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Scientist.com Global Compliance Standard

EXPECTATION OF VENDORS

What Is This Standard?

Many of the customers ("Buyers") that use Scientist.com to find and purchase services and/or products have strict standards for doing business and require that the providers of the services requested by Buyers ("Vendors") they do business with adhere to the same high standards. This document lays out the expectations of Vendors that do business with Scientist.com Buyers.

GUIDING PRINCIPLES

Organization & Culture

Vendor has a governance structure & culture that reinforces ethical and lawful behavior & ensures all aspects of its business are in full compliance with all applicable laws, rules, regulations, guidelines and requirements, including financial, legal and ethical standards. It extends this expectation to any other Third Party intermediaries acting on its behalf.

Risk Identification & Assessment

Vendor has annual internal/external reviews that measure its risk controls and identify the actions needed to deliver any necessary improvement. This includes assessing the risk of activities carried out by Third Parties acting on its behalf. It defines roles for leaders in terms of responsibility for all aspects of running the organization, including the identification, assessment and mitigation of risks to ensure business continuity

Standard Setting

Vendor has an established governance structure consistent with the size and nature of the business that defines policies/ways of working and controls for managing its business ethically. Ways of working are less formal polices that employees would recognize and be able to explain to an independent party (applicable to organizations with fewer than 15 employees). It shares these with its own Third Parties so that they are clear what standards are expected of them and, where appropriate, assesses if their policies are adequate. Vendor identifies and complies with all applicable laws, regulations, codes and standards, both in the country in which the Vendor works and in the country in which the service or products will be provided. Vendor complies with all relevant contractual customer requirements, even where these are higher than local or national laws.

Training and Competency

Vendor has a training program that achieves an appropriate level of knowledge, skills and abilities in management and workers to address these expectations.

Control Activities

Vendor has monitoring in place, to ensure that processes are being adequately followed and risk control measures are effective. Identified process and control failures should be addressed.

Reporting, Investigation and Remediation

Vendor encourages its employees to report concerns or illegal activities in the workplace without threat of reprisal, intimidation or harassment. Vendor investigates such reports and other incidents and takes corrective action if needed.

WHAT THIS MEANS IN PRACTICE

Vendor is free to determine what methods it uses to meet these expectations. It is acknowledged that local laws, values and cultural expectations may influence how these principles are applied in practice but they must be in the spirit of this Standard.

For certain highly sensitive areas, the Vendor may be expected to work exactly to the Buyers policies and standards but this will be specified in a separate contract between the Buyer and the Vendor.

1.

ANTI-BRIBERY AND ANTI-CORRUPTION

Vendor has a zero tolerance of bribery or corruption and does not give or receive bribes when conducting business. Vendor shall not:

  • Offer, request or accept bribes or permit sub-contractors or others to do so on their behalf. This includes:
  • Offering or giving – directly or indirectly – money or anything else of value, including gifts and hospitality, to any person or organization that is intended to, or could be seen as an attempt to influence or reward them to behave improperly in order to obtain or retain business or secure a business advantage for themselves, their organization or on behalf of the Buyer or as an attempt to influence or reward an official action or decision (e.g., by a public official).
  • Requesting or accepting – directly or indirectly – money or anything else of value, including gifts and hospitality, if it is intended, or could be seen as an attempt, to compromise their independence or judgment, or to improperly influence a business decision for themselves, their organization or the Buyer.

Unless specifically authorized by the Buyer, the Vendor shall not:

  • Provide any Service for or on behalf of the Company or anything else of value including hospitality
  • Give any gift or any contributions to anyone on behalf of the Buyer.
  • Give any political support on behalf of the Buyer or participate in political activities on behalf of the Buyer.
  • Make any facilitation payments on behalf of the Buyer, either directly or indirectly, to public officials (including healthcare professionals and other individuals employed by public sector organizations), regardless of whether such payments are nominal in amount, unless under duress (where there is reasonable fear for personal safety).

Vendors shall:

  • Promptly report in writing to Scientist.com all incidents where they are involved in the following situations:
    a) Facilitation payments are requested but not paid; or
    b) Payments are demanded under duress, whether paid or not.
2.

CONFLICTS OF INTEREST

Vendor does not allow Conflicts of Interest to influence or compromise the professional duties and decisions of the Vendor or its employees. Vendors shall:

  • Inform Scientist.com in writing of any actual, apparent or potential conflicts of interest relevant to the Vendor's performance of services for the Buyer, at the time they become known.
  • Have financial controls in place to prevent conflicts of interest affecting procurement and financial decision making.
3.

