Ethical use of AI

1 Introduction

Artificial Intelligence (AI) presents transformative opportunities for Orion Corporation (“Orion Pharma”) and to humans and animals using Orion Pharma’s products.  AI technologies can accelerate drug discovery and development, improve diagnostic accuracy and contribute to more effective and efficient healthcare, all of which may significantly benefit patients and the global healthcare sector. These advancements align with Orion Pharma’s commitment to delivering innovative and impactful therapies to enhance innovation, improve operational efficiency, and deliver value to patients, healthcare professionals, and society. 

The use of AI must be guided by ethical principles that ensure trust, fairness, transparency, and sustainability. Orion Corporation is dedicated to upholding the following guiding principles in all business applications of artificial intelligence.

2 Guiding Principles

2.1 Responsible and Value-Centric

AI must be used to create positive societal impact, aligned with Orion Pharma’s mission to build well-being and the principles outlined in Orion Pharma Code of Conduct. We commit to responsible innovation, balancing opportunities with potential risks, and ensuring AI supports our strategic goals and stakeholder interests.

2.2 Human-Centric

We use AI only to enhance – not  replace – human capabilities. Orion Pharma promotes a cooperative model of human-AI interaction, ensuring that AI provides meaningful support to employees, healthcare professionals, and humans and animals who use Orion Pharma’s products.

2.3 Rights-Respecting

We uphold human rights in all AI applications. This includes protecting privacy, preventing discrimination, and safeguarding vulnerable populations. Data aggregation and use must be purposeful, lawful, and respectful of individual rights.

We recognize the strategic importance of safeguarding our own rights, such as Orion Pharma’s intellectual properties, trade secrets, and proprietary data, in the development and application of AI technologies. We also respect the rights of third parties. Accordingly, we are dedicated to ensuring that all AI systems are safeguarded in accordance with relevant laws and internal policies, and that users receive comprehensive training as required.

2.4 Transparency and Explainability

We commit to communicate openly, to the extent possible and where appropriate, when and how AI is used. Usage of AI must be transparent and explainable to all stakeholders, such as regulators, employees and job applicants.

2.5 Environmental Responsibility

We are committed to ensuring that AI systems are developed, trained and run in an environmentally responsible and efficient manner to minimize adverse impacts on the environment, while maximizing the potential for AI to advance healthcare innovation. Recognizing that service providers play an integral role in the AI ecosystem, we use our leverage to address environmental issues within their operations and supply chains. Furthermore, we explore and seek to harness AI capabilities in our efforts to tackle environmental challenges. 

2.6 Fairness and Equality

The AI systems used in Orion Pharma’s business must be designed and trained to avoid bias and discrimination. We strive for fairness in both input data and output decisions, promoting diversity and inclusion in all phases of AI development and deployment.

2.7 Safety, Security and Integrity

We are committed to ensuring that all AI systems are robust, secure, and resilient. AI applications are tested prior to deployment to prevent misuse, minimise risks, and safeguard against cyber threats or unintended outcomes.

Data used in AI must be accurate, complete, and fit-for-purpose to maintain reliability in pharmaceutical contexts.

2.8 Human Oversight and Autonomy

Orion Pharma’s AI systems shall consistently operate under effective oversight and direction from humans. Human judgment remains central in all decision-making processes.

2.9 Accountability

We maintain clear accountability for all AI systems. Roles and responsibilities are defined across internal teams and external partners in accordance with Orion Pharma’s Corporate Governance Manual. 

Orion Pharma conducts data protection impact assessments, internal audits, and due diligence to manage AI-related risks and support responsible governance.

2.10 Continuous Review and Dialogue

AI is a rapidly evolving field. Orion Pharma commits to ongoing evaluation of AI systems, engaging with stakeholders, regulators, and industry peers to refine our practices and stay aligned with emerging standards and expectations.

3 Implementation and Oversight

These principles are applicable to all employees, contractors, partners, and collaborators of Orion Group who participate in AI-related activities within Orion Pharma’s business operations. The Information Management function at Orion Pharma is tasked with formulating and upholding additional instructions and guidelines for the application of AI. Units and functions are responsible for providing necessary awareness trainings on ethical use of AI within their responsibility areas.

The management of Orion Pharma’s business division or group function is responsible for compliance with these principles. Group-level oversight is provided by Orion’s Compliance & Ethics and Sustainability functions, including a regular review these Group Principles to maintain alignment with the development of legal, ethical, and environmental standards.

These Group Principles were approved by the Head of Compliance & Ethics and the Head of Sustainability on 21 October 2025. The next review is scheduled to be completed by 31 October 2026.