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Corcym S.r.l. Organisation, Management and Control Model CODE OF ETHICS 01 June 2021
Corcym S.r.l. Organisation, Management and Control Model CODE OF ETHICS 01 June 2021
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Table of contents 1. Introduction 3
2. General Principles 4 Compliance with laws 4 Defence of Human Rights and Protection of Equal Opportunities 4 Labour Protection 4 Protection of Workplace Health and Safety 4 Environmental Protection 4 The Fight against Corruption 4 Financial Integrity and Accounting Transparency 4 Privacy and Protection of Personal Data 5 Protection of Intellectual Property 5 Protection of Company Assets 5
3. Relationships with Patients 6
4. Relationships with Healthcare Professionals and Healthcare Organisations 7
5. Customer Relationships 8
6. Relationships with Suppliers and Consultants 9
7. Relationships with Employees and Contractors 10
8. Community and Institutional Relations 11
9. Relationships with Competitors 12
10. Implementation of the Code and Reporting 13
11. Penalty Provisions 14
12. Supervision 15
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1. Introduction Corcym (“Corcym” or the “Group”) is a multinational group of companies with a presence in more than 100 countries, engaged in the production and distribution of heart valves. With an awareness of its responsibilities towards patients, customers and those who contribute to the performance of the corporate activities, and more generally the community of which it is a part, Corcym's activities are inspired by the principles and rules of conduct outlined in this Code of Ethics (“the Code”). Corcym's directors, employees, suppliers, consultants and contractors of any kind – even those who act under their own responsibility or on their own behalf – are required to comply with the Code, as well as the internal policies and procedures which regulate the processes into which the activities of each Group company are divided. The code is freely available for consultation on the website www.corcym.com. A hardcopy can be requested by emailing [email protected].
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2. General Principles Compliance with laws
Corcym respects the law and operates in compliance with all regulations to which it is subject, both national and international.
Defence of Human Rights and Protection of Equal Opportunities Corcym respects and promotes universally recognised human rights, and repudiates all discrimination on the basis of gender, race, language, religion, political opinions, and personal and social conditions. Corcym is committed to creating a working environment which is inclusive and respects each person’s differences and dignity, opposing any form of discrimination, harassment and abuse, as well as intimidation and abuse of power. Corcym is committed to offering equal opportunities to all workers, both during the hiring process and as regards career advancement, ensuring that all staff are treated with dignity and respect.
Labour Protection Corcym respects and promotes each worker's right to freely exercise and assert the rights assigned to them by national and international legislation during their work. The company supports the fight against forced labour, child labour and all other forms of exploitation. Each worker is free to choose whether to join trade unions and/or other workers’ associations, and participate in collective bargaining.
Protection of Workplace Health and Safety Corcym is committed to creating and consolidating a culture of safety, developing awareness of risks and promoting responsible behaviour from all employees and contractors.
Environmental Protection
Corcym promotes the responsible use of resources in order to allow responsible development which respects the environment and the rights of future generations. To this end, it is committed to minimising the impact of its activities on the environment and complying with all applicable environmental standards and regulations.
The Fight against Corruption Corcym is committed to fighting all forms of corruption. It is prohibited to offer, promise or give money or other considerations, or to solicit or request money or other considerations, in order to obtain undue services for or by Corcym.
Financial Integrity and Accounting Transparency Corcym complies with legal requirements in all financial operations and transactions in order to ensure consistency, congruency and proper recording at all times. Accounting records and corporate documentation are made in a timely and accurate manner, on the basis of complete, truthful, accurate and precise information.
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Privacy and Protection of Personal Data
All Corcym employees and contractors are required to safeguard the confidentiality, availability and integrity of information in accordance with strict standards. This applies in particular to personal data undergoing processing involving the risk of loss, deletion or unauthorised access. To this end, everyone is required to comply with applicable data protection and information security legislation. In the performance of work duties, the utmost confidentiality must be maintained regarding news and information relating to Corcym, its know-how, activities and products, such as: strategies; R&D; technical, production, sales and marketing data; promotional or sales activities or marketing campaigns; operating financial results; corporate operations; information on personnel and wages. Even following the end of the working or other relationship, all knowledge and information acquired through work as an employee or contractor must be safeguarded and not improperly divulged in any case.
Protection of Intellectual Property Corcym complies with and protects all forms of intellectual property, both its own and that of third parties, whether this relates to copyright, patents, marks, commercial secrets or other intangible assets. It is everybody's duty to prevent the disclosure and inappropriate use of Corcym's information, processes and industrial data.
Protection of Company Assets Employees and contractors shall not utilise information, assets and equipment used in the performance of their work and duties for personal ends. Each employee or contractor is personally responsible for preserving and protecting the company assets and/or resources assigned to them or with which they have been equipped to carry out their duties, ensuring efficient and appropriate use.
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3. Relationships with Patients Corcym's primary goal is to give hope to patients and their families by developing innovative medical devices able to provide an improvement in people’s quality of life. Aware of the responsibilities implicit in this goal, Corcym adopts strict quality standards for the production and distribution of its products around the world, maintaining a solid distribution chain in order to ensure their efficacy, safety and immediate availability.
