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Stratpharma AG
Modern Slavery Statement

Introduction

This statement is made pursuant to section 54 of the UK Modern Slavery Act 2015 and outlines the steps Stratpharma AG (including its subsidiaries) has taken to prevent modern slavery and human trafficking in our business operations and supply chain. While Stratpharma does not meet the reporting thresholds under the UK Modern Slavery Act or the Australian Modern Slavery Act, we voluntarily comply with these principles to ensure ethical standards in our business. This statement has been approved by the Stratpharma Board of Directors.

Our Business and Supply Chain

Stratpharma AG is a Switzerland-based company specializing in medical devices. Our supply chain involves the procurement of materials from a global network of suppliers. These materials are processed and assembled in various locations in Europe. We recognize that some regions present a higher risk of modern slavery and human trafficking, but we take steps to mitigate those risks through strict monitoring and control processes.

Compliance with International Standards

Stratpharma AG is ISO 13485 certified, ensuring that our supply chain and production processes follow stringent quality management and regulatory standards. Most of our suppliers comply with ISO 13485 ISO 9001 and other relevant international standards, which support adherence to quality management and ethical practices across our supply chain.

Policies and Governance

Stratpharma has implemented strict policies and procedures to prevent modern slavery and human trafficking. Our Employment Policy emphasizes the protection of workers' rights, health, and safety across all operations. We include clauses related to modern slavery in our supplier agreements to ensure compliance with human rights and labor laws.

Supply Chain Due Diligence and Risk Management

We undertake due diligence on our suppliers to assess risks of modern slavery, focusing on regions with higher risks. Our due diligence measures include obtaining Modern Slavery Declarations from key suppliers and conducting risk assessments where appropriate. Through our ISO 13485 certification, we ensure that suppliers are subject to regular audits and monitoring for compliance with ethical labor practices.

Training and Awareness

We provide basic training to employees on modern slavery risks, including how to recognize potential signs of exploitation. This training is reviewed and updated regularly to ensure that staff, particularly those involved in procurement and supply chain management, are equipped to address potential risks. In the future, we plan to enhance these training programs by incorporating emerging best practices in modern slavery prevention.

High-Risk Suppliers Focus

Stratpharma prioritizes monitoring high-risk suppliers and conducting more rigorous audits where necessary. Our focus on compliance with ISO 13485 and other international standards helps ensure that suppliers in these regions meet international standards for labor practices. During regular audits, we assess suppliers for any signs of unethical labor practices, including forced labor and human trafficking.

Collaboration and Future Plans

Stratpharma is committed to working with suppliers and other partners to prevent modern slavery. To date, we have had no reports of modern slavery within our business or supply chain. We remain vigilant and work closely with our suppliers to ensure continuous improvement in labor conditions and compliance with ethical standards. Our focus is on maintaining an open dialogue and supporting our suppliers in meeting the highest standards for worker welfare.

Conclusion

Stratpharma AG remains dedicated to ensuring that modern slavery and human trafficking are not present in our business or supply chain. Our ISO 13485 certification and the additional compliance of suppliers with international standards demonstrate our commitment to upholding ethical standards. We will continue to review and improve our policies and processes to ensure the highest standards across all our operations

Signed:
Luka Valas, Director & Corporate Secretary Stratpharma AG

On behalf of the Board of Directors of Stratpharma AG

October 1st, 2024

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Privacy & Cookie Policy


This website (hereinafter the “Website“) is provided by Stratpharma AG (hereinafter “us” or “we”). Further information about Stratpharma AG:

Stratpharma AG
Aeschenvorstadt 57
CH-4051 Basel
Switzerland
Email: personaldata@stratpharma.com
Phone: +41 61 691 12 80


Handling of personal data

In the following we wish to provide you with information on how we handle your personal data when you use our Website. Unless otherwise indicated in the following sections, the legal basis for the handling of your personal data results from the fact that such handling is required to make available the functionalities of the Website requested by you (Art. 6(1)(b) General Data Protection Regulation).

