Ethical codex

Pharmakos Consulting d.o.o. Zagreb (hereinafter: the Company) adopted the Code of Ethics with the aim of formulating clear and unambiguous guidelines and requirements on ethical business, both for the Company and for all those persons who are appropriately connected with the Company, to protect the values of the Company.

Success is the result of the dedicated work of qualified and creative employees who behave responsibly and respect ethical standards. To promote the establishment of the practice, the Director of the Company, by adopting this Code of Ethics, decided to prescribe and implement standard ethical rules.

The Code of Ethics represents the basic system of ethical rules of the Company and complements the provisions of the regulations of the Republic of Croatia as well as other internal acts of the Company. The Company's ethical rules represent guidelines to be followed in the performance of daily work, in relation to colleagues, business partners and other interested persons in accordance with good business practice and the reputation of the Company and its role on the market. The company expects transparent, honest, and professional behaviour from its employees in accordance with the highest standards of responsible behaviour, even in situations that are not specifically regulated by the Code of Ethics.

In its operations, the Company is committed to ensuring legal operations, which includes compliance with all legal regulations of the Republic of Croatia and other relevant external regulations, internal Company acts and contractual obligations. Also, the Company ensures compliance with and implementation of the anti-corruption law, and in its operations has adopted the principle of zero tolerance towards corruption and bribery, as well as a clear position on the prohibition and inadmissibility of all forms of corruption.

The company uses all means at its disposal to maintain and further improve its ethical standards of behaviour. Namely, transparent business operations and work in accordance with standard ethical principles can significantly contribute to increasing the success, competitiveness, and domestic and international recognition of the Company.

A professional and motivated team, following European business standards, provides design and consulting services in pharmacovigilance, regulatory affairs, and medical products, supporting business partners in achieving their strategic business goals and contributing to improving the living conditions of the population in the use of medical products.

To be a reliable, efficient, and development-oriented consultant who will focus all available resources on providing services tailored to business partners and the environment and establish himself as a leading service provider in the region in the field of design and consulting services in pharmacovigilance.

The guidelines and requirements stated in the Code of Ethics determine the obligations for the Company's Management, for the Company's employees, as well as for other legal and natural persons who are in another legally binding relationship with the Company.

All the above-mentioned persons are obliged to respect and adhere to the provisions formulated in the Code of Ethics, during the duration of the employment relationship or other contractual relationships with the Company, during and outside of working hours.

Employees and persons who perform contractual obligations for the Company and during the performance of their activities establish contact with a wide range of existing or potential clients of the Company, perform services on behalf of the Company and clearly appear in public during the performance of contractual obligations as representatives of the Company.

Diligence, honesty, teamwork, transparency are the key virtues expected of each of our employees.

Every employee is equally important, regardless of their position. The society strictly condemns any discrimination and fosters a culture of mutual respect. In relation to employees, special attention is paid to their safety and health, personal and professional development, and the application of employment policy according to clear criteria, encouraging an environment in which employees can contribute, and nurture and develop their own innovation and excellence.

Aware of the importance of sustainable business, the Company promotes compliance with stricter technological and environmental standards to reduce the risks of negative effects on the environment. The Company's operations are always focused on environmental protection and preservation of natural resources for current and future generations.

In the Company, we are responsible towards clients, employees, business partners, social and natural environment. Understanding our customers and ensuring their positive customer experience is our priority responsibility. This includes understanding their needs and the associated risks for them and for the Company. We carefully and responsibly build partnership relations with those with whom we enter business relations. As employees, we have a duty to each other, as well as to all actors, to behave professionally, with dedication and to respect each other in our work. We stand for integrity and bravely face challenges.

Honesty and sincerity are the basis of every responsible procedure. We fulfil our goals, we strive to achieve and exceed the expectations of our clients, business partners and society. We participate in the implementation of the Company's strategy and actively advocate for the achievement of strategic goals in the spirit of honesty and credibility.

Open communication and cooperation are the basis of our work. We clearly say what is allowed and what is not allowed. We actively seek and provide feedback. We share information in a timely and open manner. We give constructive criticism in an honest and fair way. For the benefit of the Company, we exchange knowledge and learn from each other. Communication is simple and understandable. We cooperate with all interested parties in good faith and professionally.

