiar with the relevant provisions of the law, regulations, rulings, tariff schedules, and decisions applicable to the Company’s importing operations. These employees must also be familiar with the terms of import transactions, and with the description, use, valuation, and country of origin of the merchandise imported by the Company.

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that the items ordered be shipped to a restaurant located in a small town. What should you do?

A: Because this situation raises multiple red flags that indicate a risk of diversion to an improper end use or end destination, you should hold off on setting up the new account, and contact the Legal Department immediately. Red flags: t Residential billing address t Unusual customer information t Unusual shipping address These red flags must be investigated before proceeding with the transaction.

Q: Bribes are viewed very differently depending on the country. What is viewed as a bribe in one country might be an expected payment in another. How can I reconcile these differences?

A: You must not make a bribe or payment to any government official or any other individual. No matter what is customary, you are expected to comply with The Protocol and conduct your business affairs accordingly. Please contact the Legal or Compliance Department with further questions.

Q: While negotiating a large sale of next generation sequencing equipment to a government-owned institution, you become aware of a cash payment that will be made to a distributor as a finder’s fee.

A: All sales to government-owned institutions are subject to the FCPA and other anti-bribery laws. The Legal Department should be consulted immediately for further advice. Red flags: t Cash payment t Finder’s fee t Distributor payment t Government institution

Additional reference materials (found on integration central)

Guidelines for Compliance with the Foreign Corrupt Practices ActExport Policies and ProceduresPolicy on Employee Access to Technology Import Policies and Procedures Manual

practical examplesQ: You are a US employee who travels to several foreign countries. During one of your visits, you take small inexpensive personal gifts to be given to key customers. Is this a violation of the FCPA requirements?

A: Not necessarily; however, all gifts given to customers should be cleared with the Legal Department. In addition, many countries preclude all governmental officials from accepting gifts of any type. See the Working with Governments section of The Protocol.

Q: One of your foreign customers needs a product to complete a critical development project. Is it OK to pay a small gratuity to expedite this product through customs?

A: No. The FCPA and The Protocol do not permit payments to government officials as part of an effort to obtain or retain business. Other companies have been prosecuted for making payments to customs officials to expedite customs clearance, under the argument that the payments assist the company in retaining business (or obtaining future business) with the recipient of the product or services being delivered. Any questions about these kinds of payments should be directed to the Legal Department.

Q: A customer working for a research institution in Canada places an order for one of the Company’s transfection reagents. During a routine review of the paperwork, you notice that the end user of the product is a company based in Iran. Should you proceed with the order?

A: No. You have information indicating that the end destination for some part of this order may be Iran, a prohibited country. US law prohibits the Company from shipping products that it knows or has reason to believe are destined for an embargoed country, even if the customer who placed the order is not located in an embargoed country. You should immediately put the transaction on hold, contact your supervisor or the Legal Department, and wait for further instructions. The Legal Department will investigate the situation and determine the appropriate course of action.

Q: A new customer calls to set up an account with the Company. He gives you his billing address, which turns out to be his private residence. When you ask him about his proposed end use for the products he refuses to discuss it, claiming that “the information is proprietary.” The caller also requests

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39life technologies

Quality and regulatory compliancesummaryWe are committed to “tangible Quality” in our products and services.

Basic principlestangible Qualityt For our customers, Tangible Quality means that our customers can rely on our products and services to consistently meet or exceed expectations.

t For regulatory authorities, Tangible Quality means the Company meets or exceeds all applicable regulatory requirements and operates according to the highest ethical standards.

t For our employees, Tangible Quality means that every day we take full ownership for quality in our individual tasks, perform our jobs with the highest integrity, and understand and apply all appropriate regulatory requirements. Any type of unethical behavior, violation of Company policies, or intentional deviation from critical operating procedures is not acceptable.

t For our organization and culture, Tangible Quality means having a culture dedicated to superior quality, with the leadership, systems, internal controls, and resources necessary to promote that culture.

