Governance

Business Conduct (G1)

Material Impacts, Risks and Opportunities (SBM-3)

Our business model relies on a culture of integrity, transparency, and collaboration. Ethical conduct, strong governance, and robust supplier relationships promote the safety, quality, and continuity of our immunology therapies. Upholding high standards in employee well-being, scientific integrity, and responsible research practices fosters trust among patients, regulators, and partners, driving innovation and delivering long-term value. Clear ethical expectations, strong oversight structures and trusted relationships with employees and third-party partners enable us to anticipate and manage legal, ethical, and compliance-related risks that could disrupt operations. Our governance structures and mechanisms support transparent decision‑making, promote accountability, uphold our values, maintain robust oversight of value‑chain partners, and maintain compliance with regulatory requirements. For further information on these structures see Section 7.1.4.1 “Management of Material Risks, Impacts and Opportunities by Administrative, Management and Supervisory Bodies (GOV-1, GOV-2)” and for information on the relevant business conduct expertise of argenx’s Board of Directors and Senior Management see Section 3.2.4 “Non-Executive Directors”.

Corporate Culture

Policies (G1-1, MDR-P)

Our policies define principles and guidelines for employees, partners, collaborators, and vendors, promoting an ethical culture that supports long-term success.

At the center of this approach, our ethics and compliance program and Code of Business Conduct and Ethics translate our core values into clear standards of behavior for operating within a highly regulated and competitive global environment. The Code of Business Conduct and Ethics is supplemented by policies on whistleblower protection and anti-bribery and anti-corruption, which together reinforce our ethics and compliance culture and guide employees in applying our values in their daily work.

Our approach to ethics also includes the Interactions with the Healthcare Community Global Policy, which governs engagements with healthcare professionals (HCPs). Together with the Code of Business Conduct and Ethics, this policy ensures that all interactions comply with applicable laws, regulations, and ethical standards, prohibiting improper influence or incentives and promoting fair-market-value compensation.

Corporate Culture at argenx

We establish and develop our culture through a focus on our five Cultural Pillars—innovation, co-creation, empowerment, excellence, and humility—and reinforce these through clear expectations for employees communicated in the Code of Business Conduct and Ethics:

• Follow the rules: Employees are expected to know and comply with the laws, regulations and company policies that apply to their role and the countries in which they operate. When local laws or policies are more restrictive, employees are expected to follow the stricter requirements.
• Exercise good judgment: Employees are expected to conduct business with honesty and integrity and in a manner that protects the Company’s reputation.
• Ask questions: Employees should seek guidance from a manager, Legal, Ethics and Compliance, or HR business partner when uncertain about the laws, regulations, or company policies that apply to their role or the country in which they operate.

We continuously promote and evaluate our corporate culture through training, internal communications, targeted awareness campaigns, and engagement initiatives such as Culture Lab sessions, which encourage employees to live out our Cultural Pillars and share insights to improve the employee experience. In 2025, we enhanced the Code of Business Conduct and Ethics training, along with other core curriculum. These required annual trainings apply to all employees and to our extended workforce, except managed service providers, who instead agree to comply with our Third Party Partner Code Of Conduct, as outlined in their contracts.

The annual Code of Conduct training covers key areas including company values, product safety, ethical promotion, anti-bribery and corruption, discrimination and harassment, and data privacy. Training is primarily delivered online through the intranet, with completion requiring a read through and acknowledgement of relevant policies and standard operating procedures. Certain topics are also being addressed during new-joiner onboarding sessions.

Metrics (G1-3)

Protection of Whistleblowers

Policies (G1-1, MDR-P)

We comply with applicable global legal requirements to protect whistleblowers. In addition to the Code of Business Conduct and Ethics, the following policies encourage employees and third parties to report ethics-related concerns and to protect those who report in good faith from retaliation.

Metrics (G1-3, MDR-M)

Measures to Protect Whistleblowers (G1-1, MDR-A)

We expect all employees to promptly report suspected violations of laws, regulations, or company policies - including potential incidents of corruption or bribery - by notifying their manager, HR, Legal, or Ethics & Compliance, or by using the argenx Helpline. The argenx Helpline is externally managed to allow confidential and anonymous reporting.

