McKesson | Code of Conduct

McKesson

Code of Conduct

Handbook

McKesson Corporation

I²CARE in Action

A practical framework for acting with integrity, meeting legal and regulatory

requirements, speaking up, and protecting the people, patients, customers,

communities and reputation connected to McKesson.

Purpose: Advancing health outcomes for all™

Mission: To improve care in every setting, one product, one partner, one patient at a time

McKesson | Code of Conduct

Table of Contents

Our Responsibilities

Your Responsibilities; Responsibilities of Leaders; Making Ethical

Decisions; Ethical Decision-Making Guide; Consequences of

Noncompliance; Disciplinary Action

Seeking Help and

Speaking Up

Our Commitment to Non-Retaliation; How to Contact McKesson

Hotlines; How We Handle Concerns; Waivers and Exceptions

Our People

Embracing a Respectful Workplace; Keeping Workplaces Safe, Healthy

and Secure

Our Customers

Marketing and Selling Ethically; Conducting International Trade

Compliantly; Competing Honestly and Fairly; Anti-Money Laundering

and Terrorist Financing

Our Relationships with

Governments

Regulatory Excellence; Working with Governments; Political

Contributions and Political Activities

Our Company

Avoiding Conflicts of Interest; Preventing Insider Trading Violations;

Protecting Our Assets; Safeguarding Private and Personal Information;

Maintaining Accurate Records and Financial Reports; Safeguarding Our

Reputation

Our Communities

Protecting Our Environment; Respecting Human Rights; Responsible

Sourcing; Investing in Our Communities

Conclusion

Compliance and Ethics at McKesson; McKesson Hotlines

The structure follows the published McKesson Code of Conduct and its principal section architecture.

McKesson | Code of Conduct

Our Responsibilities

The Code of Conduct is McKesson's framework for behaving with honesty and integrity and for complying

with legal and regulatory requirements. It is intended to guide employees, officers and directors and

supports McKesson's I²CARE values.

Your Responsibilities

• Be familiar with regulatory requirements relevant to your job.

• Know and follow policies that apply to your role.

• Seek help before making a decision when you are uncertain.

• Speak Up about potential violations of the Code, McKesson policies or the law.

• Cooperate fully with investigations.

• Communicate truthfully and professionally.

Responsibilities of Leaders

• Lead by example and follow the Code and applicable policies.

• Ensure teams understand regulations affecting their roles.

• Ensure assigned compliance training is completed.

• Create an environment where employees feel comfortable Speaking Up.

• Promptly detect, correct and respond to compliance issues.

• Prevent retaliation and recognize ethical decision-making.

McKesson | Code of Conduct

Making Ethical Decisions

McKesson states that it follows the laws of every country where it does business. When a law is more

restrictive than the Code, the stricter requirement applies.

Ethical Decision-Making Guide

Is the course of action legal?

Consult the Law Department if you are unsure.

Does it follow the Code and

applicable policies?

Stop and seek guidance if it does not.

Does it align with I²CARE in Action?

Consider integrity, accountability, respect, inclusion and

regulatory excellence.

Is it consistent with McKesson's

ethical reputation?

Consider how the decision would look to colleagues, customers,

regulators and the public.

When in doubt

Pause and ask for help through a People Leader, Compliance, Human Resources, the Law Department or

the applicable McKesson Hotline.

Consequences of Noncompliance

McKesson identifies possible consequences including prosecution and fines, government sanctions, patient

harm, loss of business, reputational damage and business disruption. Violations may also result in

disciplinary action, up to and including termination.

McKesson | Code of Conduct

Seeking Help and Speaking Up

McKesson encourages employees to raise concerns promptly when they have reason to believe that a

violation of the Code, company policies, procedures or law may have occurred.

Speak Up Channels

• Any People Leader

• Compliance Department

• Human Resources Department or U.S. Human Resource Support Center

• Law Department

• McKesson Hotlines

Our Commitment to Non-Retaliation

McKesson states that it will not tolerate retaliation for raising concerns, asking questions, seeking guidance

or participating in an investigation. Retaliation can itself lead to discipline, up to and including termination.

Confidentiality and anonymous reporting

The Code states that concerns can be reported anonymously through McKesson Hotlines. Information is

handled confidentially and shared on a need-to-know basis, subject to legal obligations and the

requirements of a thorough investigation.

McKesson Integrity Line

U.S., Canada and Rest of World, excluding Europe

1.877.625.4625

integrity.mckesson.com

Europe

Compliance Helpline / Ombudsman: 00800-66283762

McKesson | Code of Conduct

Our People

Embracing a Respectful Workplace

McKesson describes a workplace culture centered on respect, inclusion and integrity. Employees are

expected to treat others fairly and respectfully and to follow applicable policies concerning discrimination,

harassment and workplace conduct.

