Code of Business Conduct

The Board of Directors of West Pharmaceutical Services has adopted the following recent amendments to the Code of Business Conduct:

Date of Amendment: July 19, 2016

Nature of Changes: The Code has been amended to (1) expand the policy on anti-corruption to specifically prohibit commercial bribery and to prohibit making any facilitation payments; (2) include a new guidelines on employee’s use of social media; (3) expand the policy on environmental protection to include the Company’s position on sustainability; (4) amend the Company’s position on protection of personal information to clarify the circumstances under which the Company may monitor personal communications; and (5) specify public communications that are subject to prior internal review and approval.

Code of Business Conduct  Code of Business Conduct - English
Code of Business Conduct  Code of Business Conduct - Chinese
Code of Business Conduct  Code of Business Conduct - Danish
Code of Business Conduct  Code of Business Conduct - German
Code of Business Conduct  Code of Business Conduct - Spanish
Code of Business Conduct  Code of Business Conduct - French
Code of Business Conduct  Code of Business Conduct - Portugese
Code of Business Conduct  Code of Business Conduct - Serbian

How To Report Complaints and Problems

There are several ways in which to report – anonymously if the employee prefers – breaches or suspected breaches of this Code. These are shown below.

  • Call the Company’s Compliance Helpline
    • In the U.S. dial 1-866-814-2685
    • All other locations dial the AT&T code for your country and then 866-814-2685. The list of AT&T country codes is posted on West’s intranet.
    • All callers will have the opportunity to call the Compliance Helpline and discuss the complaint with an operator in their native language 24 hours a day, 365 days a year.
    • If you are non English speaking, please wait until the line operator answers and then let them know what language you require. The operator will conference in an individual who speaks your language.
    • Calls received in this manner will be treated anonymously and the caller will be given a report and personal identification number (PIN) for follow up and resolution information.
    • Once the operator has logged the complaint depending on the nature of the complaint, it will be routed to either the Chairman of the Board of Directors Audit Committee, and/or the Law Department for investigation, follow-up and disposition. All callers will be able to dial back in to the operator using their assigned report and PIN to gain feedback on the status or resolution of the complaint.
  • Web submission to the Company’s Compliance Helpline at https://www.compliance-helpline.com/westcompliance.jsp
  • Send an e-mail, call, or write:

    George L. Miller
    Senior Vice President, General Counsel and Corporate Secretary
    West Pharmaceutical Services, Inc.
    530 Herman O. West Drive
    Exton, PA 19341 USA
    Tel. +1-610-594-3319
    George.Miller@westpharma.com or Integrity@westpharma.com

Complaints or messages received in this manner will be received by the Law Department, who will handle the investigation and disposition of the complaint. All complaints will be handled promptly and anonymously if desired.

  • If you have a complaint or suspect a violation of the Code that concerns an accounting, internal accounting controls or auditing matter, you may send your complaint directly to the Chairman of the Audit Committee, Board of Directors at the following address:

    Chairman of the Audit Committee
    Board of Directors
    West Pharmaceutical Services, Inc.
    P. O. Box 3066
    Lionville, PA 19341

    Complaints sent through this means will be received directly by the Audit Committee of West’s Board of Directors and not by company management. All complaints may be sent anonymously.
  • Employees can contact the Chairman, Independent Directors of the Board of Directors. The Chairman of the Independent Directors will review the communications received and determine how they should be investigated and resolved. All complaints may be sent anonymously. Complaints should be addressed as follows:

    Chairman, Independent Directors
    Board of Directors
    West Pharmaceutical Services, Inc.
    P.O. Box 3066
    Lionville, PA 19341
    USA

West guarantees that no employee who reports a breach or suspected breach of this Code will be penalized in any manner for providing such information
regardless of the means used to report the breach.

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How to Get Answers to Your Questions

If you have a question about the Company’s compliance program or about the Code or its application to a particular situation, you may contact:

George L. Miller
Senior Vice President, General Counsel and Corporate Secretary
West Pharmaceutical Services, Inc.
530 Herman O. West Drive
Exton, PA 19341 USA
Tel. +1-610-594-3319
George.Miller@westpharma.com or Integrity@westpharma.com

You may also contact the Company’s Compliance Helpline with a question about the Code or its application to a particular situation.

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