Amgen GLOBAL CORPORATE COMPLIANCE POLICY

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1 1. Scope Applicable to all Amgen Inc. and subsidiary or affiliated company staff members, consultants, contract workers and temporary staff worldwide ( Covered Persons ). Consultants, contract workers, and temporary staff are not Amgen employees, and nothing in this Policy should be construed to the contrary. 2. Policy It is Amgen s policy to comply with all applicable export and import control laws and regulations. This Policy sets forth the requirements for proper trade compliance activities, including export and import of goods, software, or technology. Export Control Laws It is important to ensure that Amgen s global supply chain is not interrupted, and movement of goods comply with international trade regulations specific to each country s jurisdiction. In the United States ( U.S. ), for example, there are laws that govern, and in many cases restrict, the final destination of the sale and/or shipment of goods, software, and technology to ensure that certain individuals, businesses, or entities, including individuals and organizations associated with known terrorist activities, do not receive items made by or from a U.S. company. In addition, Amgen must adhere to regulations around trade embargoes that may dictate partial or complete prohibition of commerce and trade with a particular country. The Directorate of Defense Trade Controls and the U.S. Bureau of Industry and Security in cooperation with the Office of Foreign Assets Control, are responsible for managing the flow and sale of U.S. software, goods, and technology from the U.S. All subsidiaries of the U.S. companies are bound to comply with the U.S. export control laws, and violations can result in civil and criminal penalties for Amgen and Covered Persons as well as suspension or denial of export privileges and debarment from U.S. Government procurement. Countries other than the U.S., such as members of the European Union, also have export control restrictions, and Covered Persons are required to follow all applicable laws related to exports. When controlled technology is released to foreign nationals within the U.S. or outside the U.S., deemed export occurs. Technology is "released" when it is exchanged verbally, in written or electronic format, or made available for visual inspection or through practice or application by persons with knowledge of the technology. Amgen Global Trade Office conducts controlled technology assessments and maintains a list of controlled technologies within Amgen facilities. Hiring of foreign nationals either within or outside the U.S. into facilities with controlled technology are subject to review by the Global Trade Office. Anti-boycott regulations require U.S. firms and their subsidiaries to refuse to participate in unsanctioned foreign boycotts of countries friendly to the United States, for example, Israel. Any requests received by Covered Persons that are discriminatory in nature towards a country or a business, and are made in connection with international transactions, must be refused and reported to the Global Trade Office. Effective Date: June 1, 2015 FORM

2 Import Control Laws Globally, countries regulate the flow of goods, technology and persons into their borders. In the U.S., for example, Customs and Border Protection ( CBP ), a division of the U.S. Department of Homeland Security, secures and facilitates trade and travel into the U.S. Many of the regulations enforced by CBP are intended to prevent acts of terrorism and to assure that goods entering the country are legitimate and that appropriate duties and fees are paid. Wherever Amgen operates, Covered Persons are required to follow all applicable laws related to imports. Violations of import control laws may result in importations, including hand-carries, being rejected or seized, and civil and criminal penalties imposed on Amgen and Covered Persons. Since Amgen products are also regulated by the U.S. Food and Drug Administration ( FDA ), it is important to note that the FDA also regulates import and export of drugs, biologics, combination products and medical devices. Other government agencies having jurisdiction over commodities Amgen imports may include the U.S. Department of Agriculture, U.S. Centers for Disease Control and Prevention, U.S. Environmental Protection Agency, U.S. Fish and Wildlife Service, other agencies depending on the commodity. Similar agencies may exist globally, and Amgen is also subject to adherence to other government agency regulations when applicable outside the U.S. Generally, these laws are in addition to, and not in lieu of, regulations referenced above. General Guidelines for Compliance with Export and Import Laws Covered Persons are advised to consult Global Trade Office Amgen s trade compliance group, for guidance on export and import compliance in advance of a planned import or export transaction. Some transactions may be prohibited or restricted and require securing permits or licenses prior to the transaction. When appropriate, Global Trade Office will liaise with other key stake holders and functions for cross-functional perspective and advice. Covered Persons must comply with export and import controls and requirements when engaging in any of the following activities (which is a non-exhaustive list): Shipment or movement of goods (including hand-carries) across international borders whether between Amgen locations or third parties on Amgen s behalf, including contract manufacturers, logistics service providers and other business partners; Creation of international shipping documentation such as a Customs/Commercial invoice, statement of Origin or shipping waybill; and Transfer of technology outside of the U.S. and within the U.S. to foreign nationals either verbally or in written form, which is subject to deemed export regulations. This includes transfer of technical data, blueprints, training on specific methods and/or technologies needed for product use and/or development. Covered Persons are required to follow all procedures that Amgen s Global Trade Office has established to ensure export and import compliance, which include: Providing accurate and complete information on imported goods and exported goods where such information is required; Valuing goods in alignment with applicable regulations and Amgen policies; Marking goods with the appropriate country of origin where required to provide such information. Country of Origin regulations are complex and are determined by each Effective Date: June 1, 2015 FORM