• Support an inclusive workplace where people are treated with respect.

• Do not engage in discrimination or harassment prohibited by policy or law.

• Speak Up about concerns involving workplace conduct.

• Cooperate honestly with investigations.

• Protect colleagues from retaliation when they raise concerns or participate in investigations.

Keeping Workplaces Safe, Healthy and Secure

McKesson expects employees to follow safety and security requirements relevant to their work, report

hazards and incidents, and take appropriate steps to protect themselves, colleagues, customers and others

affected by company operations.

Examples of I²CARE in Action

• Know the safety requirements that apply to your role.

• Do not take shortcuts that compromise safety.

• Report unsafe conditions and incidents through the appropriate process.

• Follow security procedures and required training.

McKesson | Code of Conduct

Our Customers

Marketing and Selling Ethically

McKesson expects marketing and sales activities to be truthful, accurate and consistent with applicable

laws, regulations and company policies. Employees should avoid improper influence and seek guidance

when a customer interaction raises a compliance concern.

Conducting International Trade Compliantly

McKesson operates across multiple jurisdictions and requires compliance with applicable trade laws and

restrictions. Employees involved in international transactions must understand requirements relevant to

their roles and seek guidance when necessary.

Competing Honestly and Fairly

Employees must compete honestly and fairly and avoid agreements or conduct that could violate

competition laws. When an interaction with a competitor creates uncertainty, employees should consult the

Law Department or Compliance.

Anti-Money Laundering and Terrorist Financing

• Be alert to unusual transactions or payment structures.

• Follow customer and transaction due-diligence requirements.

• Escalate suspicious activity through the appropriate Compliance or Legal channel.

• Maintain accurate records and do not attempt to conceal the source or destination of funds.

McKesson | Code of Conduct

Our Relationships with Governments

Regulatory Excellence

McKesson describes regulatory excellence as compliance with the laws and regulations affecting its

business, operations and communities. The Code specifically addresses service and product quality,

controlled substances and anti-diversion, government price reporting and billing, exclusion screening, and

regulatory inspections, audits and investigations.

Controlled Substances and Anti-Diversion

The Code states that McKesson maintains controls designed to prevent and detect diversion in the supply

chain. Its described processes include due diligence on potential customers, monitoring

controlled-substance orders for potential diversion, analytics for suspicious orders, security procedures and

controls, and blocking or reporting certain orders when specified thresholds are reached.

Working with Governments

• Follow laws and regulations governing government business.

• Consult the Law Department when marketing or selling to government customers.

• Keep accurate records relating to government contracts.

• Do not offer or provide anything of value to improperly influence government officials.

• Notify the Law or Compliance Department promptly about government inspections, audits or

investigations.

McKesson | Code of Conduct

Political Contributions and Political Activities

McKesson states that it expresses views to governments and policy leaders transparently, ethically and in

compliance with applicable laws. The Code also distinguishes employees' personal political activities from

their work for McKesson.

Company-related political activity

• Consult Public Affairs or the Law Department before engaging in lobbying, advocacy or political activities

as part of your McKesson role.

• Disclose McKesson expenses related to advocacy and communications with government officials as

required.

• Do not use McKesson funds to support a political party, candidate or ballot measure without required prior

approval.

• Do not speak to or advocate for political officials on behalf of McKesson without consulting the appropriate

functions.

• Do not use McKesson time, resources or facilities for personal political activity.

Personal political activity

The Code states that employees are free to express their personal political views, but must avoid creating

the impression that McKesson supports, requires or guides their personal political activities.

Why the distinction matters

Political and government-related activity can be subject to complex federal, state and local requirements.

Employees should obtain guidance before acting on behalf of McKesson.

McKesson | Code of Conduct

Our Company

Avoiding Conflicts of Interest

• Disclose actual or potential conflicts of interest promptly.

• Be alert to personal relationships that could affect hiring, supervision or business decisions.

• Consider whether outside employment or financial interests conflict with McKesson responsibilities.

• Do not use McKesson resources or brand for personal gain.

Preventing Insider Trading Violations

Employees must protect material nonpublic information and comply with applicable securities laws and

McKesson requirements before trading securities or sharing information.

Protecting Our Assets

McKesson assets include physical property, technology, systems, information, intellectual property and

other resources. Employees should protect these assets and use them appropriately.

Safeguarding Private and Personal Information

Employees must handle personal and confidential information responsibly, access it only as authorized, and

follow applicable privacy, security and information-handling requirements.

McKesson | Code of Conduct

Records, Reputation and Responsible

Communication

Maintaining Accurate Records and Financial Reports

Business records and financial reports must be accurate, complete and maintained in accordance with

applicable requirements. Employees should never create false or misleading records or conceal relevant

information.

• Record transactions accurately and completely.

• Follow document retention and records-management requirements.