A. Using our Website

1. Accessing our Website

When you access our Website, your browser will transfer certain data to our web server. This is done for technical reasons and required to make available to you the requested information. To facilitate your access to the Website, the following data are collected, briefly stored and used:
• IP address
• Date and time of access
• Time zone
• Content of request (specific site)
• Status of access/HTTP status code
• Transferred volume of data
• Website requesting access
• Browser, language settings, version of browser software operating system and surface

Moreover, to protect our legitimate interests, we will store such data for a limited period of time in order to be able to initiate a tracking of personal data in the event of actual or attempted unauthorized access to our servers (Art. 6(1)(f) General Data Protection Regulation).

2. Setting of cookies

1. What are cookies?

This Website uses so-called “cookies”. Cookies are small text files that are stored in the memory of your device via your browser. They store certain information (e.g. your preferred language or site settings) which your browser may (depending on the lifespan of the cookie) retransmit to us upon your next visit to our Website.

2. What cookies do we use?

We differentiate between two categories of cookies: (1) functional cookies, without which the functionality of our Website would be reduced, and (2) optional cookies used for website analysis and marketing purposes. The following tables contain a detailed description of the cookies we use:

FUNCTIONAL

These cookies are required for basic site functionality and are therefore always enabled. These include cookies that allow you to be remembered as you explore the site within a single session or, if you request, from session to session. They help make the shopping cart and checkout process possible as well as assist in security issues and conforming to regulations.

PERFORMANCE

These cookies allow us to improve the site’s functionality by tracking usage on this website. In some cases these cookies improve the speed with which we can process your request, allow us to remember site preferences you’ve selected. De-selecting these cookies may result in poorly-tailored recommendations and slow site performance.

SOCIAL MEDIA AND ADVERTISING

Social media cookies offer the possibility to connect you to your social networks and share content from our website through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond Stratpharma websites. In some cases, these cookies involve the processing of your personal data. For more information about this processing of personal data, check our Privacy & Cookie Policy. De-selecting these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.

3. Subject to your consent

We only use optional cookies if we have obtained your prior consent (Art. 6(1)(a) General Data Protection Regulation). Upon your first access to our Website, a banner will appear, asking you to give us your consent to the setting of optional cookies. If your consent is given, we will place a cookie on your computer and the banner will not appear again as long as the cookie is active. After expiration of the cookie’s lifespan, or if you actively delete the cookie, the banner will reappear upon your next visit to our Website and again ask for your consent.

4. How to prevent the setting of cookies

You may use our Website without any cookies being set. In your browser, you can at any time configure or completely deactivate the use of cookies. This may, however, lead to a restriction of the functions or have adverse effects on the user-friendliness of our Website. You may at any time object to the setting of optional cookies by using the respective objection option indicated above.

3. Website Analysis

Google Analytics
On our Website we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

Google will analyze your use of our Website on our behalf. To this purpose we use, among others, the cookies described in more detail in the above table. The information collected by Google in connection with your use of our Website (e.g. the referring URL, our webpages visited by you, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the USA, where it will be stored and analyzed. The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address during this process. We have activated on our Website the IP anonymizing function offered by Google, which will delete the last 8 digits (type IPv4) or the last 80 bits (type IPv6) of your IP address. Moreover, Google is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to the processing of data by Google in the US.

You may revoke your consent to the use of web analysis at any time, either by downloading and installing the provided Google Browser Plugin or by administrating your consents above, in which case an opt-out cookie will be placed. Both options will prevent the application of web analysis only as long as you use the browser on which you installed the plugin and do not delete the opt-out cookie.

Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics and in the Google Privacy Policy.

4. Use of contact forms

You can contact us directly via the contact forms available on our Website. In particular, you may provide us with the following information:
• Name, surname and title
• Address
• Country
• Contact data (e.g. e-mail address, phone number)
• Message
• Credit Card information


We collect, process and use the information provided by you via the contact forms exclusively for the processing of your specific request.

