EVROSTON ECONOMICS AND MANAGEMENT CONSULTANTS CORPORATE BUSINESS ETHICS POLICY JANUARY 2012
CORPORATE BUSINESS ETHICS POLICY TABLE OF CONTENTS Page 1. INTRODUCTION 2 2. COMPLIANCE WITH LAW AND REGULATIONS 2 3. QUALITY SERVICE 2 4. COMPETITION AND ANTITRUST 3 5. ADVERTISING AND PROMOTION 3 6. SCIENTIFIC STAFF 3 7. CONFLICT OF INTERESTS 3 8. INTELLECTUAL PROPERTY & CONFIDENTIAL INFORMATION 4 9. ASSET PROTECTION AND USE 4 10. BUSINESS OPPORTUNITIES 4 11. CONTACTS AND REPRESENTATION 4 12. PEOPLE ACTING ON BEHALF OF COMPANY 5 13. RECORDS BOOKS AND ACCOUNTING 5 14. POLITICAL ACTIVITY 5 15. CORPORATE SOCIAL RESPONSIBILITY 6 16. ENVIRONMENTAL POLICY AND MANAGEMENT 6 17. WORK ENVIRONMENT 6 18. SAFETY AND HEALTH 6 19. PARTNERSHIPS AND TRANSACTIONS 7 20. CODES ASSOCIATED COMPANIES 7 1
1. INTRODUCTION EVROSTON (the Company) undertakes consulting and research regarding business, investment, financial, and others issues in the sectors relating to healthcare services, pharmaceuticals, medical devices, chemicals, drinks and foods. The Company is undertaking consulting in the areas of market research, marketing, pricing, compensation strategy, brand development, advertising, sales promotion, organizational and human resource development, and economic appraisal. The reputation of a Company is its fundamental and most valuable asset. This reputation is largely based on compliance with the law, respect of rules and regulations, the behavior and the prevailing ethical standards in the conduct of business. The vision and mission of the Company, its values and this Code of Business Conduct (Code) provide guidelines that are essential for its success. This Code is intended to inform all interested parties about the legal and ethical obligations and commitments of the Company and its personnel to its clients and society in general. It also includes the rules governing intra-corporate processes and behavior. Taking into account the legal and regulatory complexities of today's markets it is essential to have a clear policy and rules of conduct that need to be implemented by all stakeholders. The Company's management is responsible to define, update and continuously implementing standards of business conduct, depending on changes in the regulatory, regulatory and business environment and conditions. 2. COMPLIANCE WITH LAW AND REGULATIONS The Company and its officers, consultants and researchers, implement and comply with all applicable domestic and international laws, rules and regulations regarding the conduct of research and consulting services and studies in the fields it specializes As the Company is often involved in medical research its makes sure that it implements all applicable international and local rules and regulations for the conduct of clinical trials, observational studies and pharmaco-economic studies. The Company is committed to maintaining an open, constructive and professional relationship with regulatory bodies on issues related to the industries in which it operates. 3. QUALITY SERVICE The Company provides independent services of high quality, reliability, efficiency, scientific rigor that adequately meet the needs of the companies and organizations it cooperates. The scientific staff of the Company are highly trained and qualified to undertake the studies and services in hand and the information provided is sufficient, honest, unbiased, accurate and robust. 4. COMPETITION AND ANTITRUST The Company and its staff apply the anti-trust legislation and promote free, fair, and open competition in the market, avoiding collusion and illegal actions. It tries to persuade the partner organizations to choose it because of its merits and advantages and scientific collaborations. The Legal Adviser's opinion is 2
demanded on all those cases where the management and the employees of the Company want to ensure beyond any doubt that their actions are within the laws and regulations of fair competition. The Company's activities uphold the law, equality, fair competition, honesty, respect, ethics, justice, and condemns discrimination, exploitation of the weak, and opaque and irregular or illegal practices. 5. ADVERTISING AND PROMOTION The Company and its staff ensure that all actions and means of advertising and promotion services and claims, comparisons and arguments put forward on the basis of analyses and studies are accurate, objective, clear, reasoned, balanced, and are based on science and real data. The studies are intended to give a clear and fair view of the technical, operational, clinical and financial characteristics of different health technologies and decisions in relation to the alternatives available and to encourage rational use of technologies and services. Any information, communication, material, study, publication of the Company is honest, objective, reliable and in full compliance with the regulations and the Code. 6. SCIENTIFIC STAFF The staff performs their duties with responsibility, professionalism and ethical behavior and provide objective, accurate and timely information and analyses. They are well trained, educated and constantly monitor the progress of knowledge, science and technology in order to be abreast of the latest scientific developments and assist with analysis and studies the organizational effort for better and more efficient industries. The Company is staffed with scientists and specialists wit significant expertise and invests in education, development and encouragement of staff in order to meet the performance and exceeds the needs and expectations of its customers. The Company and its staff behave towards all manner consistent with high standards of professionalism, decency and ethical conduct. Nobody takes actions that may damage, cause injustice, abuse or exploit a third person or entity. 