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Q: A US customer phones the Company’s Tech Services group and states that the product he received did not work. A Company Tech Services representative determines that the product is not a RUO product, but a regulated product. The Company representative documents the discussion and forwards the complaint to the Quality Assurance department at the appropriate site. The customer is told the product return is being investigated. Did the Company Tech Services representative do the right thing?

A: Yes. To comply with Health Authority regulations for regulated products, the complaint must be evaluated by Quality Assurance.

Q: Manufacturing is extremely busy, and the backlogs are increasing. As a supervisor you decide to bypass several of the sterilization steps outlined in the manufacturing protocol to speed up the manufacturing process and reduce the backlog. These protocol steps are clearly excessive, as the treatment baths are sufficient to sterilize the containers. Are you overstepping your supervisory responsibility in making these changes?

A: Yes. Many of our manufacturing processes are regulated by governmental agencies and must follow strict operating procedures. If these protocols seem redundant or unnecessary, review them with your manager or quality personnel at your site before you attempt to implement any changes.

practical examplesQ: Tim has been diligently working on the production of a key product for the last several weeks. He has found out that after final QC testing, the product is cloning at a 91% efficiency and not the 92% rate required by the product specifications. After reviewing the potential customers and their requirements, Tim has determined the cloning efficiency of 91% is sufficient for our customers’ use and adjusts the numbers and records to reflect a 92% cloning rate. Why is this inappropriate?

A: Because Tangible Quality does not mean changing the standards when it’s convenient to do so. Tim must accurately reflect the efficiency rate in all his reports.

Q: A “Research Use Only” (RUO) product was sold by a Company Sales Representative to a research lab. The lab purchased the product and then told the Company Sales Representative that they were planning to use the product in a clinical environment for clinical diagnostic purposes. Knowing that the research lab is planning to use the RUO instrument for clinical diagnostic purposes, what should the Company Sales Representative do?

A: The Company Sales Representative should inform the lab that the RUO instrument can only be used for research applications, and cannot be used for any clinical diagnostic purposes, because it has not been approved by Health Authorities for clinical diagnostic use.

Q: The Company’s regional office becomes aware that a country has just implemented new regulations requiring registration by the end of the year for currently marketed IVD products. The Company’s Global Regulatory team makes the submissions in time; however, the approval for a few of the products has not been received by year end. The Company’s regional office decides to continue selling those products, as the required information has been submitted to the Health Authorities. Is the regional office making the correct decision?

A: No. By continuing to market the still unapproved products past the year-end deadline, the Company is out of regulatory compliance. The result could be product recalls and potential fines. The regional office must stop selling products which have not received approval, and work with the Company’s Global Regulatory team to complete the registrations and necessary approvals.

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41life technologies

Working with governmentssummarythe company conducts business with the Us government and with many federal, state, and local governments and government agencies worldwide. the company and its employees must observe special legal and regulatory requirements when doing business with government entities.

Basic principlesBribery, kickbacks, or other improper paymentsBribery, kickbacks, and other improper payments have no place in the Company’s government contracting and other business. All employees who come into contact with government officials must maintain the highest professional standards.

Employees should never offer anything of value to government officials to obtain a particular result for the Company. Bribery of government officials can lead to criminal penalties. The Company’s government contracts prohibit the making of payments to government employees and the employees of other contractors in a variety of different situations.

political activitiesGovernment laws and regulations can have a significant impact on the Company’s business. Therefore, the Company interacts with federal, state, and local policymakers, primarily through the VP of Government Relations and senior executives. It is the Company’s policy to comply fully with all federal, state, and local laws dealing with government lobbying activities and political contributions.

Three gene targets in a whole-mount Drosophila embryo

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“ethical principles shape employee behavior from the perspective that it makes you think of yourself not as an individual working on your own, but rather as a representative of the company, and how your decisions, actions, and behaviors can affect the reputation of the company. the protocol has an unquestionably positive impact on the working environment at life technologies. on a daily basis it makes you question what you do and how you do it, and gets you thinking ‘Am i doing the right thing?’ in all aspects of your job and the people you deal with.”