5. Subscription to our newsletter

On our Website, you may subscribe to receive our newsletter. Based on your prior consent, we will collect and use the email address you indicate for providing you with the newsletter (Art. 6(1)(a) General Data Protection Regulation).
If you wish to receive a customized newsletter, you may, on a voluntary basis, provide us with the following additional information:
• Name and surname
• Title
• Media, Department
• City, Country
• Language
• Subject(s) of interest


For subscription to our newsletter we use the so-called double opt-in procedure. After you have subscribed to the newsletter on our Website, we will send you a message to the indicated email address asking for your confirmation. If you do not confirm your subscription, your subscription will automatically be deleted. In order to prevent any misuse of your personal data, we will log your subscription and confirmation, filing the IP address you use when subscribing, the time of your subscription and confirmation, the messages sent by us regarding your subscription, and the wording of your subscription and confirmation. You may at any time with future effect revoke your consent to receive our newsletter. To declare that you wish to unsubscribe, you may use the respective link included in all newsletters, or refer to the contacts indicated below.

6. External services or content on our Website

We include third-party services and/or content on our Website. When you use such third-party services or when third-party content is displayed, communication data are exchanged between you and the respective provider for technical reasons.
The respective provider of the services or content may also process your data for own additional purposes. To the best of our knowledge, we have configured the services and content of providers known to process data for own purposes in such a way that either any communication for other purposes than to present their services or content on our Website is blocked, or communication only takes place once you have actively opted to use the respective service. However, since we have no control over data collected and processed by third parties, we are not in a position to provide binding information regarding the scope and purpose of such processing of your data. For further information regarding the scope and purpose of such collection and processing of your data, please consult the privacy statements of the providers whose services and/or content we include and who are responsible for the protection of your data in this context:

• YouTube (videos)
• Google Maps


7. Information on side effects and quality complaints

This Website is not intended or designed for communications regarding side effects, lack of therapeutic effect, medication errors, grey market products/counterfeit medicine, incorrect or off-label use, quality complaints and/or other issues regarding the safeness or quality of Stratpharma products. If you wish to report side effects or make a quality complaint, please contact your health care professional (e.g. physician or pharmacist), your local health authority, or use our contact details above.

If you nevertheless report to us undesirable side effects or other issues regarding the safeness or quality of Stratpharma products, we will be legally bound to deal with your communication and may have to contact you for clarification purposes. Subsequently, we may have to notify the competent health authorities of the issues reported by you. In this context, your information will be forwarded in pseudonymized form, i.e. no information by which you may be directly identified will be passed on. We may also have to forward these pseudonymized notifications to our affiliates and distribution partners, to the extent these are likewise obliged to notify their respectively competent health authorities.

8. Use of Publication Order

On our Website, you may order/subscribe to our publications. Based on your prior consent, we will collect and use the address details you indicate for providing you with the publication:
• Surname
• Address (Street, Post code, Town or City, State/Province, Country)
• E-mail adress
• Phone number


You are welcome to provide us with the following optional information:
• Title
• First name
• Company
• Department


9. User Surveys

Participation in the user surveys conducted from time to time on our website is voluntary. We use functional cookies to carry out the user surveys. The technical information recorded by the user survey is the same information that is recorded when users visit the website (see above). Your responses submitted during the user survey will not be linked to your personal data such as your IP address.

B. Transfer of data for commissioned processing

For the processing of your data we will to some extent use specialized service contractors. Such service contractors are carefully selected and regularly monitored by us. Based on respective data processor agreements, they will only process personal data upon our instruction and strictly in accordance with our directives.

C. Processing of data outside the EU / the EEA

Your data will in part also be processed in countries outside the European Union (“EU”) or the European Economic Area (“EEA”), which may have a lower data protection level than European countries. In such cases, we will ensure that a sufficient level of protection is provided for your data, e.g. by concluding specific agreements with our contractual partners (copy available on request), or we will ask for your explicit consent to such processing.