EMPLOYMENT PRINCIPLES & MODERN SLAVERY

Scientist.com is committed to eliminating slavery, servitude, forced or compulsory labor, human trafficking, and child labor (collectively, "modern slavery") in our supply chains and business operations.

We require all organizations to operate in line with internationally recognized human rights and promotes and maintains a culture of respect and equal opportunities. Any organization that is knowingly engaging in or otherwise taking action that supports modern slavery in our business operations, providing services via the Scientist.com platform and/or our supply chain is grounds for immediate termination of agreement. More specifically, this policy prohibits doing any of the following in the course of doing business:

  • Using child labor in the performance of contracts, which includes any person under the age of 15 or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 will not perform work that is likely to jeopardize their health, safety, or well-being. Will not employ workers under 18 at night or in hazardous conditions;
  • Procuring commercial sex acts (any sex act for which anything of value is given or received);
  • Using forced, bonded or indentured labor or involuntary prison labor in the performance of contracts, which includes any practice or conduct which materially restricts a worker's or contractor's freedom to leave their job;
  • Destroying, concealing, confiscating, or otherwise denying access to an individual's identity or immigration documents, such as a passport or driver's license (regardless of the issuing authority);
  • Making workers' pay for recruiting fees;
  • Using recruiters who do not comply with local laws;
  • Using misleading or fraudulent practices during the recruitment of workers, which includes failing to disclose or making material misrepresentations as to the basic details and terms or conditions of employment, such as wages and benefits, work location, living conditions or costs, costs charged to the worker, or the hazardous nature of work;
  • Failing to provide a worker with an employment contract or contract for services in writing if required by law or contract, including (i) failing to disclose, in a format and language accessible to the worker, basic employment information and (ii) failing to provide at least five days written notice prior to relocating a worker;
  • Not compensating workers according to applicable wage laws, including minimum wages, overtime hours and mandated benefits;
  • Have working hours that do not comply with national laws;
  • Not communicating with the employee, the basis on which they are being compensated in a timely manner;
  • Not communicating with the employee whether overtime is required and the wages to be paid for such overtime;
  • Failing to provide return transportation or cover the cost of return transportation upon the end of employment, for a worker who is not a United States national and who was brought into the US for the purpose of working on a US government contract or subcontract under certain circumstances;
  • Providing housing to workers that violates local housing or safety laws;
  • Not respecting the rights of employees, as defined in local laws, to associate freely, join or not join labor unions, seek representation, and join employees' councils
  • Doing business with a vendor or supplier that you know engages in modern slavery, including any of the practices described above; and
  • Establishing or maintaining a commercial business relationship with a customer that you know engages in modern slavery, including any of the practices described above.

Reporting Concerns

If an employee, temp, vendor, or contractor of Scientist.com or their agents becomes aware of or suspects behavior that constitutes modern slavery in connection with business operations or supply chain, they must report it immediately to the Compliance team. Remember, Scientist.com has a strict policy against retaliation for raising a concern.

4.

SAFETY, HEALTH AND THE ENVIRONMENT

Vendor carries out business in an environmentally responsible manner and promotes a safe and healthy workplace for all their employees, including those who work on their behalf worldwide.

PROTECTION OF THE HEALTH AND SAFETY OF PEOPLE

Vendors shall:

  • Protect people from unhealthy exposure to physical, psychological, chemical and biological hazards. Significant releases of chemicals are prevented or otherwise mitigated through reliable process safety controls.
  • Make information relating to SHE risks, chemicals and other hazardous materials, including pharmaceutical materials available and use it to manage risks and train and protect people.
  • Put registrations/notification approvals and applicable legal documentation for the manufacture, import and transport of hazardous materials in place as required by local and international regulations.

ENVIRONMENTAL PROTECTION & CONSERVATION

Vendors shall:

  • Manage business activities in a way that, as far as practical, avoids the use of hazardous materials, conserves water, energy and other natural resources and minimizes the generation of waste through avoidance, reuse and/or recycling.
  • Ensure any emissions to air, water and land are in compliance with laws and regulations and controlled or treated to the extent necessary to eliminate, or otherwise minimize the risk of, adverse affects on human health or the environment.
5.

TRADE CONTROLS AND COMPETITION

Vendor complies with all competition and anti-trust laws applicable in the countries where it operates. It is committed to importing, exporting and engaging in all other forms of trade in a legal and ethical manner.

TRADE CONTROLS

  • Vendors shall comply with applicable trade regulations including licensing requirements, boycotts, embargoes and other trade restrictions that have been approved by recognized national and international authorities.