Claire Bolton paisley, scotland

Multicolor fluorescence analysis of mouse cerebellum cross section

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43life technologies

lobbyingThe Company’s US lobbying activity is conducted in accordance with all applicable federal regulations, including the Lobbying Disclosure Act. US federal lobbying laws prohibit gift giving to members and staff of the US Congress by the Company and any employees. State and local lobby and government ethics laws also impose restrictions upon the Company, its employees, and consultants. The Company and its employees must disclose all lobby and related political activity on behalf of the Company. Compliance with these regulations is facilitated by the VP of Government Relations.

fundraising and political contributionsThe Company and its employees may engage in political fundraising and donations consistent with federal, state, and local laws.

The Political Action Committee (PAC), established by the Company, will make campaign contributions consistent with federal law, and the bylaws and giving guidelines of the PAC. No employee’s political contribution shall be reimbursed by the Company. The Company supervisors may not require or coerce the participation of any employee in a political fundraising activity.

The Company systems and facilities may not be used to support political activities without the advance approval of the VP of Government Relations, and in no event can that use be more than incidental (i.e., does not affect the Company’s expenses), unless reimbursed by the candidate. The posting of politically oriented materials on the Company property is prohibited.

These restrictions are not intended to limit the right of individuals to participate in the political process and to make individual contributions. Any questions regarding political activities and fundraising should be directed to the Director of Government Relations.

government contractsEmployees who support the Company’s government contracts must comply with the terms of these contracts, the Company’s policies and procedures regarding government contracts, and all related laws and regulations.

All pricing on federal government supply schedules must be carefully reviewed by the Government Contracts group in

the Legal Department so the Company does not violate its contractual obligations. Any failure to properly address contractual issues with the government can have serious consequences for the employee and the Company, including criminal prosecution and/or suspension and preclusion from participation in government contracts.

government investigationsIt is our policy to cooperate fully with government investigations. It is imperative that the Company and its employees be properly represented by legal counsel during an investigation. If you believe that a government investigation or inquiry has begun, you should immediately contact the Company’s Chief Legal Officer. This policy does not apply to routine dealings with the government (e.g., tax audits, audits from Labor Department personnel, or health, safety, and environmental inspections).

Sometimes it is difficult to tell when a routine government audit or inspection graduates into a government investigation. In case of any doubt, employees should consult with the Company’s Chief Legal Officer. Appropriate handling of government investigations is very important for the Company, for manage-ment, and for all employees. Virtually all of the federal laws and regulations covering the Company’s business—including antitrust, securities, government procurement, tax, financial dis-closure, OSHA, environmental, food and drug—contain civil and criminal penalties. Both types of penalties apply to companies and to any individuals within a company who violate the law.

Prohibited actions in a government investigation include:

t Destroying Company documents in anticipation of a request for those documents from any government agency or a court

t Altering Company documents or records

t Lying or making any misleading statements to any government investigator

t Attempting to cause any Company employee, or any other person, to fail to provide information to any government investigator or provide any false or misleading information

If you should receive a government inquiry in the form of a written subpoena or written request for information (such as a Civil Investigative Demand), you should give it to the Company’s Chief Legal Officer immediately—before taking or promising any responsive action.

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44 the protocol

practical examplesQ: A federal supply schedule currently in place with NIH has specific pricing for TaqMan® gene expression assays. What are the consequences if TaqMan® is sold to the Company’s commercial customers below the pricing on the federal supply schedule?

A: It is against the law and could have serious repercussions that could potentially preclude the Company from participating in any government contract opportunities. All government pricing issues should be reviewed with the Government Contracts group.

Q: During the last few years as a government–focused sales rep- resentative, you have worked closely with several NIH employees. As a token of your appreciation, you give this NIH department (where these employees work) a small gift basket. Is it permissible to give a gift to this government department?

A: In most cases in the US and other countries it is against the law to provide business associates of the government with any gifts, meals, or forms of entertainment. In this case, the gift was small, presumably inexpensive, and was given to the entire NIH department and is probably appropriate; however, all gifts given to any government entity should be reviewed by the Government Contracts group in the Legal Department.

