Code of Conduct and Business Ethics
Dear Colleagues, Contractors, Vendors and business Partners,
PharmaNest aims to be a global leader in the development and validation of novel digital pathology image analysis and Ai methods for the quantification of Fibrosis and it’s associated histological features.
Westrivetocommercializeour solutions in a scientifically driven and consultative way to support pharmaceutical companies in the development of novel compounds for the treatment of fibrotic conditions, and clinicians in the evaluation and follow of patient affected by fibrotic conditions, including in the space of fibro-immuno-oncology..
We seek to collaborate with high profile academic institution and investigators to push forward the field of pathomic fusion with spatially resolved single-fiber datasets.
We seek to foster a positive work environment for employees, where they can excel professionally, and to create a culture that supports innovative, agile thinking and decisive actions.
To achieve our goals, we have established guiding values and standards to not only meet our ethical, compliance and legal obligations but also position us for lasting success. Together, these values and standards provide one global identity for PharmaNest and its employees.
Equally important, the Code of Conduct and Business Ethics for PharmaNest inc (the “Code”) provides principles to help us select the appropriate path when faced with a difficult decision.
At PharmaNest, we rely on our values to guide us in achieving our goals and determining that path:
Entrepreneurship and passion. As entrepreneurs, we participate with passion coming from within. It is what drives us to change the lives of patients affected by fibrotic conditions, and contribute to the sustainable, successful further development of our organization. As entrepreneurs, we challenge and agree on our goals, ensure the appropriate resources and act decisively and in line with our established guiding values and standards. We feel responsible to deliver on our promises.
Teamwork, trust and respect. Nobody knows everything! As a team, we rely on each individual and his or her competencies and commitment. We build trust by having faith in each other, and we expect everyone to act as entrepreneurs. We are transparent and explain what we are doing and why. We show respect. Showing respect means knowing your own limits and respecting the abilities and opinions of others. This also applies to our competitors and the market. We achieve and celebrate success as one team.
We want to foster a high-performance culture, one in which everyone, regardless of location, level or type of work, feels respected and appreciated. We want to promote a culture in which the right things are done the right way. We want all PharmaNest employees to be able to identify with this culture and to reflect the Company’s values and standards in everything they do.
We ask all employees, contractor, supplier and partner to please carefully review the Code, to abide by it and to seek guidance if unsure of the best course of action for any given situation. Through our shared commitment, we are confident we will continue to achieve our goal of making a difference in patients’ lives.
Mathieu M. Petitjean, Ph.D. CEO
Striving for Excellence
We uphold the code as a reflection of our values and commitment to conducting business with integrity
Purpose and Scope
Purpose
PharmaNest aims to make a meaningful difference in the lives of our employees and the patients affected by fibrotic conditions. While we do no discover nor develop therapeutic compounds, we believe our Digital Pathology and Ai method can significantly accelerate the discovery of antifibrotic compounds and improve the management of patient affected by fibrosis. To do so, we strive for excellence in all areas of our business operations and not just those focusing on the development, cloud-deployment and marketing of our services and solutions. Our goal remains to be recognized as a world-class organisation with a history of sustained success, innovation and responsible business practices.
PharmaNest Code of Conduct and Business Ethics (the “Code”) acknowledges our business, environmental and social responsibilities and serves as a guide to responsible and ethical decision making. The Code establishes business practices that are not only essential to how we achieve success but also define our Company.
While our Code sets standards that promote compliance with many of the laws impacting our industry, it is not intended to cover every situation we may encounter.
Employees, business partners and vendors must use good judgment and should look to additional Company policies and applicable procedures and other resources available on the Company intranet.
Scope
The Code applies to PharmaNest and its respective affiliates (collectively referred to as the “PharmaNest” or the “Company”). While the Code is primarily directed toward Company employees, in some circumstances, it may be applicable to the activities of our strategic business partners, vendors and third-party agents. Employees who engage such third parties must seek to ensure that these parties are made aware of the Code and should seek their cooperation in complying with the Code including, where possible, the establishment of a contractual requirement to act in accordance with the Code when working on behalf of the Company
All employees should ensure their personal decisions and actions comply with the Code in letter and spirit, regardless of their location and the nature of their work. If a difficult situation arises, employees are expected to seek advice from their manager or the Human Resources, Legal or Compliance Departments before acting.
Violations of the Code will not be tolerated and may result in disciplinary action, up to and including termination of employment or commercial relationships
General Standards Of Conduct
We expect all employees to adhere to general standards of business conduct while performing their job duties.