2. Information regarding your rights

The following rights are in general available to you according to applicable data privacy laws: • Right of information about your personal data stored by us; • Right to request the correction, deletion or restricted processing of your personal data; • Right to object to a processing for reasons of our own legitimate interest, public interest, or profiling, unless we are able to proof that compelling, warranted reasons superseding your interests, rights and freedom exist, or that such processing is done for purposes of the assertion, exercise or defense of legal claims; • Right to data portability; • Right to file a complaint with a data protection authority; • You may at any time with future effect revoke your consent to the collection, processing and use of your personal data. For further information please refer to the chapters above describing the processing of data based on your consent.

If you wish to exercise your rights, please address your request to the contact form or to our office indicated below.

3. Contact

For any questions you may have with respect to data privacy, please use the provided contact form or contact our company at the following address:

Stratpharma AG
Aeschenvorstadt 57
CH-4051 Basel
Switzerland
Email: personaldata@stratpharma.com
Phone: +41 61 691 12 80


4. Amendment of Privacy & Cookie Policy

We may update our Privacy & Cookie Policy from time to time. Updates of our Privacy & Cookie Policy will be published on our Website. Any amendments become effective upon publication on our Website. We therefore recommend that you regularly visit the site to keep yourself informed on possible updates.

Last updated: October, 2018

Privacy & Cookie Policy


This website (hereinafter the “Website“) is provided by Stratpharma AG (hereinafter “us” or “we”). Further information about Stratpharma AG:

Stratpharma AG
Aeschenvorstadt 57
CH-4051 Basel
Switzerland
Email: personaldata@stratpharma.com
Phone: +41 61 691 12 80


Handling of personal data

In the following we wish to provide you with information on how we handle your personal data when you use our Website. Unless otherwise indicated in the following sections, the legal basis for the handling of your personal data results from the fact that such handling is required to make available the functionalities of the Website requested by you (Art. 6(1)(b) General Data Protection Regulation).

A. Using our Website

1. Accessing our Website

When you access our Website, your browser will transfer certain data to our web server. This is done for technical reasons and required to make available to you the requested information. To facilitate your access to the Website, the following data are collected, briefly stored and used:
• IP address
• Date and time of access
• Time zone
• Content of request (specific site)
• Status of access/HTTP status code
• Transferred volume of data
• Website requesting access
• Browser, language settings, version of browser software operating system and surface

Moreover, to protect our legitimate interests, we will store such data for a limited period of time in order to be able to initiate a tracking of personal data in the event of actual or attempted unauthorized access to our servers (Art. 6(1)(f) General Data Protection Regulation).

2. Setting of cookies

1. What are cookies?

This Website uses so-called “cookies”. Cookies are small text files that are stored in the memory of your device via your browser. They store certain information (e.g. your preferred language or site settings) which your browser may (depending on the lifespan of the cookie) retransmit to us upon your next visit to our Website.

2. What cookies do we use?

We differentiate between two categories of cookies: (1) functional cookies, without which the functionality of our Website would be reduced, and (2) optional cookies used for website analysis and marketing purposes. The following tables contain a detailed description of the cookies we use:

FUNCTIONAL

These cookies are required for basic site functionality and are therefore always enabled. These include cookies that allow you to be remembered as you explore the site within a single session or, if you request, from session to session. They help make the shopping cart and checkout process possible as well as assist in security issues and conforming to regulations.

PERFORMANCE

These cookies allow us to improve the site’s functionality by tracking usage on this website. In some cases these cookies improve the speed with which we can process your request, allow us to remember site preferences you’ve selected. De-selecting these cookies may result in poorly-tailored recommendations and slow site performance.