Q: Allison is very active and supportive of a local politician in her Scottish council. She dedicates most of her free time to the support of this candidate. The candidate is supportive of the Company’s operations and is campaigning on a pro- business platform. As elections near, Allison would like to place posters, signs, and placards on the Company facilities in support of this candidate. Is this permissible?

A: No. The Company’s assets and facilities should not be used for political purposes. The Company encourages employees to dedicate their time and resources to important causes and be active in their community, but use of assets and facilities is prohibited.

Q: At the annual BIO convention and meeting, the Company’s marketing team has organized a promotional campaign to generate leads to increase sales of the iBlot®® product. Any potential customer who completes a short survey and attaches a business card will be eligible for a prize-drawing to visit our iBlot®® manufacturing facility in Israel. Is this an acceptable promotion?

A: No. All of the Company’s US Government customers, most academic customers, and some of our industrial customers are prohibited from accepting any gifts. All corporate promotions must be reviewed with the Government Contracts group in the Legal Department.

Additional reference materials (found on Integration central)Disclosure PolicyPolicy on Political Activities

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45life technologies

environmental stewardship and workplace safetysummaryWe are committed to compliance with all applicable environmental, health, and safety laws, and related policies. We seek to protect the environment and the health and safety of our employees, our customers, and the people in the communities where we operate. every employee is responsible for conducting business in this manner.

Basic principlesenvironmentThe Company expects employees to be proactive in ensuring compliance with environmental laws and regulations. We seek continual improvement of management systems for compliance and risk control, and support these actions by ongoing auditing and corrective action programs.

health and safetyThe Company is subject to a variety of regulations concerning health and safety. We have policies and procedures addressing these issues. Further, we conduct regular training and routine auditing relating to health and safety compliance. Every Company employee is responsible for ensuring that both the letter and the spirit of these policies are fully implemented. Employees should promptly inform higher management of any suspected compliance deficiencies and any health, safety, or environmental incident, such as an accident or release of hazardous materials.

The Company commits to continual, practical, and cost-effective improvements in the Environmental, Health, and Safety (EHS) performance of our products, processes, and services. It is senior management’s objective and the responsibility of every employee to operate the businesses in a manner consistent with the following principles:

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46 the protocol

t Comply with applicable EHS law and internal requirements

t Consider relevant industry standards

t Protect our employees, customers, communities, environment, property, and assets by managing the risks associated with our products, processes, and services

t Perform EHS due diligence reviews for potential business acquisitions

t Respond swiftly and appropriately to EHS emergencies, allegations, and concerns

t Train employees on relevant EHS topics and hold them accountable for compliance

t Engage all employees in improving EHS performance

t Consider customer and other stakeholder EHS requirements in the product design process

t Collaborate with vendors, suppliers, and contractors to communicate potential hazards

It is the responsibility of EHS functions, within each of the Company business groups and joint ventures, to have appropriate EHS standards and procedures for their employees that incorporate the principles of this policy and the Company standards. Having safety rules is not enough, though. The Company’s commitment to safety means each of us needs to be alert to safety risks as we go about our jobs. All employees are encouraged to bring issues of unsafe behavior or lack of compliance to health and safety standards to the attention of their immediate supervisor, their respective EHS department, or the Compliance Officer.

A safe and secure work environment also means a workplace free from violence. Threats (whether implicit or explicit), intimidation, and violence have no place at any Company site and will not be tolerated.

WeaponsWeapons—even if used for sporting purposes and obtained by lawful means— are not allowed in the workplace without prior written authorization from the site manager. In Europe, no weapons of any kind are permitted in the workplace, under any circumstances.

Alcohol and drugsEmployees are required to abide by all applicable laws and regulations relating to the possession or use of alcohol and drugs. It is a violation of the Company policy to be under the influence of alcohol or illegal drugs in the workplace.