We believe our values are the foundation for the Code and that the Code guides our behavior. This section of the Code defines the general standards of conduct expected of all employees. The standards described below provide the minimum behavioral expectations for all employees. Further details covering specific aspects of acceptable or prohibited behaviors and business practices are covered in other sections of the Code and in the Company’s policies and applicable procedures.
In situations where an employee is unsure of what to do or internal guidance is unclear, they should contact their manager or the Human Resources, Legal or Compliance Departments for additional guidance. Similarly, all employees must promptly report any identified or potential violations of the Code or these general standards of conduct to their manager or the Human Resources, Legal or Compliance Departments.
Harassment and discrimination
We value a positive, constructive, and ethical work environment free from harassment. Workplace harassment of any kind is prohibited. Harassment includes any action that creates an intimidating, hostile or offensive work environment, whether physical, verbal or other.
We welcome diversity and are an equal opportunity employer. The Company prohibits any form of discrimination or harassment and provides fair treatment to all employees regardless of race, color, origin, citizenship, religion, gender, sexual orientation, gender identity, marital status, pregnancy, age, medical condition or disability. Additionally, we must always respect the privacy of others.
Drugs, alcohol, substances, and violence
We are committed to securing a safe and healthy workplace for our employees free from drugs, alcohol, substances and violence.
Employees must comply with Company policies regarding the use of alcohol and the possession, sale or use of illegal substances. Unless otherwise offered by the Company as part of a Company-sponsored travel, event or activity, alcohol may not be consumed during working hours. The Company reserves the right to test employees for drug, substances and alcohol during working hours, business travel and during any event sponsored by the Company.
Equally important, we do not tolerate violence or any threats of violence and prohibit the possession of weapons of any kind on Company property or while off-site conducting Company business.
Commitment to Compliance
At PharmaNest, we believe that a culture of compliance leads to better business and medical outcomes for our Company and patients, respectively.
As part of our commitment, all employees are expected to adhere to the values and standards established in the Code as well as in the Company’s policies and applicable procedures.
We have implemented a comprehensive compliance program to ensure our operations and activities are always conducted with integrity. Our compliance program is composed of the following elements to support its effectiveness:
• Compliance officers: The Company maintains Compliance Officers charged with providing broad leadership and strategy for how the Company integrates compliance requirements within its everyday business activities
• Ethics and compliance committees: The Company uses respective bodies, such as Ethics and Compliance Committee(s), composed of cross-functional senior leadership, to both promote and provide oversight over the Company’s compliance initiatives.
• Code, policies and procedures: The Company sets standards for acceptable employee behaviors and interactions with other employees, customers and business partners.
• Communications and training: The Company regularly communicates with and trains employees on the Company’s policies and applicable procedures to enable them to effectively do their jobs consistent with compliance requirements
• Monitoring and auditing: The Company regularly reviews its business activities to identify potential risks and instances of non-compliance.
• Corrective actions: The Company swiftly and consistently takes action to uphold compliance requirements, regardless of the identity of the affected employees.
While a comprehensive compliance program serves a critical role in supporting our Company’s efforts, only the day-to-day action and commitment of our employees will result in its effectiveness.
Speak up and responsibility for Compliance.
We promptly report any identified or potential compliance violations to support the Code.
We are all accountable for the reputation of PharmaNest. We expect employees to act ethically and responsibly at all times in accordance with our values and standards, the Code and the Company’s policies and applicable procedures. With this commitment we also have the responsibility to “speak up” and report any identified or potential violations of the Code or the Company’s policies and applicable procedures.
As such, all employees must report any identified or potential violations promptly to their manager or the Human Resources, Legal or Compliance Departments. All reports of potential non-compliance with the Code or the Company’s policies and applicable procedures made in good faith will be reviewed and investigated.
At times, conditions may exist in which making the right decision may be challenging. We provide multiple resources for employees to ask questions and raise concerns. Employees should contact their manager or the Human Resources, Legal or Compliance Departments if they are unclear about any aspect of this Code or are unsure how to respond to an issue that the Code or the Company’s policies do not address.
We also seek to maintain the confidentiality of employees reporting identified or potential compliance violations, unless disclosure is otherwise required by law or for the conduct of the investigation. Employees may also make reports anonymously as follows:
PharmaNest is committed to the quality of the services and solutions that we provide. We must immediately report (within one business day) any suspected quality issue that might compromise the safety of patients, for instance patients that participate to clinical studies where our solutions are used.
