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Our Principles
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Our Principles
At GBT, we know that our main responsibility is with those who, in one way or another, use our products: our patients, their families, their loved ones and the health-care professionals. Being close to them is a privilege we should thank and inexorably respond. Their needs and dignity are our focus.
We are also responsible for our suppliers, employees, and business partners. The quality of our products, the fair compensation for the tasks performed, and a professional, healthy and safe work environment, where development opportunities are provided, are all reasons for our constant concern, and we watch over these issues at all times. Therefore, we understand that our employees must be able to bring their opinions and offer their suggestions.
GBT has assumed the obligation to its investors, employees, customers, business partners, and the community in general, to establish clear guidelines on how GBT conducts its business. These guidelines should apply always to the behavior of all those who participate in one way or another in our business relationships.
At GBT we truly believe that our actions must be professional, fair and guided by the best ethical standards. Also, our business must be carried out responsibly. We must improve every day and learn from our experiences, whether positive or negative. If we act in accordance with these guidelines, which we call Our Principles, we will have managed to give the best of each one of us, we will have served the interests of our shareholders, the interests of the community and, above all, the
Our Principles
interests of those who need and use our products. They all trust us daily, and our obligation is to reward such trust with ethical and transparent actions, and always comply with the applicable laws.
Our Principles are the pillars on which we have built our internal policies and procedures. All our actions are important. If we act honestly and always worry about doing the right thing, over what could be more comfortable or convenient, without any doubt we will be living by Our Principles.
I am proud to present Our Principles and lead a Company that understands that ethics, morality, and acting correctly is the only way to restore the trust that our shareholders and investors, our patients, business partners, and the medical community in general, place in us every day
Federico Wintour Chief Executive Officer
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Our Principles
1. What are Our Principles?
2. Promotional Activities and Interactions
with Health-Care Professionals
3. Safety, Efficiency, and Quality Control
of Our Products
4. Anti-Corruption and Anti-Bribery Laws
5. Anti-Monopoly and Defense of Competition Laws
6. Political Activities and Contributions of Funds to Political Parties
or Political Campaignss
7. Public Procurement - Sales to Government Entities
8. Proper Purchases
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9. Laws and Regulations on Sustainability and the Environment
10. Privacy
11. Hiring of our staff
12. Use of Social Media
13. Financial Integrity and Protection of GBT Assets
14. Responsible Use of GBT Properties and Assets
15. Respecting Trade Secrets and Confidential Information
of Third Parties
16. Compliance with Stock Market Laws and Use of Insider Information
17. What is a “Conflict of Interest”?
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Table of Contents
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Our Principles
What are Our Principles?
The values and principles (“Our Principles”) that serve as a guide to our daily actions and must govern our behavior and decisions. Our Principles include the basic requirements upon which our business is founded and are the pillars of our internal policies and procedures. Our internal policies and procedures provide additional guidance on how we must act, and what is expected of each one of us.
Why do we have Our Principles and must comply with them?
To ensure the sustained and sustainable operation of our business, and to maintain and strengthen our reputation as a Company that prioritizes and puts our patients’ needs, as well as the needs of those whose lives we touch around the world, before our own. It is our obligation to live and act in accordance with Our Principles and contribute to an ethical, legal, and fair work environment that makes us deeply proud.
If we become aware of a violation to Our Principles, to our internal policies and procedures, or to the applicable laws, we must report it, so as to solve the problem and help prevent future behaviors contrary to Our Principles.
Correcting violations to Our Principles may require experts’ advice, as well as taking disciplinary measures, which may range from a warning to the dismissal of the person or persons who have committed the violation, including communication to competent authorities, as the case may be.
Each of our employees is responsible for reporting any situation that they consider to violate, or which may violate, in any way, Our Principles, our internal policies and procedures, or the law.
In the following chapters of Our Principles we will find the channels to report complaints, but also to request guidance on how to proceed in case of doubts or violations, or possible violations, to Our Principles:
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Our Principles
In summary, what is expected of us is:
To always act honestly, helping GBT maintain its reputation and corporate image. Therefore, we must:
• Know the rules and act accordingly.• Take interest and ask questions in case of doubt.• Always act honestly and make the right decisions, in compliance with the applicable laws, assuming our responsibility and being accountable before others, understanding that there will be situa-tions in which taking the “correct decision” may pose a challenge• Report any signs. If we believe that someone may be breaking a law or policy, we must report it. We must also report situations in which we detect retaliation against any collaborating employee who seeks advice, expresses a concern, or reports bad behavior of another employee.It is not always easy, but it is essential to make the right decisions even when they are difficult
What questions should we ask ourselves in a difficult situation or a situation suggesting a possible violation to Our Principles?