• Respond truthfully to internal requests and investigations.

• Escalate suspected inaccuracies or improper reporting.

Safeguarding Our Reputation

Employees represent McKesson through their conduct and communications. External communications, use

of company information and public statements must follow applicable company requirements.

Use of technology and information

The published Code emphasizes protection of company assets and private information. Role-specific

technology, cybersecurity and information-management policies may contain additional requirements and

should be followed where applicable.

McKesson | Code of Conduct

Our Communities

Protecting Our Environment

McKesson identifies environmental responsibility as part of its commitments to its communities. Employees

are expected to follow environmental requirements applicable to their roles and operations.

Respecting Human Rights

McKesson states its commitment to respecting human rights and applicable labor laws and practices in the

countries where it operates. The company also addresses human-rights expectations in its responsible

sourcing and supply-chain practices.

Responsible Sourcing

Employees involved in sourcing and supplier relationships should follow applicable procurement,

supplier-conduct, due-diligence and responsible-sourcing requirements.

Investing in Our Communities

McKesson describes community investment as part of its broader impact commitments. Employees

participating in company-sponsored community activities should follow applicable policies and approval

processes.

McKesson | Code of Conduct

Compliance and Ethics in Practice

The Code is designed to support practical decisions, not simply provide a list of rules. Employees are

expected to recognize compliance risks, ask questions early and Speak Up when something may be wrong.

Practical compliance checklist

• Know the regulations and policies relevant to your work.

• Pause when an action could affect patient safety, product quality, privacy, government programs or

regulatory compliance.

• Do not bypass controls to meet a deadline or business objective.

• Document transactions and decisions accurately.

• Seek guidance when a rule is unclear.

• Promptly raise suspected violations.

• Cooperate fully and honestly with investigations.

• Never retaliate against someone who raises a concern in good faith.

Controlled-substance compliance

In the published Code, controlled-substance and anti-diversion controls are part of Regulatory Excellence.

The Code describes due diligence, suspicious-order monitoring, analytics, security controls and reporting

processes as components of the company's anti-diversion approach.

McKesson | Code of Conduct

Employee and Leader Reference

Topic

Primary responsibility

I²CARE in Action

Act with integrity, accountability, respect, inclusion and regulatory excellence.

Speak Up

Promptly raise concerns about possible violations of the Code, policy or law.

Non-retaliation

Do not retaliate against people who raise concerns or participate in investigations.

Regulatory excellence

Follow requirements affecting product quality, controlled substances, government

programs and regulatory interactions.

Information protection

Safeguard private, personal, confidential and proprietary information.

Records

Maintain accurate business, financial and government-related records.

Government activity

Obtain appropriate guidance before acting on behalf of McKesson with government

officials.

Community responsibilities

Follow environmental, human-rights and responsible-sourcing requirements relevant to

your role.

Leader reminder

People Leaders have an ongoing responsibility to model the Code, complete required compliance training,

create a safe environment for Speaking Up, promptly escalate concerns and prevent retaliation.

McKesson | Code of Conduct

McKesson Hotlines

McKesson Hotlines are described in the Code as independent third-party channels available 24 hours a day,

seven days a week, with operators available in multiple languages. Anyone inside or outside the company

can use the Hotlines to raise an anonymous concern.

Region

Channel

U.S., Canada and Rest of World,

excluding Europe

Integrity Line

Phone: 1.877.625.4625

Online: integrity.mckesson.com

Local toll-free numbers are listed at the Integrity Line site.

Europe

Compliance Helpline / Ombudsman

Phone: 00800-OMBUDSMAN or 00800-66283762

Email: ombudsman@thielvonherff.com

Other Speak Up Channels

• Any People Leader

• Compliance Department

• Human Resources Department or U.S. Human Resource Support Center

• Law Department

The appropriate reporting channel can vary by country and issue. Local law may limit the types of concerns that can be raised

through Hotlines.

McKesson | Code of Conduct

Conclusion

The McKesson Code of Conduct provides a common framework for acting with integrity, following the law,

meeting regulatory expectations and protecting the people and communities connected to McKesson.

I²CARE in Action

• We act with integrity.

• We Speak Up without fear of retaliation.

• We are accountable.

• We prioritize regulatory excellence.

• We show respect.

• We are inclusive.

• We are proactive.

• We engage in sustainable business practices.

• We detect and respond to compliance issues.

When the right answer is unclear, pause, consult the Code and applicable policies,

and seek help through a Speak Up Channel.

McKesson Code of Conduct. Published corporate document structure and content reflected in this handbook are based on McKesson's

official Code of Conduct.

McKesson Code of Conduct Handbook

Prompt to Clone This McKesson Code of Conduct Handbook

Apply this example's core structure, strategic pacing, and structural hierarchy directly to your own topic.

What are you generating today?