3 destination country, Covered Persons should contact Global Trade Office for guidance on country of origin marking when it is not known; and Maintaining relevant records in accordance with the regulations, typically five years. Covered Persons should contact Global Trade Office if they have any questions about international transfer of goods, software, or technology. Covered Persons are prohibited from making payments or offering anything of value to Government Officials (as defined in Amgen s Global Corporate Compliance Policy - Anticorruption and U.S. Foreign Corrupt Practices Act), directly or indirectly (e.g., via third parties), in order to influence those officials behavior in relation to import or export shipments, clearances, licenses, permits, certificates or statements. In the event there is a threat that Amgen s business is being paralyzed by a Government Official, Covered Persons are required, in advance of taking any action, to contact local Amgen Management and the Law Department immediately to discuss the situation and permissible options. For further guidance on this topic, please see Amgen s Global Corporate Compliance Policy - Anti-corruption and U.S. Foreign Corrupt Practices Act. Basic Shipping Procedures Because of the complexity of export and import laws, Amgen s Global Trade Office has established procedures and controls to help ensure that shipping and other international activities are performed in a compliant manner. Covered Persons are required to follow these procedures. All international export activity must be shipped via approved shipping locations (posted on Global Trade Office Site on MyAmgen) for final processing. Third parties exporting or importing on behalf of Amgen must be instructed to contact Global Trade Office to ensure compliant transactions. All internationally shipped goods must be accompanied by documentation to meet customs and other government agencies rules and regulations. Consult Global Trade Office to review the documentation for shipments originating from or bound for the U.S. as well as for general guidance on international shipping procedures and processes, including documentation, Customs valuation, country of origin, tariff classification, right to import, import duties/taxes, Free Trade Agreements and other special programs, INCOterms and any other aspects of international trade. Supply Chain Security Amgen is a voluntary member of supply chain security programs including the Customs-Trade Partnership Against Terrorism ( C-TPAT ) program (U.S.) and Authorized Economic Operator ( AEO ) program (E.U.). This commits Amgen to maintain high standards and security measures throughout our supply chain. Procedures in support of these standards are designed to enhance the security of our facilities, people, cargo shipping, cargo receiving and cargo tracking processes. Amgen s goal in participating in these programs is to prevent cargo loss and cargo tampering, including the introduction of illegal merchandise into the global supply chain. One of the aspects of this program includes the ongoing security screening of our business partners such as suppliers, manufacturers, importers, carriers, consolidators, and customs brokers to verify the integrity of their security practices and to ensure they follow security procedures that meet a similar supply chain security standard. Effective Date: June 1, 2015 FORM

4 Amgen s Global Trade Office is responsible for administering the Amgen C-TPAT program and works with the Amgen regional offices to ensure they meet the security standards of C-TPAT and/or the applicable supply security program within their region. Effective Date: June 1, 2015 FORM

5 3. Additional Information Every Covered Person worldwide is required to follow (1) the Amgen Code of Conduct, (2) laws and regulations applicable in the relevant jurisdictions, and (3) Amgen governance documents applicable to him or her, including without limitation, those relating to this Policy. Covered Persons should exert due diligence in preventing violations of such laws, regulations, and governance documents. Covered Persons must refer to the governance documents in effect for the geographic area in which they work, or for which they are responsible, or request guidance from their manager or compliance representative with responsibility for that geographic area. The term governance documents in this Policy means Amgen s written policies, standards, procedures, business practices, and manuals. Amgen expects its managers to (1) be familiar with (or take appropriate steps to become familiar with) the laws, regulations, and Amgen governance documents applicable to the activities they manage or supervise, (2) ensure their direct reports have appropriate training on compliance requirements to perform their job functions, and (3) supervise their direct reports with respect to compliance requirements and activities. If Amgen determines that any Covered Person has violated this Policy, related standards, procedures or controls, applicable laws or regulations, or any governance documents, appropriate disciplinary measures will be taken, up to and including immediate termination of employment, to the extent permitted by applicable laws. The following is a non-exhaustive list of possible disciplinary measures to which Covered Persons may be subject (subject to applicable law): oral or written warning, suspension, removal of job duties/responsibilities, demotion, reduction in compensation, and/or termination of employment. Subject to applicable laws, Amgen reserves the right to take whatever disciplinary or other measure(s) it determines in its sole discretion to be appropriate in any particular situation, including disclosure of the wrongdoing to governmental authorities. Nothing in this Policy changes the at-will nature of employment at Amgen, its affiliates or subsidiaries, where applicable. Amgen may also terminate the services or work engagement of non-employee Covered Persons for violation of this Policy. Effective Date: June 1, 2015 FORM