Biogen Anti-Slavery and Human Trafficking Statement

Founded in 1978, Biogen is a group of leading biotechnology companies that pioneer innovative science to deliver new medicines to transform patients’ lives and to create value for shareholders and our communities. We apply deep understanding of human biology and leverage different modalities to advance first-in-class treatments or therapies that deliver superior outcomes. Our approach is to take bold risks, balanced with return on investment to deliver long-term growth. 

With approximately 7,500 employees worldwide, Biogen operates globally including our global headquarters in Cambridge, MA, USA; international headquarters in Zug, Switzerland; and a world-class manufacturing facility in Research Triangle Park, NC, USA. Our products are distributed worldwide, and we also make use of contract manufacturing organizations (CMOs) and external suppliers for product inputs and packaging. 

Biogen is committed to conducting business in accordance with the highest degree of integrity and in compliance with applicable laws, which includes recognizing and respecting human rights. Biogen prohibits all forms of modern slavery and human trafficking within our supply chains and business operations. 

In every country in which we operate, Biogen is dedicated to ensuring it meets all legal requirements, including those related to human rights. Our human rights position is also guided by the U.N. Universal Declaration of Human Rights, U.N. Guiding Principles for Business and Human Rights, Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, and International Labor Office Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy.

This commitment is reflected through our Code of Business Conduct and Human Rights Position Statement, which together set forth our code of ethics and expectations regarding responsible business conduct. These documents provide information about the standards of integrity that Biogen requires all employees, officers and subsidiaries to follow, including standards relating to fair treatment and diversity, anti-harassment and bullying, modern slavery and human trafficking. 

Biogen expects that our suppliers adhere to the Code of Business Conduct, which provides guidance and requirements for doing business with Biogen. In addition, suppliers are also required to comply with the terms and conditions of applicable contracts and purchase orders entered into by both parties. Each supplier doing business with Biogen under these terms and conditions agrees it will comply with all applicable laws and regulations in its performance of the contract. Biogen does not currently require a separate certification in addition to these contractual provisions. 

Biogen recognizes that, as with any supply chain, there may be modern slavery risks in its supply chains, and works to identify, evaluate and address such risks. While we have owned operations, contract manufacturers, suppliers, sales and distribution in numerous countries around the world, the large majority of our operations and supply chain partners are located in countries that our own and independent assessments (such as the U.S. Department of State's Trafficking in Persons report) have found to be at lower risk for human rights violations including modern slavery and human trafficking. 

Biogen takes steps to verify the environmental, social and governance risks of our supply chains, including modern slavery and human trafficking risks, based upon the industry in which we operate and the geographic locations in which we conduct business and/or obtain materials and services. We do this through a process of reviewing country risk profiles for corruption and human trafficking risks published by independent third-party expert organizations and providing added diligence on specific areas or suppliers as needed based on this assessment. Our risk assessment process indicated very low risk of human rights issues or violations in our supply chains. A summary of our due diligence process, key performance indicators, and results of our supply chain risk assessments is reported annually in our Corporate Responsibility Report. 

In addition to our own due diligence process, Biogen is a member of the Pharmaceutical Supply Chain Initiative (PSCI), an organization made up of leading global pharmaceutical companies that focuses on increasing the capabilities and responsibility of our supply chains. The PSCI has developed and shared with industry suppliers our Principles for Responsible Supply Chain Management, which include prohibitions against forced and child labor, along with other expectations regarding responsible labor, governance and environmental practices. More details on the PSCI and these Principles can be found at https://pscinitiative.org/home.  

We did not identify any specific instances of modern slavery during the reporting period, so no remediation measures were needed. We also did not identify any instances of loss of income for vulnerable families as a result of the steps we have taken to eliminate risks of modern slavery, and remediation measures were not necessary. We are committed to addressing any instances of modern slavery we identify, including working with relevant stakeholders to improve working conditions or otherwise support impacted rightsholders. 

All Biogen employees are trained on our Code of Business Conduct upon hire and undergo mandatory annual refresher training thereafter. This training includes information about our issue reporting hotlines and other tools and familiarizes our team with the system that allows us to address, resolve, and track any human rights or other issues that may arise. 

We are committed to continuously improving our systems to better identify, assess, and address modern slavery and human trafficking risks within our global business and supply chains and aim to periodically review the effectiveness of our measures. We listen to the viewpoints of our stakeholders and use their feedback to improve our performance and report on our human rights due diligence process, risks and performance in our annual Corporate Responsibility Report. 

This statement was approved by the Corporate Governance Committee of the Board of Directors at its June 18, 2025 meeting.