We develop, implement and train our team to receive , investigate, remediate quality issues and concerns in general.
To report and raise a quality concern, please use the link at the bottom of the home page of our website, or here
Maintaining Patient Focus
We act in the best interest of patients, customers, and company.
Interactions with healthcare professionals
We hold ourselves to high ethical standards in our interactions with healthcare professionals to maintain our reputation and credibility.
PharmaNest interacts with healthcare professionals (often called HCPs) for the ultimate benefit of the patients we serve. Some of our core interactions relate to the sale and marketing of our products, research and development and other consulting services. To maintain our reputation and credibility, we are committed to ethical and compliant interactions with healthcare professionals in all of our business activities.
Our Company defines a healthcare professional as any person who is a member of the medical, dental, pharmacy or nursing profession, or who is affiliated with a healthcare organization, or any other person who, in the course of
his or her professional activities, may prescribe, purchase, supply, recommend or administer a medicinal product, including any official or employee of a government agency.
All interactions with healthcare professionals must adhere to the Code and the Company’s policies and applicable procedures, which reflect applicable laws and industry codes. We should always focus on the benefit to patients when interacting with healthcare professionals.
Marketing interactions
While our products and solutions are “for research only use”, but might in the long term be deployed in the clinic, we are committed to ethically promoting our products and services and recognize the importance of providing healthcare professionals with the accurate scientific and medical information they need to make informed prescribing decisions.
Although the laws and regulations governing the promotion of pharmaceutical drugs to healthcare professionals vary by region, our Company has adopted the following global principles for all promotional and marketing-related interactions:
• We promote consistency with the approved product characteristics or indications.
• We make truthful, accurate, balanced, fair, objective and complete claims.
• We provide relevant product safety information.
• We do not provide any items or services to inappropriately influence or induce the use or recommendation of our products.
Research interactions
We are committed to scientific integrity in all of our research activities and recognize the important role healthcare professionals play in the development of new products and services. Research-based interactions with healthcare professionals are structured to maintain the independence and integrity of the research conducted. Moreover, our relationships with healthcare professionals conducting research related to our products and services may not inappropriately influence the design or results of research activities.
Other healthcare professional consultant interactions
We are committed to only engaging healthcare professionals for consultant services where there is a clearly defined need, legitimate purpose and scope. In such circumstances, healthcare professionals must be paid fair market value for services provided. Consultant interactions and payments may not be used to influence or induce the use or recommendation of our products and services.
Maintaining Patient Trust
We always act in the best interest of patients affected by Fibrotic conditions.
PharmaNest interacts indirectly (via the Sponsors that we serve) with patients for the purposes of conducting clinical research, supporting patient advocacy groups and improving disease awareness. The intent of these activities is to enhance patient education, access to medicines and care. As such, and even indirectly, we are committed to always acting with transparency and responsibility in all of our patient interactions.
All direct and indirect activities with patients, including research, must adhere to the Code and the Company’s policies and applicable procedures, which reflect applicable laws and industry codes focusing on patient interactions.
Communications with patients
We are committed to ensuring our communications with patients focus on providing the information they need to make informed, personal medical decisions. Such communications must be tailored for patient audiences and not healthcare professionals.
Privacy and patient information
We respect the privacy of every patient. During our business activities, we may come into contact with or obtain patient personal information. We comply with patient privacy laws, which among other things, may require that only pseudonymized digital images are transferred to us, and that Sponsors and collaborators obtain patient consent before patient information may be used for business activities.
Research
We strive to ensure our research activities are conducted to high standards, especially those involving interactions with research subjects via our partnership and services delivered to Sponsors and / or Academic research Organizations. All research subjects must be provided with complete and full disclosure of the purpose and nature of the activity in which they seek to participate.
We must never deceive, mislead, or inappropriately induce individuals to participate in our research activities.
Patient organizations
We interact with patient organizations to improve patient care by advancing education and awareness. All interactions with patient organizations should be consistent with the mission of the patient organization.
While, in some instances, we may provide support to patient organizations in a manner consistent with the Code and the Company’s policies and applicable procedures, any such support should be properly documented and structured to maintain the independence of the organizations.
Cloud Deployment, quality, and scalability
We know that achieving our goal of becoming a leading global digital Pathology and AI company starts with ensuring the quality of our services and solutions.
PharmaNest recognizes that our clients rely on our services and solutions to improve the development of therapeutic compounds and the management of patients affected by fibrotic conditions. We must maintain this trust by adhering to strict quality control standards in the development, validation, deployment, and scalability of our cloud based operations.
