AstraZeneca Annual Report and Form 20-F Information 2008

Code of conduct

The new AstraZeneca Code of Conduct was launched in May 2008 and is available on the Company’s website, astrazeneca.com. The new Code became effective on 1 July 2008 and applies to all Directors, officers, full-time, part-time, contractor and temporary staff at all levels in every country where we operate. It has been translated into over 40 languages and every employee has a copy in his/her local language. It is designed to provide clear direction as to how the Company’s commitment to honesty and integrity is to be translated into consistent actions across all areas of the business. Compliance with the Code of Conduct and with the standards detailed by the Company in support of it is mandatory. The same applies to the laws and regulations of the countries in which we work and do business, as well as applicable national and international codes, and the Company seeks to operate to the highest of these standards.

The new Code unites every member of the Group under a single Code of Conduct. It provides guidance across all areas of activity previously covered by the US code, which is therefore no longer required.

The Code also includes information on how to report possible violations of the Code through the appropriate channels, including the AZethics telephone lines and the new global website, AZethics.com. Anyone who raises a possible breach in good faith will be supported by management and will not be subject to retaliation, which would itself be considered a serious violation of the Code. We review all alleged compliance breaches and concerns, and we investigate and report on them to the Audit Committee, as appropriate.

During 2008, 206 reports of alleged compliance breaches or other ethical concerns were made via the telephone helplines, AZethics.com website or Global Compliance e-mail or postal addresses described in the Code of Conduct. The number of reports via the equivalent channels in 2007 was 133. We believe the increase in the number of reports via these channels is due, in part, to our efforts to enhance these reporting channels and, in part, to the increase in awareness following the launch of the new Code of Conduct and the accompanying training and communications. To date, no material issues have been identified through these mechanisms.

The Group policies have also recently been reviewed, and a new Global Policy Structure was launched in November 2008 and came into effect in January 2009. As with the Code of Conduct, the Global Policies apply to all members of the Group. Like the Code of Conduct, the new Global Policies provide clearer and more comprehensive guidance, in plain language, to all managers and employees as to their accountabilities in key ethical, compliance and corporate responsibility risk areas.

A critical element of the effective implementation of the new Code of Conduct and Global Policies is to deliver clear training and education to employees on an ongoing basis. One of the SET scorecard objectives for 2008 was to train all our employees on the new Code of Conduct during 2008. Training began in July, and all employees have completed the course. Further training will be delivered on an annual basis.

A Group Finance Code of Conduct complements the Code of Conduct. It applies to the Chief Executive Officer, the Chief Financial Officer, the Group’s principal accounting officers (including key Finance staff in major overseas subsidiaries) and all Finance function employees, and it reinforces the importance of the integrity of the Group’s Financial Statements, of the reliability of the accounting records on which they are based and of the robustness of the relevant controls and processes.

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