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.