We are committed to maintaining a comprehensive quality assurance and control program to support our compliance with internationally recognized Good Practice quality guidelines (GxP), especially Software Development, Validation Lifecycle , Good Laboratory Practice (GLP) and Good Clinical Practice (GCP). Furthermore, we require the same level of quality commitment from our suppliers and business partners who provide services for the Company.
Timely reporting of any potential quality concerns is critical to ensuring the integrity of our products. Any potential quality issues or concerns must be reported to the Quality Assurance, Legal or Compliance Departments.
Ethical research
We strive to meet ethical and scientific standards in all of our research activities.
PharmaNest develops novel, innovative digital Pathology image analysis methods to improve the quantification of Fibrosis and its associated histological features. The use of these methods helps our clients and collaborators to improve and accelerate the discovery and development of novel compounds available to patients affected by Fibrotic conditions Ethical research is fundamental to creating safe, effective medicines and maintaining our credibility with customers. At Pharmanest, or in partnership with our clients and collaborators, we expect our employees to conduct all research activities in accordance with the Code, the Company’s policies and applicable procedures and recognized international standards for Good Clinical Practices (GCP) and Good Laboratory Practice (GLP). Attempting to unduly influence research results or falsification of research data is strictly prohibited. We believe in transparency in our research by reporting all results, whether positive or negative.
We respect the rights of individuals involved in our research activities and fully and completely disclose the purpose and nature of the clinical studies in which they participate. While we strive to limit our inbound data to pseudonymized data, we are committed to protect patient privacy and support our clients and partners to establish standards and protocols for the use and storage of patient personal information.
Indirectly, we are committed to support our clients and collaborators to strictly adhere to applicable animal welfare laws, industry codes and standards relating to the responsible treatment of animals in research. In situations that require the use of animals to conduct research, it is our responsibility to ensure that our clients and collaborators treat animals respectfully and with a high level of ethical concern.
Doing business with integrity
We respect and adhere to all laws, policies and regulations governing both our company and industry.
Anti-retaliation
We prohibit retaliation or harassment against anyone who, in good faith, reports an identified or potential violation of the Code or the Company’s policies and applicable procedures and applicable laws.
Our Company seeks to create a workplace that promotes an open and trusting environment.
We value our employees and have established Company policies and applicable procedures to encourage the reporting of potential illegal, unethical or otherwise non- compliant conduct without fear of retaliation
We prohibit retaliation against any employee who raises a compliance concern in good faith. Retaliation includes any employment decisions, intimidation, harassment, or other misconduct that has the intent of punishing an employee in response to reporting an identified or potential violation or assisting in a Company investigation.
We take reports of retaliation or harassment against those reporting identified or potential compliance violations seriously and will take appropriate disciplinary action when warranted.
We actively promote these principles to our vendors, strategic partners, contractors, if possible, in the form of contractual agreements
Compliance with laws and regulations
We respect and adhere to the laws and regulations governing our industry.
At PharmaNest, we are committed to following all laws and regulations applicable to our business activities, especially those designed to protect patients and improve the quality of medicines and healthcare services. As a global company, we recognize that the laws and regulatory requirements of one country may apply to our activities taking place in another country.
Furthermore, the laws and regulations governing our Company cover a wide range of business activities, such as clinical research, product marketing, securities trading, fair competition, privacy, labour and employment and environmental protection. While employees are not expected to know the details of every law or regulation, we should remain aware of the core requirements established in this Code and understand when to seek advice.
Each of us is expected to be familiar with the Company’s policies and applicable procedures relevant to the area in which we work. When appropriate, our Company provides training and education relevant to the laws and regulations governing our employees. Situations may arise in which the laws and regulations are not clear. In these cases, employees are expected to contact their manager or the Legal or Compliance Departments for additional guidance.
We actively promote these principles to our vendors, strategic partners, contractors, if possible, in the form of contractual agreements.
PharmaNest is committed to fostering a sustainable future by integrating environmental stewardship into our operations, research, and development.
Environmental Policy
PharmaNest is committed to fostering a sustainable future by integrating environmental stewardship into our operations, research, and development. This Environmental Policy outlines the principles and actions that PharmaNest will adopt to manage, monitor, and address climate change issues. Our commitment is driven by the belief that responsible environmental practices are essential to the long-term success of our company, the health of our planet, and the well-being of future generations. General principles include:
Compliance and Accountability
• Ensure compliance with all applicable environmental laws, regulations, and standards in the regions where we operate.
