Compliance and Transparency

Immunocore’s Code of Business Conduct and Ethics:  https://ir.immunocore.com/corporate-governance/document-charters

Compliance hotline (anonymous): (877) 657-5005

Whistleblower and ethics portal (anonymous): https://www.whistleblowerservices.com/IMCR/

Email (non-anonymous): Compliance@immunocore.com

Immunocore Compliance Program

Effective July 1, 2005, California Health & Safety Code, Sections 119400 – 119402, (“California Compliance Law”) requires that certain pharmaceutical companies doing business in California adopt a compliance program in accordance with the April 2003 publication “Compliance Program Guidance for Pharmaceutical Manufacturers” (“OIG Compliance Guidance”) developed by the United States Department of Health and Human Services Office of Inspector General (“OIG”) and policies for compliance with the Pharmaceutical Research and Manufacturers of America (“PhRMA”) “Code on Interactions with Health Care Professionals” (“PhRMA Code”) within six months of any update or revision of the PhRMA Code. Revisions to the PhRMA Code were implemented/will be implemented in January 2009, October 2019 and January 2022.

Immunocore’s current policies support adherence to the voluntary guidelines that California law will now enforce. Immunocore will enhance its existing policies and programs to cover the formal annual dollar limits required by the law and begin monitoring performance against those limits. For purposes of compliance with the requirements of the California Compliance Law and as part of the Compliance Program, Immunocore has established a specific annual aggregate dollar limit of $2000 on gifts, promotional materials, or items or activities that Immunocore may give or otherwise provide to an individual medical or healthcare professional in California on an annual basis from January 1st to December 31st.