• Does said behavior implies a violation of, or jeopardizes, Our Princi-ples, a Company policy, or the law?• Is the behavior contrary to the responsibilities assumed under Our Principles?• Would the shareholders of the Company or an external observer consider the conduct unethical?• Could the behavior damage my reputation or GBT’s reputation?
If the answer is Yes to one or more of the above questions, the behavior must be avoided. In case of doubt, you must seek help. Similarly, if we become aware of a violation or possible violation to Our Principles, we must report it.
Who must comply with Our Principles?
We are all responsible for understanding the importance of the legal and ethical issues that have an impact on GBT’s business. All employees of any of the GBT Group companies must comply with the provisions of Our Principles, our internal policies and procedures, and the laws applicable to our activities.
Regardless of our position in GBT, our tasks, or the type of work we carry out, each of our employees is responsible for knowing and complying with Our Principles. Together with our internal policies and procedures, Our Principles help us make the right decisions and act accordingly.
Each of our employees is an example to other employees and our custo-mers, patients, and business partners, and has the responsibility to act in accordance with Our Principles.
Leaders or those who have management positions must not only be the example to follow, but also act as guides and help other employees to understand, apply, and comply with Our Principles.
It is essential to take into consideration and actively communicate to third parties that all persons or companies acting on our behalf also have the obligation to comply with Our Principles (in addition to applicable GBT policies depending on their tasks or activities).
We are all responsible for understanding the importance of the legal and ethical issues which have an impact on GBT’s business.
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Our Principles
Sections of Our Principles that may apply must be included in contracts with suppliers, manufacturers, contractors, managers, and distributors who do business on behalf of any of the GBT companies.
Who can help and guide us regarding Our Principles?
The first thing we must know is that we are not alone. GBT has organized and made available procedures to help us comply with and live by Our Principles, GBT’s internal policies and procedures, and the law.
Compliance Department members, together with the leaders of each of the Company’s departments, are highly qualified to help you carry out the different tasks and activities that make up the GBT business, compl-ying with the laws and GBT’s internal policies and procedures. They shall also help you to understand the rules that regulate our interactions with health-care professionals and public officials, as well as personal data protection and privacy regulations which must be observed at all times.
At the same time, a summary of facts shall be submitted regularly to the Risk Committee, Audit & Compliance of the Board.
Finally, GBT offers telephone, e-mail, and website services available 24/7 to file possible violations to Our Principles.
Website:www.grupobiotoscana.com/compliance/report
Email:[email protected]
Free telephone numbers:Available for all countries. See the numbers on our website.
Means for filing complaints are independent, safe, and confidential.
Each of our employees is an example to other employees and our customers, patients, and business partners.
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What are our responsibilities regarding the compliance with Our Principles?
Every employee watches over the compliance with Our Principles, as well as GBT’s reputation and good name. Every employee must help GBT to enforce Our Principles. If you think Our Principles have been violated or believe that an activity or behavior could result in a violation to Our Princi-ples, it is your responsibility to report it.
You may choose to identify yourself or report anonymously, but you must provide as much information as possible so that the matter can be ad-dressed quickly and effectively. As an employee, you have the obligation to cooperate in any investigation carried out by GBT. Our Company does not tolerate retaliation against any person who reports or collaborates in an investigation regarding a breach or violation to Our Principles, any of GBT’s policies and procedures, or any applicable law or regulation.
Any employee who separates from Our Principles shall be subject to disci-plinary actions and could even be dismissed.
If you supervise other employees, your main responsibility is to be an example and act always in accordance with Our Principles. Your decisions must be fair and objective, and always bear in mind the best interest of GBT’s business.
Frequently discuss the content of Our Principles with employees, at least twice a year. Help them to understand the spirit and importance of Our Principles, as well as GBT’s internal policies and procedures.
Make sure that employees under your supervision are familiar with, receive training, and know the laws and regulations applicable to the GBT business, as well as GBT’s internal policies and proceduresthrough regular training and communications.
Create an environment in which GBT employees feel comfortable to speak without reservations and without fear of retaliation.
Take seriously the concerns communicated to you by other GBT emplo-yees that may jeopardize Our Principles. Think deeply if a certain matter should be notified to your superior or to another GBT department or authority. If you consider necessary, notify the issue immediately.
Take action when someone under your supervision separates from Our Principles. Support any internal investigation.
Recognize and reward ethical behavior and compliance with Our Principles.
Employees’ Obligations
Failure to comply with applicable laws and regulations may result in civil and criminal penalties, fines, imprisonment, and other disciplinary actions for GBT as well as employees who have breached the rules.
