As a business we are committed to doing the right thing. It is important to us and is what our customers, employees, and shareholders find compelling. We ensure we comply with our legal and ethical obligations throughout our business operations, from the way we source materials, design and manufacture our products, through to selling our products across the world.
Our Code of Conduct reinforces this culture. All employees are trained on this policy, and understand they have a responsibility to work in a legal and ethical manner. The Code covers a range of areas relevant to legal compliance, including competing fairly, health and safety, data protection and privacy, working with customers and suppliers, sanctions compliance, responsible marketing, financial records and reporting, continuous disclosure and insider trading, combating bribery and corruption and interactions with healthcare professionals.
Our Speak Up (or whistle-blowing/protected disclosures) policy ensures that employees know how to report potentially unethical or illegal behaviour or breaches of our Code of Conduct, without fear of retaliation or harassment.
We have an in-house legal team that provides advice and assistance to the business globally on how to comply with our various legal obligations, and engage external legal counsel to assist us as and when required.
In the course of our business we interact with a wide range of government officials and private sector individuals or businesses, including government regulators, inspection authorities and healthcare professionals.
We do not tolerate bribery, corruption, kickbacks or other types of improper benefits, whether committed by our own people or by anyone we deal with.
Most of the countries in which we operate have strict anti-bribery and corruption laws that apply to our interactions with public officials. We have processes in place for assessing anti-bribery and corruption risk and implement measures to mitigate these risks.
Failing to comply with these laws could have serious consequences for us, both as individuals and as an organisation. In some cases, these consequences could include criminal charges.
Our Code of Conduct sets out our expectations for all employees in combatting bribery and corruption. We never offer or accept (or ask a third party to offer or accept) bribes, facilitation payments, secret commissions or kickbacks to or from any person. These rules apply to all our business activities, including any interactions we may have with government officials or with any private person or business, either locally or overseas.
The Code requires that where we suspect bribery or corruption, either by our own people or by any of our suppliers, customers or other business partners, we report it immediately. The Speak Up policy ensures that all employees know how to make such a report, and can be confident that concerns will be taken seriously and investigated and will not result in retaliation or other harassment.
As we are a healthcare business, we must comply with laws and regulations on interacting with healthcare professionals in various countries around the world. It is critical that our activities do not improperly influence the medical decisions of healthcare professionals or the purchasing decisions of entities that buy our products.
Our Policy on Interactions with Healthcare Professionals ensures that we act ethically and legally in our interactions with healthcare professionals, comply with all applicable laws, and do not provide improper benefits or inducements to healthcare professionals. We provide training to employees on this policy.
We sometimes participate in or observe testing to assess biocompatibility and obtain worldwide regulatory clearances. This includes animal testing on rabbits, pigs, guinea pigs and mice. We conduct this testing to according to International Standards 10993 and 18562.
Our external test labs maintain accreditation to the Association for Assessment and Accreditation of Laboratory Animal Care (AAALAC), and all applicable portions of study protocols are conducted as per regulations and guidelines regarding animal care and welfare.
Wherever possible, we look for alternatives such as in vitro or analytical chemistry testing, which do not require the use of laboratory animals. We take great care to ensure there is no duplicate testing of our products.
In order to sell our products around the world, regulatory permission and compliance with established regulatory requirements is required. Without evidence of regulatory compliance or specific product licenses, we are not permitted to market our products in certain countries.
We have a regulatory affairs process that enables us to obtain and maintain product licenses, as well as a quality management system that ensures compliance with applicable regulatory requirements.
We have monitoring steps in place to evaluate the effectiveness of our programmes, and our executive management team conducts regular management reviews.
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