SOCIAL MEDIA AND ADVERTISING

Social media cookies offer the possibility to connect you to your social networks and share content from our website through social media. Advertising cookies (of third parties) collect information to help better tailor advertising to your interests, both within and beyond Stratpharma websites. In some cases, these cookies involve the processing of your personal data. For more information about this processing of personal data, check our Privacy & Cookie Policy. De-selecting these cookies may result in seeing advertising that is not as relevant to you or you not being able to link effectively with Facebook, Twitter, or other social networks and/or not allowing you to share content on social media.

3. Subject to your consent

We only use optional cookies if we have obtained your prior consent (Art. 6(1)(a) General Data Protection Regulation). Upon your first access to our Website, a banner will appear, asking you to give us your consent to the setting of optional cookies. If your consent is given, we will place a cookie on your computer and the banner will not appear again as long as the cookie is active. After expiration of the cookie’s lifespan, or if you actively delete the cookie, the banner will reappear upon your next visit to our Website and again ask for your consent.

4. How to prevent the setting of cookies

You may use our Website without any cookies being set. In your browser, you can at any time configure or completely deactivate the use of cookies. This may, however, lead to a restriction of the functions or have adverse effects on the user-friendliness of our Website. You may at any time object to the setting of optional cookies by using the respective objection option indicated above.

3. Website Analysis

Google Analytics
On our Website we use Google Analytics, a web analysis service of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

Google will analyze your use of our Website on our behalf. To this purpose we use, among others, the cookies described in more detail in the above table. The information collected by Google in connection with your use of our Website (e.g. the referring URL, our webpages visited by you, your browser type, your language settings, your operating system, your screen resolution) will be transmitted to a server of Google in the USA, where it will be stored and analyzed. The respective results will then be made available to us in anonymized form. Your usage data will not be connected to your full IP address during this process. We have activated on our Website the IP anonymizing function offered by Google, which will delete the last 8 digits (type IPv4) or the last 80 bits (type IPv6) of your IP address. Moreover, Google is certified under the EU-US Privacy Shield, which ensures that an adequate level of data protection is maintained with respect to the processing of data by Google in the US.

You may revoke your consent to the use of web analysis at any time, either by downloading and installing the provided Google Browser Plugin or by administrating your consents above, in which case an opt-out cookie will be placed. Both options will prevent the application of web analysis only as long as you use the browser on which you installed the plugin and do not delete the opt-out cookie.

Further information on Google Analytics is available in the Google Analytics Terms of Use, the Privacy and Data Protection Guidelines of Google Analytics and in the Google Privacy Policy.

4. Use of contact forms

You can contact us directly via the contact forms available on our Website. In particular, you may provide us with the following information:
• Name, surname and title
• Address
• Country
• Contact data (e.g. e-mail address, phone number)
• Message
• Credit Card information


We collect, process and use the information provided by you via the contact forms exclusively for the processing of your specific request.

5. Subscription to our newsletter

On our Website, you may subscribe to receive our newsletter. Based on your prior consent, we will collect and use the email address you indicate for providing you with the newsletter (Art. 6(1)(a) General Data Protection Regulation).
If you wish to receive a customized newsletter, you may, on a voluntary basis, provide us with the following additional information:
• Name and surname
• Title
• Media, Department
• City, Country
• Language
• Subject(s) of interest


For subscription to our newsletter we use the so-called double opt-in procedure. After you have subscribed to the newsletter on our Website, we will send you a message to the indicated email address asking for your confirmation. If you do not confirm your subscription, your subscription will automatically be deleted. In order to prevent any misuse of your personal data, we will log your subscription and confirmation, filing the IP address you use when subscribing, the time of your subscription and confirmation, the messages sent by us regarding your subscription, and the wording of your subscription and confirmation. You may at any time with future effect revoke your consent to receive our newsletter. To declare that you wish to unsubscribe, you may use the respective link included in all newsletters, or refer to the contacts indicated below.