The consequences of non-compliance with the laws, include, but are not limited to, the following:
Consequences for GBT:• Accusations, fines, and other penalties due to the inappropriate behavior of employees• Negative impact on share value.• Investigations and complaints before government agencies.• Loss of business or business opportunities.• Deterioration of customer relations.• Damage to the Company’s reputation.
Consequences for patients, clients, and the community in general:• Impact on the safety or efficiency of products.• Increase in the cost of medicines.
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Our Principles
Each employee is responsible for becoming familiar with and res-pecting GBT’s internal policies and procedures, as well as the laws and regulations applicable to the promotion, sale, distribution, and manufacture of pharmaceutical products.
Our Principles are based on the deep conviction that to meet the needs of health-care professionals, patients and their families, everything we do at GBT must meet and pursue the highest quality standards and our actions must be governed by ethics and honesty.
At all times, we must comply with laws, standards, and regulations applicable to our products (such as regulations applicable to clinical research and development of pharmaceutical products, to the safety of pharmaceutical products, to good manufacturing and dis-tribution practices, to the protection of personal data, and to the promotion, marketing, and sale of medical specialties) maintaining high ethical, scientific, and clinical standards.
Everything we do at GBTmust meet and pursue the highest quality standards.
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Our Principles02Promotional Activitiesand Interactions withHealth-Care Professionals
Regulations on advertising and the promotion of medicines directly affect our business. All employees must follow GBT’s policies on interactions and promotional activities with health-care professionals applicable to their business unit, in order to ensure compliance with the laws and regulations.
Advertising material and communications must be true, complete, based on scientific evidence, not misleading, and reflect the uses and indications approved by health authorities.
Our contribution to continuing medical education and our commercial relationship with health-care professionals is also subject to strict regula-tions. All interactions with health-care professionals must be guided by:
• Laws, regulations, and other standards (such as guidelines or industry codes) in force.• GBT’s internal policies and procedures.
Scenario 1 GBT is launching a drug recently approved by the local health authority. A client suggests holding a meeting for its launching, in order to inform doctors about the product, its characteristics, and therapeutic indications. Can I organize a breakfast outside the office (for example, in a conference center) and invite health-care professionals?
Yes. Organizing events of scientific content with health-care professionals is allowed.Events must be reasonable in the sense that they must not be organized in luxurious venues and their content should be focused on the strictly scientific. Likewise, all contracts related to the event must be documented as established in our policies.
Scenario 2I am carrying out promotional activities with a health-care professional and he asks me a question about a medicine that has not yet been approved for sale by the local health authority. I do not know how I should answer. What principles should I take into consideration? What can I do to be prepared for this kind of situations?
The Code of Ethics clearly establishes that promoting products not approved by the local health authority is not allowed. Check with the Compliance, Medical or Regulatory departments about the information you can share with health-care professionals.
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03Safety, Efficiency, and Quality Control of Products
To protect patients who use our products, it is essential to understand each product’s safety profile and characteristics. We are aware that products’ safety profiles and their efficiency and performance are only fully known when a product has been marketed.
Therefore, we need to have the maximum amount of information about our products and we need our employees, collaborators, and distrib-utors to share the responsibility of notifying any security, quality, or efficiency issue of our products.
We may gather information about the issues of our products in many ways: by phone, mail, e-mail, websites, observational studies, pharma-covigilance forms completed by health-care professionals, meetings or informal conversations at work, or even at social events.
We must report any problem we become aware of. The report shall be made through the channels enabled for this purpose by GBT, including the following:
An acquaintance tells me that he felt certain discomforts after taking a GBT medicine, what should I do if I become aware of adverse events to our products?Should I report it?
Yes, whenever we become aware of any situation related to a possible adverse event we must report it through the channels enabled for it.
Before reporting it, we must obtain as much information as possible in order to identify the medici-ne and the problem, so that GBT can reassess its efficacy and performance.
Websitewww.grupobiotoscana.com/countries/[name of the country]
E-mail: farmacovigilancia.[name of the country]@grupobiotoscana.com
In the case of adverse events reports, contact the local pharmacovigilance manager or access the web page of the Biotoscana Group companies for the online reporting form.
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Our Principles
04Anti-Corruption and Anti-Bribery Laws
GBT has a firm and uncompromising stance against bribery.
In compliance with international conventions and laws against acts of co-rruption and bribery in most countries around the world, GBT condemns and strictly prohibits bribes, illegal payments, influence peddling and, in general, any offer or delivery of things or items of value that may unduly influence (directly or indirectly, through third parties such as distributors, agents, managers, or any representative) a customer for placing an order, buying, or using our products.