The use of alcohol is prohibited on the premises of the Company, except to the extent consumed in a responsible manner at a social event approved by senior management. We strictly prohibit the possession, use, sale, purchase, or transfer of illegal drugs (which includes having such drugs in your body) on the Company premises. The same prohibitions apply when you are on the job for the Company at a location other than the Company’s facilities.

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practical examplesQ: A sign indicating Personal Protective Equipment (PPE) requirements is posted at the laboratory entrance door. Safety glasses, lab coats, and closed-toed shoes are required PPE before entering the lab. You feel that all the safety apparatus is a hassle, hinders your creativity, and besides that, you are incredibly careful while handling toxic chemicals. It is your body if anything happens. Why do you need to wear the required protection?

A: The protection is required by law and you will be in violation of The Protocol and other applicable laws if the procedures are not followed.

Q: While working on the manufacturing assembly line you witnessed a near accident. An employee’s lab coat was not buttoned properly and got caught in the assembly machinery. Fortunately, the machinery was shut down before the employee was seriously hurt. The accident report submitted only reported that the employee slipped and fell. What responsibility do you have to report this incident properly?

A: As a Company employee you have a responsibility to ensure all accidents are reported properly (including appropriate paperwork). You should contact the EHS and Legal Departments and your HR representative.

Q: Your site has had a stellar reputation for reducing injuries over the last five years. Your site has had a perfect safety record for the past year. Today, you saw one of your coworkers cut his arm. He chose not to report the injury, stating that it was only a “flesh wound” and not serious. Do you have a responsibility to report the incident?

A: Yes, it is vital to the goal of continued improvement in workplace safety that all injuries be reported. If your coworker is unwilling to report the injury, you should report the incident to your supervisor.

Q: At one of our new manufacturing locations, the procedures were not properly followed, which resulted in the improper disposal of a large amount of toxic chemicals. The EHS representative was not notified and only found out about the release of toxic chemicals when she was contacted by a federal regulator reviewing the waste water disposal records. What should be done now?

A: Following government cleanup operations is imperative. The Company is committed to being a good corporate citizen and complying with all environmental laws and regulations applicable to every location wherein we operate. In many cases, if a release of toxic chemicals is determined quickly, mitigation efforts can be implemented to control the environmental damage. Disposal of toxic chemicals without proper treatment is unacceptable and can damage our health as well as the health of our community by contaminating the water, air, and soil.

Q: Marilyn is responsible for verifying that all products shipped on dry ice are properly labeled. While preparing to ship a large back order, the labeling equipment jammed and several boxes were mislabeled. Due to time constraints and the pressure to ship the back order, Marilyn did not verify that all products were properly labeled. What are the potential repercussions of this decision?

A: Any products improperly labeled present significant risk to the Company and others. Federal regulators could levy fines and potentially shut down our operations. There could be legal liability and product safety issues. The Company is obligated to review all products for adherence to pertinent transportation, labeling, and commerce regulations prior to shipping. If you have responsibility for verifying that shipments are accurate, you must complete that task.

Additional reference materials(found on integration central)Global Environmental, Health, and Safety PolicyDrug and Alcohol Abuse PolicyDrug and Alcohol Testing Policy

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implementing the protocolliving the protocol

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50 the protocol

living the protocolWhen i discuss the protocol with the Board or senior management, we almost never discuss rules. the protocol has lots of rules—it refers you to other rules, laws, and regulations. We know where to find the rules. What we discuss instead are principles. We discuss the kind of culture we are creating and whether it supports compli-ance with the protocol and other corporate policies. We talk about simple, broad principles like integrity and doing what’s right, because if we start with that kind of foundation, complying with the rules is a natural result.

We also talk about creating an environment where integrity and ethical corporate action can thrive. so that’s what we ask that you do to implement the protocol—help create a working environment based on principles of integrity, ethics, and character. then, use the protocol to guide specific actions within that context.

ManagersWhen managers ask how they should implement the protocol, i refer them to the book Crucial Conversations, which describes how to create an environment that encourages frank and open communication on difficult issues. for the protocol to be meaningful to your employees, they must feel free to raise issues with you without hesitation. As a manager, you must create the environment that gives them that freedom.