• Hold all employees and partners accountable for adhering to this Environmental Policy as an integral part of our Code of Conduct.
Sustainability Integration
• Incorporate sustainable practices into all aspects of our operations, including research, development, manufacturing, and supply chain management.
• Consider environmental impact as a key factor in decision-making processes.
Climate Change Mitigation
• Reduce greenhouse gas (GHG) emissions by adopting energy-efficient practices, utilizing renewable energy sources, and promoting low-carbon alternatives.
• Support innovative technologies and methods that minimize the environmental footprint of our operations and products.
Resource Efficiency
• Optimize the use of natural resources, including water, raw materials, and energy, by implementing reduction, reuse, and recycling initiatives.
• Minimize waste generation and ensure proper disposal of hazardous and non-hazardous materials.
Biodiversity Conservation
• Protect and preserve biodiversity by preventing harmful environmental impacts of our activities on ecosystems.
• Support initiatives and partnerships that enhance ecological conservation efforts.
Transparency and Reporting
• Monitor, evaluate, and publicly report our environmental performance, goals, and progress in a transparent and verifiable manner.
• Engage stakeholders, including employees, clients, and partners, in our environmental sustainability journey.
Continuous Improvement
• Commit to ongoing evaluation and improvement of our environmental management systems to adapt to emerging challenges and advancements in sustainability.
• Provide training and resources to employees to promote awareness and active participation in environmental initiatives.
Partnerships with Government Authorities and Regulators
We operate in good faith when interacting with government authorities and regulators.
We cooperate with all government authorities and regulators in connection with Company audits, potential investigations or requests for information, and support our clients who have the same objectives. When contacted by government authorities regarding a non-routine request, we expect all employees to immediately contact the Legal Department, who will advise on our rights and obligations as a company. Employees must not lie or in any way obstruct government authorities’ requests for information.
Similarly, we expect all employees to cooperate with internal Company audits and investigations by providing honest, truthful and complete information without fear of retaliation.
Business partners and the Code
We require our business partners to uphold the values and standards of PharmaNest when acting on our behalf.
PharmaNest expects all employees to promote the values and standards established by the Code. These very same expectations are also applied towards the Company’s business partners such as external consultants, partners, agents, suppliers, vendors or other entities acting on behalf of PharmaNest.
As such, PharmaNest seeks to work with only qualified and reputable business partners whose values and standards for conducting business are aligned with the Code as well as applicable laws, regulations and industry codes relating to generally accepted ethical standards for the protection of human rights, prohibition of child or forced labor and human trafficking, prohibition of money laundering and prohibition of corruption and bribery.
To ensure this, select business partners undergo regular and comprehensive screenings before entering into a business relationship with the Company.
Furthermore, engagements with business partners who do not meet the Company’s values and standards will be terminated. We are all responsible for holding our business partners accountable and employees are encouraged to collaborate with only reliable and ethically sound business partners.
Employees must report any business partner related concerns to their manager or the Legal or Compliance Departments.
Bribery and Corruption
We conduct our business with transparency and prohibit bribery of any kind.
PharmaNest is committed to integrity and transparency in all our business dealings. As such, the Company strictly prohibits all forms of bribery and corruption when interacting with healthcare professionals, customers, government officials, suppliers and vendors.
Employees, as well as third parties acting on behalf of the Company, must never offer, promise, provide, or authorize payments to improperly influence or gain an unfair business advantage in our business dealings or to illegally advance our business or financial interests. Additionally, we prohibit accepting any offer or demand for a payment that would affect our ability to act in the best interests of the Company. This includes the offering of “facilitating” or “grease” payments to public officials to expedite or secure performance of non-discretionary, routine governmental actions (e.g., processing a visa, customs invoice or other governmental paper).
While gifts, meals and hospitality are often part of customary business or professional relations, employees must exercise care to ensure such courtesies do not implicate anti-bribery laws and industry codes. Employees may provide these courtesy items to demonstrate respect, appreciation, and good etiquette, in accordance with the Code and the Company’s policies and applicable procedures.
If employees are presented with an offer or demand for a bribe or “kickback” or are in a situation where they are unsure whether a gift may be accepted, they should immediately contact their manager or the Legal or Compliance Departments.
Fair competition
We are committed to fair and open competition.
PharmaNest complies with laws that protect free enterprise and fair competition. We seek to compete in our industry based on the merits of our people and products. We do not participate in unethical business practices such as deceptive marketing, unauthorized use of confidential competitor or customer information or the theft of trade secrets.