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4. Relationships with Healthcare Professionals and Healthcare Organisations
Corcym recognises the value of the contribution that healthcare professionals (physicians, nursing and technical personnel, researchers, laboratory staff) make with their expertise to the development and correct, informed use of new products. Corcym is committed to promoting its products to healthcare professionals solely for the purposes for which they have received regulatory approval, providing them with complete, truthful, accurate and precise information supported by scientific validation, ensuring that their independence is not compromised in any way, particularly as regards treatment or operating paths for patients. In its relationships with HCPs, Corcym is scrupulous in its observance of all applicable standards and regulations, including those relating to transparency and the engagement of healthcare professionals, contained in the sector codes of conduct it has signed up to.
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5. Customer Relationships In its relationships with customers, Corcym acts, and requires its directors, employees, suppliers, consultants and contractors of all kinds to act, with professionalism, honesty and transparency. All communications to customers, whether of an informational, commercial or promotional nature, must be accurate, correct and truthful. Corcym avoids any form of misleading, aggressive or otherwise inappropriate behaviour. Corcym also ensures that its customers have understood the nature of the products offered, the financial conditions and any other terms provided for under the corresponding sales agreements and other agreements relating to the products offered. Any information relating to Corcym products must be consistent with the scientific results, medical best practice, approved company policies and applicable standards and legislation. Corcym guarantees its customers that its products are of the highest quality and technical suitability, and that they comply with both internal standards and those imposed by applicable legislation. Corcym also demands that the conduct of its directors, employees, suppliers, consultants and contractors of any kind be appropriate and characterised by respect, availability, courtesy and the utmost professionalism, with a level of familiarity suited to the relationship.
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6. Relationships with Suppliers and Consultants Relationships with suppliers and consultants are characterised by the utmost integrity and propriety. Corcym guarantees that the suppliers and consultants it makes use of are treated with complete equality. Suppliers and consultants are chosen and assessed on the basis of objective and verifiable criteria such as the quality of the products and services offered, value for money, technical and professional suitability to supply the products and services, as well as adherence to the principles set out in this Code and commitment to promoting and respecting the same. It is permitted to receive gifts from suppliers, as long as such gifts are limited to festivities and anniversaries, and are nevertheless of modest value and insufficient to influence the decision-making process during the course of the negotiations.
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7. Relationships with Employees and Contractors Relationships between all those who operate at any level within Corcym's organisational structure must be characterised by honesty, propriety, collaboration, integrity and mutual respect. Employees and contractors are required to carry out their duties in a diligent and professional manner, in compliance with the law, their contractual obligations, any instructions given by Corcym from time to time, and the principles set out in this Code. In the event of (potential) situations in which employees or contractors could hold personal or economic interests in conflict with those of Corcym (or their close relatives should hold such interests), and in any other cases involving significant cases of self interest, they are also required to inform their line manager without delay.
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8. Community and Institutional Relations Corcym aims to build long-lasting, mutual partnerships with public authorities and institutions in general, with the goal of contributing to the development of the regulatory and legislative framework of the healthcare sector. In its relationships with public administration bodies and anyone acting as a public official or person entrusted with providing a public service, Corcym is committed to strict compliance with applicable legislation, requiring those acting on its behalf to avoid behaviour even potentially likely to incorporate practices which are fraudulent, corrupt and/or in any case prohibited, and to inform Corcym without delay of any fraud or corruption attempt which comes to their attention. Corcym does not finance any political or trade union organisation or representative.
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9. Relationships with Competitors Corcym complies with all legislation on competition and competes in the market with fair, transparent practices centred on the quality and innovation offered by its products. Corcym requires its directors, employees, suppliers, consultants and contractors of all kinds who work on behalf of the Group to act in a fair and transparent manner, avoiding any kind of unfair competition, in compliance with the limits set out by law.
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10. Implementation of the Code and Reporting The Corcym S.r.l. supervisory board, implemented pursuant to Italian Legislative Decree no. 231/2001, ensures that the Code is kept up to date and applied, and promotes its circulation. Any (presumed) violations of the code may be reported, preferably not anonymously, to the following email address: [email protected] or by post to the following address: Organismo di Vigilanza di Corcym S.r.l. Via Benigno Crespi 17 20126 Milano Italy Corcym guarantees whistle-blowers the highest levels of confidentiality and protection against any form of retaliation.
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11. Penalty Provisions Violation of applicable laws, standards and regulations, as well as violation of the Code by employees and contractors represents, in addition to a disciplinary offence, nonfulfilment of the obligations deriving from the employment or other contract, and in the most serious cases can lead to termination of the working relationship. Penalties are decided on by the management body of the Corcym company connected to the violator, in accordance with the provisions of applicable collective labour contracts, and are proportional to the seriousness of the violation. In the event of violations of the Code by suppliers, consultants and contractors, Corcym reserves the right to terminate the corresponding contracts, without prejudice to the right to seek other legal remedy. No conduct in violation of the Code shall be considered justified or less serious if it has been made in the perceived interests of or for the advantage of Corcym.
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12. Supervision This Code has been approved by the management bodies of the Corcym companies and is valid from its date of approval. The Code is subject to updates. In this case, Corcym will provide notification of this through publication on www.corcym.com.