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All employeesi also encourage all employees to learn the skills of open communication discussed in Crucial Conversations. learn how to approach your boss, fellow employees, or third parties with difficult compliance issues. if you master these skills, you will help us create the type of environment in which we all want to work, you will increase your prospects for career advancement, and you will learn how to become a truly influential person. Don’t believe it? read the book, and learn about the 20+ years of research the authors did to identify the skills—the learnable skills—of people who are exceedingly influential in organizations. then, apply what you learn in your workplace.

one great benefit that comes to an employee and the company if we are successful in mastering these skills is that we develop an ability to deal with issues before they become compliance problems. trust me—for you, me, and the company, that’s infinitely better than trying to patch things up after a violation of law has occurred.

so help us catch these issues up front and continue to make life technologies a respected, principles-based company.

John Cottingham chief legal officer and secretary

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Basic principlesAll employees, officers, and directors of the Company and its subsidiaries are required to comply with The Protocol and related policies and procedures. Failure to comply can result in disciplinary action up to and including termination of employment. In addition, violations of The Protocol could be against the law and could result in criminal or civil penalties. A breach of the compliance rules can lead to serious consequences for both the Company and the Employee.

We do not expect you to become a legal expert as a result of reading The Protocol. We do, however, expect you to comply with it, to be generally aware of certain laws and regulations, and to recognize sensitive issues. Most important, we expect you to seek advice when necessary.

Compliance with The Protocol is a key factor in performance evaluations. In this context, you should think of “compliance” in broad terms. It includes abiding by the specific rules and underlying spirit of The Protocol and other Company policies. It also includes exercising leadership and moral courage to do the right thing. It includes reporting violations if they occur, ensuring that there is no retaliation against employees for reporting violations, and cooperating in any investigations that are needed.

leadership obligationsIt is crucial that all leaders in the Company promote The Protocol within the groups that they lead. The Company expects all employees in leadership roles to help build an environment in which compliance is part of the fabric of the Company.

Leaders should:

t Use operating mechanisms that identify compliance problems in advancet Train employees on compliance issuest Audit for compliance in their areas of responsibilityt Personally lead compliance and ethics trainingt Incorporate compliance into performance reviews and employment decisionst Recognize and reward employees for acting with integrity and complying with The Protocol

If a leader becomes aware of risks or potential violations of The Protocol, he or she must promptly communicate these matters as described in the section titled “Protocol for Raising Concerns.”

Annual certificationsIt is a condition of employment that once during each calendar year each employee must complete a certification form as part of the annual online Protocol training. The Compliance Officer summarizes the certifications and makes a report to the Audit Committee.

initial employee certificationEach new employee is required to complete the online Protocol training and employee certification.

remember, it is always better to ask questions first so that problems can be avoided later.

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Value to customers ohio state University college of Medicine

“one of the core values at ohio state University Medical school is ‘integrity–we promote ethical standards in our daily conduct and duties.’ it is important that our product and equipment suppliers have the same high standards and professional integrity. We have been working with Applied Biosystems for several years in the area of genetic research and sequencing. We have confidence in their professional conduct and integrity.”

Hansjuerg Alder, PhD research professor Director, nucleic Acid shared resource ohio state University comprehensive cancer center

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protocol for reporting concernsWhom do I contact if I need to report a protocol issue?

t protocol helpline: +1.866.854.2783t online protocol helpline: www.lifetech.silentwhistle.comt Your Supervisort hr representative: See up-to-date listing on Integration centralt employee relations: See up-to-date listing on Integration centralt chief legal officer: John cottingham (+1.760.476.6987)t compliance officer: John Skousen (+1.760.603.6408)t Site ombudsperson: See up-to-date listing on Integration central

the protocol helplineMost issues can be resolved by direct communications between the affected parties. However, if you are ever unsure about where to go, or are uncomfortable about using one of the other resources identified in The Protocol, you may do the following:

t First, you can email your question to Protocolhelpline@lifetech.com. Because of the email return address, this obviously is not an anonymous report.

t You can call The Protocol Helpline by dialing +1.866.854.2783. A call to the Helpline is anonymous; however, you will be invited by the operator to disclose your identity. Your information will be kept confidential and revealed only to the persons in charge of the investigation. The Company encourages you to provide this information to assist with the investigation. If you wish to remain anonymous, however, the operator will comply with your request.

t You can also send a confidential email report online at www.Lifetech.silentwhistle.com.