We find solutions and solve problems creating advantages and added value for our clients. We invest in the skills of our employees and the quality of the working environment. We follow contemporary trends, look for and recognize new and better methods and approaches in providing services and products to clients. Innovation is encouraged at the level of processes, organization, and internal operations, as well as at the level of complete solutions for clients, all with the aim of improving the user experience (internal and external) of clients, creating additional value for our products and services, and improving their availability.

Efficiency in everyday work is one of our basic goals. We offer our clients innovative and efficient solutions and added value to save them time and energy. We are actively working on optimizing our business processes with the aim of increasing efficiency. This allows us to devote more time to our clients.

By establishing a safe, stimulating and health-friendly working environment, we build long-term and solid foundations for the Company's operations.

In the Company, we strive for mutual relations based on cooperation, mutual respect, friendliness, and assistance. Every employee respects the dignity and personal integrity of associates, motivates them, helps them acquire new skills and knowledge, and supports them in personal development and advancement. Each employee of the Company is responsible for acting in accordance with the best standards of professional and responsible behaviour.

In the Company, we promote the expression of opinions among employees and open mutual communication.

In the Company, we are dedicated to personnel development, because we believe in the competence, loyalty, integrity, and commitment of our employees. Caring for staff development leads to proper and successful work and development of the Company.

That's why we take care of a safe and friendly working environment and strive to maintain a healthy working environment and interpersonal relationships based on respect.

It is strictly forbidden to consume and/or use alcohol, prohibited substances, drugs and/or other hallucinogenic substances at the Company's workplaces, in other places and/or on other occasions related to work for the Company and/or during work activities., as well as appearing under the influence of the same or performing actions that qualify as misuse of said funds (offering, giving, trading, etc.).

All employees must comply with occupational health and safety regulations in accordance with applicable health, safety, and fire protection legislation.

In the Company, we respect the right to privacy and the interests of all our employees, therefore we pay special attention to the protection of employees' personal data.

Every employee is obliged to respect the right to privacy of his co-workers and access to their personal data in accordance with internal rules and good customs.

The Company's employees may not use for personal gain, or disclose to a third party, any confidential information or in any other way disclose information that is prohibited by law or represents a business secret defined by the Company as such, and which is entrusted to or available to the employee at the workplace in some other way. Business secrets are also considered to be information for which it is obvious that, if disclosed to unauthorized persons, material damage could occur.

The Company's employees understand and accept the responsibility for making correct decisions based on the Company's business interests. Employees are obliged to recognize, monitor, and eliminate potential conflicts of interest.

A conflict of interest occurs when the personal activities of employees or their relationships from their private lives are intertwined with the business interests of the Company and thereby affect the objectivity of employees in making business decisions in the best interest of the Company. A conflict of interest may expose the Company to legal risks and/or the risk of loss of reputation.

The Company's employees take strict care to avoid this type of conflict of interest and adhere to internal rules that require us to recognize and properly and effectively manage a conflict of interest (business or private).

Every employee in the Company must direct his attention to the detection, prevention, and elimination of conflicts of interest. Within the scope of his duty and decision-making, the employee must always follow the interests of the Company and not his private interests.

In accordance with the provisions of applicable laws and the Company's internal acts, employees are obliged to avoid situations of actual conflict of interest, including situations that may appear to be a conflict of interest in relation to their position, work, and themselves. Employees must refrain from all activities that are in conflict with the interests of the Company and/or the interests of clients and must make decisions in an impartial and objective manner.

Prohibited manipulation is the giving or unauthorized obtaining of a benefit or obtaining an illegal advantage in exchange for a benefit. No employee or any other person acting on behalf of the Company shall offer, promise, or make payment or give any other item of specified value or demand or accept such item in order to influence public officials or other persons (or give the impression of such influence) or to obtain an unfair business advantage.

The aforementioned items of specified value include financial or other types of benefits, such as, in addition to cash, gifts, credits/loans, guarantees, discounts, honours, services, benefits, job offers, etc. There is no minimum amount or threshold that the payment is intended to for the purposes mentioned above or the gift should exceed to qualify the same as illegal or contrary to the Code of Ethics.

Also, it is necessary to avoid actions/behaviour that arouse suspicion or create the impression of corruption and illegal manipulation.

Gift giving is often part of local culture and tradition. Giving gifts during business and relations with customers can contribute to the Company's reputation and establish good business relations. It is allowed to give and receive normal gifts for business purposes.

Employees can give gifts as private individuals at their own expense (e.g., birthday, etc.).