Our policies, together with our Ethics and Compliance Investigations Global Procedure, prohibit retaliation against any individual who reports a concern or any person assists a reporter, cooperates with an investigation, responds to a request from regulators or government authorities, or exercises a legally protected right to report evidence of violations. Any form of retaliation will result in disciplinary action, up to and including termination of employment, revocation of site access, or discontinuance of services. All employees, consultants, and ad-hoc contractors are assigned an e-learning module as part of the annual Code of Conduct training, which includes whistleblowing procedures for raising concerns. Employees receiving whistleblowing reports are trained on a dedicated investigations standard operating procedure.

Anti-Corruption and Anti-Bribery

Policies (G1-3, MDR-P)

Anti-corruption and anti-bribery is addressed and communicated through our Code of Business Conduct and Ethics, (see Section 7.4.1.2. “Corporate Culture”), our Global Anti-Bribery and Anti-Corruption Policy and Speak Up & Anti-Retaliation Policy (see Section 7.4.1.3. “Protection of Whistleblowers”), our Third Party Partner Code of Conduct (see Section 7.4.1.5. “Supply Chain Management”), and additionally communicated via the intranet and onboarding sessions for new joiners. These policies aim to prevent, detect, and address potential allegations of corruption or bribery. We have reviewed these policies against peer practices to ensure consistency with industry standards. Further analysis is ongoing to assess alignment with the UN Convention against Corruption and Bribery.

Actions (MDR-A)

All employees and our extended workforce, excluding managed service providers, participate in annual training related to anti-corruption and anti-bribery through an e-learning module, which includes information on the process for reporting concerns. New members of the Board of Directors are walked through the Global Anti-Bribery and Anti-Corruption Policy and the Code of Business Conduct and Ethics as part of their onboarding. They are informed of any key policy updates and receive regular updates on ethics and compliance matters.

The Ethics and Compliance (E&C) function oversees the argenx Helpline, which serves as the central reporting channel for managing and triaging cases. The argenx Helpline was transitioned to a new system and enhanced in 2025 through integration with other argenx systems to improve reporting efficiency. All reporters are assured of confidentiality and non-retaliation.

The E&C function is responsible for managing compliance investigations and consults with additional stakeholders, including Legal and HR, where necessary. If an allegation or concern is cross-functional and involves issues relevant to more than one function (e.g., includes HR-related issues or potential law violations), E&C will confer with HR and/or Legal to determine which business function will lead the investigation.

We investigate all allegations and incidents of corruption and bribery with thoroughness, fairness, transparency and confidentiality. Investigations follow standardized procedures guided by the Ethics & Compliance Global Investigations Procedure, Speak Up & Anti-Retaliation Policy, and Code of Business Conduct and Ethics. All reports are reviewed and managed in accordance with applicable policies and legal requirements. All investigations are conducted by qualified personnel, and the specific individuals involved varies on a case by case basis.

Investigations are tracked from intake to remediation and documented in a Compliance Investigation Report. Allegations or concerns received through the various reporting channels are promptly communicated to E&C for triage. Upon intake, E&C confirms receipt to reporters and issues an acknowledgment that reports of misconduct are taken seriously. If, based on the initial evaluation, it is determined that no further investigation is required, E&C will document the matter as closed. If the reporter wishes to remain anonymous, their anonymity will be protected to the fullest extent possible, unless disclosure is required by law or necessary to conduct the investigation and any related proceedings. Reports are shared regularly with the GCC and the Audit and Compliance Committee.

E&C also conducts periodic monitoring which includes live monitoring of speaker events and advisory boards to ensure compliance with promotional, branding, and regulatory standards. Transaction monitoring includes of sponsorships, donations, grants, donations, speaker programs, fee-for-service engagements, research grants and meals.

Metrics (G1-3)

Finance, HR, Procurement, Sales and Marketing and Supply Chain Management are considered to be functions at-risk due to the nature of roles involving more frequent interaction with high risk parties or patients. 100% of these functions-at-risk are covered by the anti-bribery and corruption training programs. The training program involves an e-learning that provides an overview of the Global Anti-Bribery and Anti-Corruption Policy and asks employees to confirm they have read the policy. Please refer to the G1-3 metric table which shows completion rate of the anti-bribery and corruption training by all argenx employees.