COMPETITION

Vendors shall:

  • Only seek competitive advantage through lawful means and conduct their business consistent with fair and vigorous competition.
  • Only engage in dialogue with competitors when there is a legitimate business reason to do so, and the dialogue is such that it will not restrict competition (e.g. is limited to public or non-commercial information).
  • Not abuse their position, if it is dominant or has a monopoly, to exclude competitors or exploit customers.
6.

RESEARCH & DEVELOPMENT ETHICS

Vendor conducts high quality science delivered to high ethical standards in all areas of research and development.

Specifically in the areas of:

  • Supply or use of biological samples especially human embryonic stem cells (hESCs), and genetically modified organisms (GMOs)
  • Animal research
  • Clinical trials and patient safety

Vendors shall:

  • Provide assurance that they comply with all national or state laws, regulations & recognized international quality and safety standards applicable to the proposed work including bio-safety containment in all countries in which they operate.
  • Ensure that the appropriate informed consent & personal data protection procedures are in place and applied consistently.

ANIMAL RESEARCH AND WELFARE

Vendors shall apply the following principles to all animal studies and to the breeding and supplying of animals for use in such studies:

  • A humane approach must be adopted in the care and treatment of all animals, and the greatest consideration given to their health and welfare, consistent with meeting the necessary scientific objectives.
  • All animal studies must be carefully considered and justified to ensure that the principles of the 3Rs (replacement, reduction, refinement) are applied.
  • Animal studies should not involve wild-caught non-human primates or great ape species.
7.

PRODUCT SECURITY

Vendor tackles the threat of counterfeit and illegally traded medicines and improving the security of the end-to-end supply chain.

Vendors shall:

  • Not be involved in any activity related to counterfeit or illegally traded medicines
  • Counterfeit medicines are those that are deliberately and fraudulently mislabeled with respect to identity and/or source
    • Illegally traded medicines include illegally diverted, fraudulently traded, tampered with and/or stolen medicines
    • Inform Scientist.com in a timely manner in the event of any incident related to illegally traded or counterfeit medicines and assist Scientist.com, and/or the Buyer in any subsequent investigation.
8.

PRODUCT COMMUNICATIONS

Vendor provides information about medicines and other products to high ethical standards. Vendors shall:

  • Only provide information about the Buyer's products when authorized to do so. This includes communications about the Buyer's products in person, through written material, on the Internet or other media.
  • Promote the Buyer's products in an ethical, fair and balanced way.
  • Use only promotional materials and other product information that have been approved through appropriate Buyer review procedures.
  • Not engage in direct to consumer/direct to patient communications unless permitted by local laws and directed by Buyer.
9.

CONFIDENTIALITY AND INSIDER TRADING

Vendor protects confidential information from improper disclosure. Vendors shall:

  • Agree to confidentiality agreements if confidential information is to be shared & ensure any authorized communication of confidential information is limited to individuals who have a "need to know".
  • Prohibit their employees from insider trading for their own or other's personal profit.

These requirements apply even to misuse use of Confidential Information after a Vendor has finished doing business with the Buyer.

10.

LICENCES AND CERTIFICATIONS

Vendor has the appropriate certifications for each of the fields in which it operates. Vendors shall:

  • Maintain appropriate current certification from the relevant authorizing body for all of the services and/or products claimed.
  • Provide proof of certification to Scientist.com upon request.

GLOSSARY AND DEFINITIONS:

Buyer – For the purposes of this document, the term Buyer refers to the entity that is either contracting with the Vendor to purchase a product and/or service, or is in discussion with the Vendor about a product and/or service.

Vendor – Any person, company or organization that lists their products and/or services on Scientist.com, or is listed in any manner in the Scientist.com database such that they may be found by a Buyer looking for products and/or services.

Confidential Information – Information that gives the Buyer and/or the Vendor a competitive edge. This includes, but is not limited to: Intellectual property and know-how; managerial information and statements of strategic intent; or pricing or stock market sensitive data and statements.

ILO – The International Labor Organization is an international organization responsible for drawing up and overseeing international labor standards. It is the only ‘tripartite' United Nations agency that brings together representatives of governments, employers and workers to jointly shape policies and programs promoting Decent Work for all.

Personal Data – Any information about an identified or identifiable natural person.

Product Information – Any information, material or activity, promotional or non-promotional, designed to inform healthcare professionals and organizations, patients, investors, the media and others about the characteristics and use of the Buyer's products.

Incidents – Includes theft of material, discovery of counterfeit or fraudulent activity, demonstration by activists, threat to staff, SHE, bribery and corruption or any other area covered by this Standard.