The company strives to create a working environment where individual differences are accepted and respected. Positive or negative discrimination of any kind based on real or perceived characteristics of a particular person, including but not limited to race, ethnic origin, color, sex, religion, political or other belief, national or social origin, marital or family origin, the status, state of health, etc. is prohibited.

The Company prohibits behaviour based on intimidation of employees, especially if, as a result, employees are forced to take actions that are not in accordance with the Company's internal acts or applicable laws.

Any verbal, non-verbal or physical form of behaviour that aims at or results in the violation of a person's dignity or the creation of a humiliating and offensive environment is prohibited.

Each employee is responsible for the protection of the total material, financial and other assets of the Company and clients entrusted to his management. The assets of the Company, clients and (possibly) other third parties may be used and used only for permitted purposes in accordance with the assigned authorizations and prescribed conditions. Improper management or unauthorized sharing with third parties of assets owned by the Company or used by the Company constitutes a breach of obligations towards the Company and may even qualify as a criminal offense against the Company. Likewise, negligence, loss or unauthorized use of the Company's property may constitute a breach of obligations towards the Company.

For the purposes of this document, assets include cash, securities, tangible assets (real estate, inventory, equipment, etc.), services, business plans, customer, employee data, intellectual property, and any other personal data, copyrights, and confidential information.

Intellectual property created or purchased with Company funds becomes the property of the Company and cannot be considered private/personal property.

In addition to standard forms of intellectual property, such as patents, trademarks, and designs, which protect the Company's products, processes, services and other resources, the Company pays special attention to some special forms of intellectual property. These are business secrets, "know-how" and confidential information. These forms contain important sources of knowledge in the Company, which are particularly valuable for the Company's operations. "Know-how" and confidential data are not protected by standard intellectual property rights and need to be protected separately (e.g., by a data retention agreement).

Confidential data and intellectual property include knowledge acquired during business activities, which relate to:

1. Negotiations, contracts with business partners, customers, and other persons as well as the Company's business plans that are not known to the public,

2. Current or upcoming business transactions,

3. Research, innovations, "know-how", patents that are not protected,

4. Data on business partners, clients/customers, and employees,

5. Unpublished information about products/services,

6. Financial forecasts as well as financial data,

7. Marketing plans,

8. Other data that may affect the price of the product/service or planned actions.

The employees of the Company are obliged to protect all forms of confidential data and intellectual property of the Company, but also to protect the confidentiality of the data of business partners that they have obtained during business. Otherwise, they are responsible for the damage caused to the Company in connection with the disclosure of confidential information.

Employees and their family members may not use confidential information obtained by working in the Company, in business situations with the aim of obtaining material or immaterial benefits for themselves or related persons, nor conceal information obtained by them that may be of importance for the business decision.

Employees must, in and out of the workplace, refrain from any expression that could negatively affect the reputation of the Company.

Employees may participate and express their opinion in any organization (political, religious, or cultural) only as private individuals and must refrain from mentioning their association with the Company.

Employees must not use their right to express themselves in a way that harms the Company's reputation, that is, the Company's legitimate economic or organizational interests.

When appearing on social networks, employees must refrain from any expression that could negatively affect the reputation of the Company. The Company expects that when making statements on social networks as private individuals, the Company's employees behave in accordance with and in a manner worthy of the Company's ethical principles, especially when their activities or they themselves may be in any way connected with the Company or when it may appear that they are acting or express opinions on behalf of the Company.

The company respects the right of employees to take positions in politics and public life, but they can only perform such activities outside the workplace. While performing political activities outside the workplace, employees must not abuse their position in the Company and must refrain from behaviour that could negatively affect the reputation of the Company.

Company resources (human resources, facilities, other assets) may not be used to support political events.

In case of violation of the Code of Ethics, procedures and sanctions are applied in accordance with the principles established by the Company's internal acts. If an ethical violation is determined, the Company initiates a procedure for violation of work obligations (application of sanctions in accordance with the specific case).

Unfair business practices and illegal behaviour’s negatively affect the trust of our clients and damage the reputation of the Company and may expose us to legal measures, fines or other negative consequences. Therefore, all employees of the Company are personally obliged and responsible to act in accordance with the applicable regulations and internal rules, and to follow the spirit, purpose and rules stated in this Code. 

In case of ambiguities, remarks or need for additional information, contact us at info@pharmakos.hr.