Accounting Policies

Training program figures include employees, contractors and extended workforce, excluding managed service providers.

Metrics (G1-4, MDR-M)

Incidents of corruption and bribery

Accounting Policies

Number of convictions is tracked through the argenx Helpline. Fines for violations are tracked through the argenx Helpline system, Legal team and outside counsel. Investigations are tracked in accordance with our Speak Up & Anti-Retaliation Policy and value chain violations are tracked through the argenx Helpline.

Supply Chain Management

Policies (G1-2, MDR-P)

Our Code of Business Conduct and Ethics, detailed in Section 7.4.1.2. “Corporate Culture”, outlines ethical standards for engaging with all third parties. It establishes that third parties are selected based on clear and objective criteria such as quality, capability, reputation, past performance, and price. This is applied in conjunction with our Third Party Partner Code of Conduct.

The standard payment terms, which apply to all supplier categories, are 30-days in instances where other terms have not been contractually agreed upon. While we view payment practices as a fundamental component of vendor management, we do not currently maintain a formal payment practices policy or a separate policy for preventing late payments to small or medium-sized enterprises (SMEs), instead our standard payment terms and contractual agreements are applied to all suppliers, including SMEs.

Actions (G1-2, MDR-A)

Outsourcing and co-creation are key elements of our business strategy, enabling us to leverage external expertise and resources. Recognizing the important role of suppliers in this model, we have developed a supply chain management approach focused on defining expectations, qualifying suppliers, and monitoring performance.

Our vendor qualification and due diligence process assesses new suppliers for compliance with regulatory and company standards, including reference checks, screening, and where applicable review of the third-party’s own Code of Conduct. Social due diligence includes verification of adherence to mandatory regulatory requirements such as worker rights. Environmental criteria are not currently used in supplier selection.

The Global Sourcing and Vendor Alliance Management team oversees relationships with Development suppliers, along with functional business owners who manage collaboration with their respective third parties. We engage suppliers directly through regular meetings with business owners who oversee the operational aspects of service performance and delivery. Partnership governance structures are established with key suppliers to define collaboration from strategic through operational levels, including objectives, meeting cadence, and accountability. This governance structure is continuously evaluated.

We have established a working group focused on strengthening third-party risk-management, including early risk detection, compliance control, and process simplification. Risk management is also integrated into the supply chain management approach through the Supply Chain Maps (SCM) process, which visualizes the VYVGART supply chain, logistics and quality-assurance requirements. Suppliers across our supply chain, from development vendors, manufacturing, and distribution to our commercial and technology vendors, undergo a qualification process, periodic audits, and performance reviews to maintain quality standards and manage supplier performance.

Quality or compliance issues are escalated through governance channels. If low-quality performance, supply chain disruptions, or non-compliance with supplier agreements are identified (e.g., through audits), corrective action plans are implemented and monitored. Persistent under-performance without resolution may result in termination of a supplier relationship.

Payment Practices (G1-6)

We follow standardized procure-to-pay processes to prevent late payments. Payment runs are conducted according to a standard payment cycle determined by country of jurisdiction. Weekly payment runs were conducted for all European and US entities, while in Japan, all duly approved invoices were paid once a month.

Targets (G1-6, MDR-T)

We currently apply a qualitative approach to management of suppliers and have not yet established formal quantitative targets.

Accounting Policies

Our payment practices, including average payment time compared to standard payment terms, were calculated using data extracted from our payment system software. The analysis covered all invoices paid to registered vendors and excluded payments to employees and intercompany payments. Standard payment terms are 30-days, unless alternative terms are contractually agreed. The average payment time was determined by dividing the total number of calendar days between invoice date and payment date by the total number of paid invoices, calculated for each business unit, region, and the entire group.

Animal Welfare

Policies (G1-1, MDR-P)

The Animal Welfare Policy outlines our approach to safeguarding the welfare of animals used in research. The policy is assigned as a read-and-acknowledge requirement for all employees.