7. CONFLICT OF INTERESTS All involved staff and scientific partners fulfill faithfully their duties to the Company and protect legitimate interests of the Company and the institutions and organizations with which it cooperates. In this context, partner scientists, avoid engaging in activities where their private interests conflict with the interests of the Company and the entities with which it works. This can occur when an employee or scientific collaborators or a relative of the person undertaking activities with the Company has financial interests that cause difficulties to perform his duty to the Company and its customers effectively and objectively. Conflicts of interest can take many forms, including cooperation, employment, ownership or other financial relationship with a competitor of the Company or its customers, use of systems, data, reports and information that belongs to the Company of its customers for unauthorized use or personal gain. 3
8. INTELLECTUAL PROPERTY & CONFIDENTIAL INFORMATION Confidential information and intellectual property are information and data for each company, its products, its strategies and its customers, which is not generally known or readily available to third parties. This information is an integral asset of the Company and play a key role in its success. Confidential information may for example include know-how, trade secrets, knowledge about research and product development, business plans, marketing and sales programs, sales figures, product pricing and financial data, forecasts, data customers and suppliers, systems administration, organization and software, clinical data and health technology personal information. Moreover it may regards private information and personal data of patients. Confidential information can be stored and found in documents, letters, memos, drafts, presentations, files, videos, films, optical, electronic and acoustic instruments and computer files. The Company and its personnel protect confidential information from unauthorized access which may violate the interests and rights of the Company, its employees, its customers and third parties in general to which they refer. 9. ASSET PROTECTION AND USE All employees should protect the Company's assets and ensure the correct, lawful and authorized use in the achievement of business objectives and to protect the interests and benefits of the Company and its customers. Theft, damage and injury, and the irrational, mindless, harmful, polluting, unauthorized, harmful, unlawful, use of tangible and intangible assets of the Company is not permitted. 10. BUSINESS OPPORTUNITIES If an employee becomes aware of any business opportunity that may be interesting for the Company must notify its administration. Employees are not permitted to use for personal gain opportunities that are revealed through the use of company property, information or position, nor may use corporate property, information or position for personal gain or reasons of competition with the Company. Employees have a duty to promote the interests of the Company at any possible opportunity. 11. CONTACTS AND REPRESENTATION The Management of the Company must be informed immediately of any inquiries or requests for business by the authorities, the media, competitors, analysts, agencies or any third party contractor, so you can respond appropriately and adequately. If an employee accept a non-trivial request for information, interview or representation of the Company should be aware that the Government and the authorities have the right to request information and records of the Company, but should immediately contact and inform the Administration so that appropriate action in consultation with the Legal Advisor for the correct representation of the 4
company. In each case the contact with authorities workers must be honest and to testify the truth and the facts, data, documents and information relating to the Company. In any event, workers shall not destroy documents and information from the records of the Company. 12. PEOPLE ACTING ON BEHALF OF COMPANY Every independent party acting on behalf of the Company must be fully compliant and implement the policies and principles set out in this Code. The staff and management of the Company have duty and are responsible to ensure that the terms of each contract and relationship defined by written agreements are consistent with the Code. Additionally responsible for overseeing and monitoring the implementation of the Code by the Contracting Parties and cooperating. Noncompliance and non-implementation of the Code and the promotion or participation in any practices that violate the principles should lead directly to a close relationship with the Company. 13. RECORDS BOOKS AND ACCOUNTING The Company maintains accurate, reliable, honest and detailed records of all activities in order to be able at all times for business, legal, historical or other reasons, to provide information and data on activities in all concerned and especially all collaborating institutions. Also its maintains financial records and are following in full accounting standards, rules and regulations in order to ensure full compliance with the laws, principles and morally accepted standards of the Company, to ensure transparency and prevent fraudulent transactions. Everyone involved in the financial management and reporting of financial data of the Company acts with honesty, reliability, legitimate and objectively and ensures the accuracy and reliability of records and data files. 14. POLITICAL ACTIVITY The Company supports the right of every employee or associate scientist to actively participate in political and democratic processes. Employees must though get be approval by management before any activity takes place during working hours, or involve the property of the Company or its name to any political party, candidate, committee activity. Funds and assets of the Company may not be used directly or indirectly to any political party, political committee, or candidate for public office. No employee is allowed to try to influence the decisions of the principles and rules relating to the business interests of the Company, except for legal actions and are pre-approved by the Company's management. 5