6. External services or content on our Website

We include third-party services and/or content on our Website. When you use such third-party services or when third-party content is displayed, communication data are exchanged between you and the respective provider for technical reasons.
The respective provider of the services or content may also process your data for own additional purposes. To the best of our knowledge, we have configured the services and content of providers known to process data for own purposes in such a way that either any communication for other purposes than to present their services or content on our Website is blocked, or communication only takes place once you have actively opted to use the respective service. However, since we have no control over data collected and processed by third parties, we are not in a position to provide binding information regarding the scope and purpose of such processing of your data. For further information regarding the scope and purpose of such collection and processing of your data, please consult the privacy statements of the providers whose services and/or content we include and who are responsible for the protection of your data in this context:

• YouTube (videos)
• Google Maps


7. Information on side effects and quality complaints

This Website is not intended or designed for communications regarding side effects, lack of therapeutic effect, medication errors, grey market products/counterfeit medicine, incorrect or off-label use, quality complaints and/or other issues regarding the safeness or quality of Stratpharma products. If you wish to report side effects or make a quality complaint, please contact your health care professional (e.g. physician or pharmacist), your local health authority, or use our contact details above.

If you nevertheless report to us undesirable side effects or other issues regarding the safeness or quality of Stratpharma products, we will be legally bound to deal with your communication and may have to contact you for clarification purposes. Subsequently, we may have to notify the competent health authorities of the issues reported by you. In this context, your information will be forwarded in pseudonymized form, i.e. no information by which you may be directly identified will be passed on. We may also have to forward these pseudonymized notifications to our affiliates and distribution partners, to the extent these are likewise obliged to notify their respectively competent health authorities.

8. Use of Publication Order

On our Website, you may order/subscribe to our publications. Based on your prior consent, we will collect and use the address details you indicate for providing you with the publication:
• Surname
• Address (Street, Post code, Town or City, State/Province, Country)
• E-mail adress
• Phone number


You are welcome to provide us with the following optional information:
• Title
• First name
• Company
• Department


9. User Surveys

Participation in the user surveys conducted from time to time on our website is voluntary. We use functional cookies to carry out the user surveys. The technical information recorded by the user survey is the same information that is recorded when users visit the website (see above). Your responses submitted during the user survey will not be linked to your personal data such as your IP address.

B. Transfer of data for commissioned processing

For the processing of your data we will to some extent use specialized service contractors. Such service contractors are carefully selected and regularly monitored by us. Based on respective data processor agreements, they will only process personal data upon our instruction and strictly in accordance with our directives.

C. Processing of data outside the EU / the EEA

Your data will in part also be processed in countries outside the European Union (“EU”) or the European Economic Area (“EEA”), which may have a lower data protection level than European countries. In such cases, we will ensure that a sufficient level of protection is provided for your data, e.g. by concluding specific agreements with our contractual partners (copy available on request), or we will ask for your explicit consent to such processing.

2. Information regarding your rights

The following rights are in general available to you according to applicable data privacy laws: • Right of information about your personal data stored by us; • Right to request the correction, deletion or restricted processing of your personal data; • Right to object to a processing for reasons of our own legitimate interest, public interest, or profiling, unless we are able to proof that compelling, warranted reasons superseding your interests, rights and freedom exist, or that such processing is done for purposes of the assertion, exercise or defense of legal claims; • Right to data portability; • Right to file a complaint with a data protection authority; • You may at any time with future effect revoke your consent to the collection, processing and use of your personal data. For further information please refer to the chapters above describing the processing of data based on your consent.

If you wish to exercise your rights, please address your request to the contact form or to our office indicated below.

3. Contact

For any questions you may have with respect to data privacy, please use the provided contact form or contact our company at the following address:

Stratpharma AG
Aeschenvorstadt 57
CH-4051 Basel
Switzerland
Email: personaldata@stratpharma.com
Phone: +41 61 691 12 80


4. Amendment of Privacy & Cookie Policy

We may update our Privacy & Cookie Policy from time to time. Updates of our Privacy & Cookie Policy will be published on our Website. Any amendments become effective upon publication on our Website. We therefore recommend that you regularly visit the site to keep yourself informed on possible updates.

Last updated: October, 2018