Please refer to the Ethics and Compliance community on Integration Central for the most up-to-date information.

Speak up early and help avoid serious problems later.In many cases, compliance issues can be handled easily in the early stages. So be vigilant, report your concerns, and help the Company keep minor issues from evolving into more serious problems. Help the Company maintain a strong reputation for integrity and compliance.

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What happens when you raise a concern?If you report a potential violation, we will initiate an investigation, gather information, analyze the findings, determine an appropriate resolution of the issue, and provide feedback to you about the results.

reporting protocol issues in the european UnionSee Appendix

Where to go for helpNo code of business ethics can address every situation, and ethical behavior is ultimately the responsibility of the individual employee. What should you do if you have a question or concern about compliance and integrity standards? The most important thing is that you ask the question or raise the concern. Employ-ees who become aware of suspected misconduct, illegal activi-ties, fraud, abuse of Company assets, or violations of The Protocol—or who have any questions regarding the application of The Protocol to any particular situation—should discuss these matters with their immediate supervisor, if appropriate. If for any reason an employee is uncomfortable with this approach, he or she is encouraged to promptly contact the Compliance Officer by telephone, writing, or email.

John Skousen Compliance Officer Life Technologies 5791 Van Allen Way Carlsbad, CA 92008 +1.760.603.6408 John.skousen@lifetech.com

Prompt and appropriate corrective action will be taken in response to all valid complaints. The Compliance Officer may seek assistance from other departments depending on the nature of the allegation.

In addition, outside legal counsel may be involved if a violation of the law is alleged. The matter may also be referred to an appropriate law enforcement agency. The investigation procedure will include a review of all pertinent documents and interviews with employees, as appropriate, who will be treated with respect and dignity. The identity of the complaining

individual will remain confidential to the fullest extent possible, consistent with the need to conduct an adequate investigation, and as local law permits.

At the conclusion of an investigation, the person conducting the investigation shall make a determination that includes:

t Whether a violation occurred

t Recommendation for disciplinary action (if any)

t Whether the investigation revealed the need to create or strengthen policies, procedures, or internal controls to prevent similar violations in the future

non-retaliation policyAny employee, who, in good faith, seeks advice, raises a concern relating to a potential compliance issue, or reports suspected misconduct, is doing the right thing. The Company will not discharge, demote, suspend, threaten, harass, or in any other manner retaliate or discriminate against any employee based upon any lawful actions of such employee with respect to good faith reporting of complaints or violations, unless the employee is found to have knowingly and willfully made a false report. Individuals engaging in retaliatory conduct will be subject to immediate disciplinary action, which may include termination of employment.

If you suspect that you or someone you know has been retaliated against for raising a compliance or integrity issue, contact the Compliance Officer or call The Protocol Helpline.

practical examplesQ: One of the employees who reports to you recently told you in confidence that she had reported a Protocol violation via the Compliance Helpline about a past supervisor who was allegedly falsifying financial statements. How should you treat this employee?

A: She should be treated like any other employee. The Company has a strict non-retaliation policy that prohibits any employee from retaliating against anyone for reporting a potential Protocol violation. If you become aware of any form of retaliation against this employee, you should report your concern to the Chief Legal Officer or the Compliance Officer immediately.

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Tubulin in a live bovine pulmonary artery endothelial cell.