15. CORPORATE SOCIAL RESPONSIBILITY The Company places great emphasis and importance on social responsibility. Both the internal organization and operation and in any outdoor activity, follow a management model that focuses on respect for human beings, ethical behavior, respect for rules, environmental protection and quality products and services. 16. ENVIRONMENTAL POLICY AND MANAGEMENT The Company has committed to carry on business in a environmentally responsible manner and will try to improve performance for the benefit of employees, customers, communities, shareholders and the environment. All employees have a responsibility to ensure that the business of the Company is carried out in accordance with all applicable laws and in a manner that protects the environment. 17. WORK ENVIRONMENT The Company focuses on creating a working environment that fosters productivity, reciprocity, fairness, equity, culture, ethos, solidarity, teamwork, ambition, freedom, creativity, appreciation, respect and dignity. The company encourages and invests in personal development and continuing education and specialization of staff through training programs. Also its encourages staff to report any concerns it has regarding the above issues and prohibits any work safety and respects freedom, individuality, dignity and the need for confidentiality and discretion. All communications infrastructure and resources of the Company as used only for legitimate purposes of its business and maintains the right to control the lawful use and to compliance with the principles, laws and the Code. In the modern era of electronic communication media allow rapid and sometimes uncontrolled transmission of communication within and outside the enterprise. Employees of the Company shall in all forms of communication, especially the electronics to make sure they fully implement the Code and provisions. 18. SAFETY AND HEALTH The Company is committed to providing a safe and healthy work environment, which is consistent with all applicable laws and regulations. It is also expected of all employees of the Company to develop proactive and collaborative attitude towards health and safety issues. Similarly, the Company fully complies with the law and provide for the health and safety in the workplace. Housed in modern buildings, creating a pleasant environment with comfortable and elegant facilities and equipment. 6
19. PARTNERSHIPS AND TRANSACTIONS No benefit value, gift, reward, or other retaliation is given directly or indirectly to government officials, political parties, candidates or party officials, employees or government departments and public entities in the public sector in general, professionals, officers and executives of the Health System, doctors, nurses, administrators and any person or entity, in exchange for favorable treatment of the Company and its customers. The offering or providing of gifts and services and polite gestures, are moderate, humble and of insignificant value, they do not create an obligation to the Company or its customers, and is consistent with the business purposes of the Company and is by applicable laws, codes of business conduct and always is done with the aim to promote education and research. Company finance costs related to transportation, accommodation, and feeding people, dinners or similar events for educational, research and scientific purposes, and in all such cases the amount is low cost and does not create an obligation and requirements, and is allowed by law and is for legitimate business purposes, such as speech or participation in a scientific conference, research program and the like. The Company may pay scientists and professionals to participate in consultation and advice and services relating to business or research purposes. Payments for consultancy services, participation in the design and implementation of studies, honoraria for education, and similar services are covered if they are within reasonable and acceptable limits. The fees should be allowed, and to be fair and reasonable, to create value for the Company and its customers, to be legal and monitored with transparently through appropriate documentation and accounting procedures. The selection of scientists is based on the curriculum and qualifications depending on the specific case of cooperation. 20. CODES ASSOCIATED COMPANIES The Company works in Greece and abroad with some of the largest and leading multinational firms word-wide. The actions and the Code of Business Conduct of the Company complies in full with the corresponding ones of the associated firms it collaborates with, as well as with the respective Codes of various National and International Professional Industrial Associations, such as the Union of Advanced Medical Technology Companies, the European Federation of Pharmaceutical Industries, the Greek Association of Pharmaceutical Companies and others. 7