Moreover, we prohibit agreements or arrangements between the Company and our competitors that aim to coordinate market behavior. This includes allocating territories or specific customers as well as fixing or coordinating prices. Employees should keep in mind that any such agreement with a competitor, formal or informal, may have serious legal consequences.
Many countries have complex antitrust or fair competition laws. While employees are not expected to understand all the requirements of these laws, we must recognize the intent behind them and know when to contact the Legal Department for guidance.
Ethical Sourcing
PharmaNest is committed to upholding the highest standards of ethical sourcing in all aspects of our business operations.
Our approach to sourcing materials and services is guided by integrity, transparency, and social responsibility. We strive to establish partnerships with suppliers who share our values, ensuring that our supply chain respects human rights, promotes fair labor practices, and upholds environmental sustainability.
We adhere to the following principles:
• Supplier Selection: We identify and engage with trustworthy suppliers through rigorous due diligence. This process includes evaluating suppliers' ethical business practices, compliance with labor laws, environmental impact, and adherence to international standards for workplace safety and human rights.
• Secure Trading Partnerships: Building long-term, secure relationships with trading partners is a priority. We ensure that our suppliers operate with transparency, providing clear and open communication, maintaining legal and ethical business practices, and aligning with our company’s commitment to integrity.
• Continuous Monitoring: We actively monitor our suppliers and trading partners to ensure they consistently meet our ethical standards. Regular audits, assessments, and feedback loops are implemented to address potential risks, ensuring continuous improvement and compliance.
By embedding ethical sourcing into our operations, we not only protect our business but also contribute positively to the communities and environments impacted by our supply chain.
Conflict of Interests
We seek to ensure our decisions and actions are always for the benefit of the Company.
PharmaNest recognizes and respects the rights of employees to engage in outside activities. As employees, we should avoid situations that present a conflict between our personal interests and the best interests of the Company. Additionally, we should avoid situations that may create even the appearance of a conflict of interest. A conflict of interest may involve internal Company activities, external opportunities or employment, vendor relations, human resource decisions or any number of other activities where an employee’s interests may not align with those of the Company.
Never abuse your position or Company property for your own personal benefit. We must always conduct business in a way that serves the interests of the Company and is not influenced by personal, family, or financial interests.
Employees must disclose all potential conflicts of interest to their manager or the Human Resources, Legal or Compliance Departments.
Gifts and Entertainment
We do not give or accept gifts and entertainment that could call into doubt our personal integrity.
PharmaNest understands that giving or accepting gifts and entertainment is often associated with customary business practices as well as cultural norms.
Under these circumstances, giving or accepting gifts and entertainment may be appropriate, so long as it is done with pure intent and not for the purpose of unduly influencing the recipient, whether it be a third party or Company employee.
Even the appearance or perception of an improper gift or entertainment could compromise the business operations and reputation of the Company. As such,
employees must use caution when giving or accepting gifts and entertainment during the course of their interactions with our business partners, vendors, suppliers and other third parties. We must adhere to the following requirements when giving or accepting gifts or entertainment:
• Gifts and entertainment must be of modest value, consistent with customary business practices and cultural norms
• Gifts and entertainment must not be lavish, excessive or based on a quid pro quo understanding.
• Requesting or soliciting gifts or entertainment is strictly prohibited.
The giving or accepting of gifts and entertainment must adhere to the Code and the Company’s policies and applicable procedures, especially those focusing on anti-bribery, corruption, and interactions with healthcare professionals.
For further clarification or guidance, employees should consult their manager or the Human Resources, Legal or Compliance Departments.
Managing information
We use company assets and information responsibly to advance our business goals.
Privacy
We respect the privacy of our employees, patients, business partners and healthcare professionals and are committed to protecting the integrity of all personal information held by PharmaNest.
PharmaNest collects, retains and uses employee personal information in order to support everyday business activities related to the management of employee compensation, benefits and other Company administrative purposes. Similarly, from time-to-time, we may collect, retain and use customer-related information during the course of our business activities. We treat and protect all personal information, whether internal or external, in a manner consistent with local legal and regulatory requirements. This often means that the Company must obtain an individual’s consent before receiving or using their personal information.
Personal information includes any data or details that may be used to identify an individual, such as name, gender, age or date of birth. We take precautions to safeguard personal information from intentional or accidental exposure. Unless permitted by law, we do not use or share employee, patient, business partner or healthcare professional personal information without the prior consent of the affected individuals.
While we strive to not collect patient personal information, and use only pseudonymized information, we strive to support our clients and collaborators to protect patient privacy.