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resources

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resource directorycorporate complianceJohn Skousen Compliance Officer 5791 Van Allen Way Carlsbad, CA 92008 John.skousen@lifetech.com +1.760.603.6408

ombudspersonSee Integration Central for the up-to-date site Ombudsperson

human resourcesSee Integration Central for the up-to-date Employee Relations and HR representatives

FinanceKelli Richard Vice President, Corporate Controller Kelli.richard@lifetech.com +1.760.268.7436

legalJohn Cottingham Chief Legal Officer and Secretary John.cottingham@lifetech.com +1.760.476.6987

confidential helpThe Protocol Helpline: +1.866.854.2783 or Online: www.Lifetech.silentwhistle.com Mail: John Skousen Compliance Officer 5791 Van Allen Way Carlsbad, CA 92008 Confidential email: John.skousen@lifetech.com

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Appendix

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60 the protocol

reporting protocol issues in the european UnionDue to new French privacy laws and the Article 29 Working Group decision regarding the other European Union countries, calls to The Protocol Helpline concerning issues raised in any country in the European Union must meet certain conditions:

1. The purpose of the Helpline when calling about a facility in one of the EU countries is to facilitate the confidential reporting of concerns related to accounting, auditing, or other financial practices of the Company.

2. The types of issues that may be reported upon include:

a. Antitrust or Fair Trading Violation b. Espionage or Sabotage c. Falsification or Destruction of Business Records d. Falsification of Financial Records e. Falsification of Travel and Expense Reports f. Improper Gifts and Entertainment g. Misrepresentation of Information h. Trading on Inside Information i. Unlawful or Improper Payments j. Other actions jeopardizing the vital interest of the Company

3. If your call pertains to something other than the above matters, you are encouraged to report your concerns to local management, HR, or through other internal reporting channels.

4. A call to the Helpline is anonymous; however, you will be invited to disclose your identity, which will be kept confidential and revealed only to the persons in charge of the investigation. The Company urges you to provide this information.

When calling the Helpline: Make a collect call to ++1.866.854.2783

The Company has a Non-retaliation Policy as specified on page 55 of this document.

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life technologies protocol— We are responsibleemployee certificationi acknowledge that i have received, read, and understood life technologies protocol. i agree to comply with the policies described in the protocol and certify that, to the best of my knowledge, i am not violating any of the policies and will not do so in the future. i understand that failure to comply with the protocol can result in disciplinary action up to and including termination of employment as well as other legal penalties. i am not aware of any unreported violations of the protocol and if i become aware of a violation or have a concern about a possible violation, i will raise the concern in a manner described in the protocol.

signature:

print name:

Date:

SAMPLE. NOTFOR SIGNATURE.

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60. helpline in eU 58. human resources 27. insider trading 35. international Business 32. internet Use 41. Kickbacks 30. loans 43. lobbying34. Media, communications with 26. Money laundering 55. non-retaliation policy 58. ombudsperson 43. political Action committee 43. political contributions 34. press releases 25. privacy 60. privacy (helpline in eU) 19, 43. promotions (sales) 24. proprietary information 54. protocol helpline 23, 24. record Keeping 54. reporting concerns 55. retaliation (policy against) 45. safety 28. section 16 reporting 34. software 29. stock ownership 28. tipping 18. tying 32. Voice Mail 45. Workplace safety

index

46. Alcohol 36. Antiboycott laws17, 19, 43. Antitrust 23, 24. Books and records 18, 36. Boycotts38, 41. Bribery 29, 35. Business transaction conflicts 61. certification form 12. commitment to integrity 32. communications 32, 34. communication with the Media 30. company property (Use of)17, 30. competition laws 54. compliance helpline 54, 55. compliance officer 29. conflicts of interest 24. confidential information 37. customs laws 23. Data integrity 14, 15. Discrimination 14. Diversity 24, 25, 26. Document retention 46. Drugs 32. electronic communications 32. email 37. embargoed countries, Denied parties 45. employee health and safety 14,15. employment law45. environmental law 36. export controls 24. financial records 35. foreign corrupt practices Act 43. fundraising 30, 31. gifts 24. 41, 43. government contracts 43. government investigations 14, 15, 16. harassment 45. health 54, 58. helpline

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©life technologies

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