Our Company seeks to promote responsible data protection and security principles for the collection, processing and disclosure of personal information. For information on specific requirements, please contact the Legal Department.
Our Privacy Policy is fully disclosed at https://www.fibronest.com/team-1 ( bottom of the page)
Asset protection and confidentiality
We use Company assets responsibly to advance our business goals.
PharmaNest provides employees with access to a variety of Company assets, both tangible and intangible, for use in the course of carrying out their job responsibilities. We expect all employees to properly use and protect Company property and confidential data from loss, damage, misuse or theft.
Tangible Company assets should primarily be used for the advancement of our business interests. We expect employees to limit their personal use of Company assets such as phone, email, computers and office supplies to a reasonable amount. The Company reserves the right to regularly review and monitor Company property to ensure its use is consistent with the Code and the Company’s policies and applicable procedures. Upon termination of employment, all Company property should be returned in accordance with Human Resources policies and applicable procedures.
We also provide and use a wide variety of intangible Company assets, such as patents, customer data, non- public information and other intellectual property, during the course of our business activities. These assets must also be protected from misuse or loss by adhering to the Company’s policies and applicable procedures on information security. Employees must maintain the confidentiality of Company business information, even after their employment with the Company ends.
Employees must report any suspected misuse of Company assets, whether tangible or intangible, to their manager or the Human Resources, Legal or Compliance Departments
Record keeping
We maintain accurate records of our business activities to sustain our operations as well as satisfy legal and regulatory requirements.
Maintaining accurate business records is essential not only to sustaining our day-to-day business operations but also preserving our credibility with customers, regulators and vendors. PharmaNest is committed to maintaining accurate records for all of our Company’s activities. Records include all documents created in the course of business, reports for our own management and reports made available to our customers, regulators, vendors and other stakeholders.
We adhere to Generally Accepted Accounting Principles (GAAP), research practice guidelines and quality requirements for the recording and reporting of financial reports, scientific data and quality records, respectively. All reports, including the underlying books and records, must be complete, accurate and reliable. The Company maintains internal controls designed to promote effective and efficient record keeping and reporting consistent with applicable legal requirements.
Additionally, all Company records must be maintained, stored and, when appropriate, destroyed in accordance with Company records retention policies and applicable procedures. In certain instances, such as those involving legal proceedings or government authorities, we may be required to maintain records for periods longer than those described in Company records retention policies. To understand which records must be preserved, or if a question arises as to the interpretation of a Records and Information Retention Policy, please contact the Legal Department.
Insider Trading
We must not use or disclose confidential Company information.
During the course of performing our job responsibilities, we may learn of confidential, non-public information regarding the Company’s business, including planned activities or transactions with business partners. We must respect and maintain the confidentiality of such “inside” information. It is illegal and unethical to use inside information or provide inside information to others for use in trading securities, also known as insider trading.
Employees may never take advantage of confidential information about the Company or its business partners for personal financial gain or pass that information to others, including friends or family members. Inside information, if disclosed or used, may have a significant impact on the Company and its employees, including criminal penalties.
Securities laws and Company policy restrict us from disclosing or using any inside information gained, either intentionally or by mistake, while employed at the Company. Only authorized Company employees are allowed to make previously confidential Company information public in accordance with the principles of ad hoc publicity and the requirements any relevant stock exchange.
Media and investor relations
We are committed to delivering accurate and timely material information to the public, including the media and our shareholders.
PharmaNest operates in a global environment where many stakeholders, including individual and institutional investors, may be impacted by our business operations and the decisions we make.
External communications with these stakeholders must be carefully managed in order to preserve the Company’s reputation as well as fulfill securities laws relating to the disclosure of material information to the public by publicly traded companies.
PharmaNest Global Communications & Public Affairs and Investor Relations Departments are responsible for handling all external communications with the media and investors, respectively. Only authorized spokespeople are allowed to make public statements on behalf of the Company related to our products or corporate developments.
We are committed to delivering timely and reliable information to the public. All communications to the media and investors must be approved in accordance with Global Communications & Public Affairs and Investor Relations policies and applicable procedures. Company employees other than designated spokespeople are not authorized to answer questions from the media or investors. Employees must direct all media and financial inquiries to the Global Communications & Public Affairs and Investor Relations Departments, respectively.
Social media
We use social media responsibly in a manner that reflects the values of our organization.
PharmaNest interacts with customers, patients, business partners, media and investors through various social media platforms. Additionally, employees may use social media for personal reasons outside of the scope of their job responsibilities.
Social media includes all internet-based communication tools that enable interacting, sharing and the management of information with others. Examples of social media platforms include, but are not limited to, Facebook, YouTube, Instagram, Twitter, Reddit and LinkedIn.
Only authorised employees may post information on the internet or social media platforms on behalf of the Company. All such social media communications created or shared must adhere to the Company’s policies and applicable procedures relating to the review, approval and dissemination of external information.
Employees utilizing social media for personal use should understand that their views may be attributed to the Company and that they should exercise sound judgment. Employees may not share or communicate the Company’s business, including information related to our products, research programs, business development activities and other potential confidential information.
While it is impractical to provide specific guidance on every form of acceptable use of social media, employees should use caution when posting any information online that may relate to the Company. We expect employees to communicate appropriately on all platforms and adhere to the employee standards of conduct described in this Code. For further guidance on the Company’s Social Media policies, please consult the internal Social Media Guidelines, if any, or contact your leadership for guidance.
Supporting people and communities
We value our employees, our communities and the environment around the globe
Workplace safety
We are committed to the well-being of our employees and aim to provide a safe, healthy and secure workplace.
PharmaNest recognizes the importance of treating employees with respect and creating a positive work environment. We recognize that our employees are our greatest asset and have a choice in working for the Company. Thus, we strive to offer employees the tools and resources to not only achieve our organizational goals, but also their own development objectives in a safe and healthy work environment.
Employees have the right to safety while working on behalf of the Company We adhere to all laws, regulations and industry standards relating to workplace safety and employee well-being. Additionally, our Company has implemented workplace safety best practices, Company safety policies and applicable procedures and employee training, where appropriate, in order to reduce the risk of workplace injury or harm. Our fully cloud-based operations and business model is innovative, and we will strive to design innovative approach for a safe and comfortable working environment.
We rely on employees to exercise care and caution in their workplace activities and promptly report any potential safety concerns to their leadership.
We will strive to promote this commitment to our business partners, contractors and vendors, if possible through our commercial agreements.
Environmental Welfare
We respect and care for the environment through responsible business practices.
PharmaNest values the environment and seeks to minimize the impact of our business operations. We recognize that longterm commercial success is achieved through sustainable business practices and compliance with environmental laws, regulations and industry standards.
Employees should use due care and diligence when conducting activities or handling materials that may pose harm to the environment. To this end, we have established Company policies and applicable procedures for employees to follow. We are responsible for promptly reporting potential environmental accidents to Company management and, in some cases, environmental regulatory agencies. We are committed to correcting any environmentally unsafe conditions or practices in our daily tasks. Additionally, we must strive to conserve resources and reduce waste and emissions through recycling and other energy conservation measures to protect the communities in which we live and work.
We will strive to promote this commitment to our business partners, contractors and vendors, if possible through our commercial agreements.
Political involvement and contributions
We respect employees’ rights as private individuals to express their political beliefs.
PharmaNest supports employees’ rights as private individuals to express their beliefs through participation in the political arena. However, on behalf of the Company, we have established standards for political engagement to ensure our actions best impact the interests of the Company and the communities in which we operate.
Employees may not support their private political causes in the course of their job responsibilities or on behalf of the Company. However, we respect employees’ rights to do so as private individuals using their own personal time and resources. Additionally, employees may not solicit or request other employees, customers or vendors for political contributions or support.
Employees should direct all requests for political contributions or support to their leadership.
Charitable involvement and contributions
We support charitable causes that align with the Company’s values and mission.
We recognize the visibility of our Company and our ability to improve the world in which we live. Supporting charitable and philanthropic causes helps further our mission of making a meaningful difference in patients’ lives.
Although there are many charitable organizations and causes the Company could support, the Company focuses its resources on those that align with our values and mission. Support for charitable organizations or causes may come in the form of Company sponsorships, monetary support and in-kind donations of goods or services. We encourage employees, as private individuals, to support causes that improve our communities or are of personal interest.
However, for all Company-requested support, employees should direct requests to their leadership and may not promise or otherwise commit the Company’s support for a charitable request. All Company charitable support must be reviewed, approved and funded in a manner consistent with the Company’s policies and applicable procedures. For questions or details on the types of charitable organizations and causes supported by our Company, please contact the leadership of the company.
Version Release date Content
1 March 2023 Creation
2 October 2, 2024 Enriched with Ethical sourcing Link to Oct 2 2024 Privacy policy
3 January 27 025 Added with Environmental Policy