We must be particularly sensitive to issues such as bribery and corruption involving public officials, because governments are generally both the regulators of our products and one of our biggest clients. Also, we use health-care professionals and scientists’ services, many of whom may be considered public officials in some jurisdictions.
Within this framework, it is very important:• To observe, at all times, our duty to comply with applicable local and international laws that prohibit bribery and corruption.• Not to unduly influence medical decisions of health-care professionals.• Not to unduly influence purchasing decisions of entities buying our products.
In carrying out our businesses, the approach must be:• Equitably and impartially treat our business partners, competitors, and all those who make decisions (approval, selection, purchase, or others) related to our products.
• Work with third parties that adopt high ethical standards in their business, and value honesty and transparency.• Not accept benefits of any kind (money, gifts, invitations, etc.) from businesses or possible businesses in which we participate on behalf of GBT.
Contact the Compliance Department in case of doubts or questions related to Anti-Corruption and Anti-Bribery laws.
Scenario 1I attend a meeting with a public official and he asks me to pay for a trip in exchange for helping me to get the GBT products purchased by the government agency he represents. Can I accept the request?
No. According to Our Principles, we must not offer any type of advantage or benefit to obtain or facilitate a business. On the other hand, we have the obligation to report this type of situations through the enabled channels.
Scenario 2A supplier with whom I have had a business relationship for many years offers me as a gift a cell phone as a token of appreciation. It’s an honest relationship which goes back many years and I do not think it can set an undue benefit. Can I accept it?
No, it should not be accepted. In case of doubt, approach the Compliance Department to get advice on how to proceed, taking into account the Code of Ethics and GBT’s internal policies.
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Our Principles
The first Latin American company of advanced medicines.
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Our Principles05Anti-Monopolyand Defense of Competition
Anti-Monopoly and Defense of Competition laws aim at promoting free competition and protecting consumers from commercial practices which may harm them. In general, these laws address issues such as illegal agreements between competitors whose purpose is to restrict or impede free competition or set prices or perform other anti-competitive business practices, such as market or customer allocations among competitors, or agreements to boycott other competitors.
At GBT we comply fully with all Anti-Monopoly and Defense of Compe-tition laws applicable to our business. We are all responsible for ensuring compliance with these laws and for ensuring fair treatment of customers, suppliers, competitors, business partners, and other third parties.
Contact the Compliance Department in case of doubts or questions related to Anti-Monopoly and Defense of Competition laws.
An official of a company competing with GBT offers to hold a meeting because he wants to make a commercial agreement. He does not give me any detail, but before going to the meeting and given the information he provided, I can tell that the agreement could involve agreeing prices with the competitor. What should I do? Should I attend the meeting even if it is to listen to the proposal?
No. Before accepting the meeting, we must gather more information about the type of agreement, always remembering that we cannot share pricing information with our competitors. Likewise, we must inform our supervisor and a member of the Compliance Department, in order to assess whether we are facing a risk of non-compliance with any Anti-Monopoly or Defense of Competition rule. We must avoid any kind of anti-competitive practices.
06Political Activitiesand Contributions of Fundsto Political Parties or PoliticalCampains
Our employees are free to contribute, during their free timeand with their own money, to candidates and political parties and to non-profit organizations.
It is not allowed to use or contribute, directly or indirectly, GBT fundsor assets (including, for example, permission to use our offices or other equipment or assets, and even our time as GBT employees) to political parties, candidates, or political campaigns, except if approved by the Financial and Compliance departments.
We are all responsiblefor ensuring compliance with these laws and ensuring fair treatment.
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Our Principles07Public Procurement - Sale to Government Entities
Government authorities and departments may be GBT clients in different countries. In many countries, public entities, such as public hospitals, certain health plans, and health insurances, as well as other institutional buyers, are subject to strict local laws and regulations that regulate the way in which these institutional purchasers and agencies buy products and services.
As suppliers of products, we are also required to comply with these laws and regulations. GBT employees who participate in bidding processes, offer our products to any government authority or to the buyers detai-led above, must understand and comply with public procurement rules. These regulations may be complex, but are of great importance to the GBT business.
In case of doubt, the Compliance Department can provide guidance on these regulations.
My supervisor asks me to contact a member of the local Ministry of Health to execute an agree-ment for the sale of our products, and he highlights that the agreement must be executed directly, according to what he talked with the representative. However, I know that GBT has certain proce-dures for sales to government agencies. Do I have to comply with my supervisor’s order?
Of course not. In these situations, we must proceed in compliance with all internal lawsand rules, and we must always act honestly and transparently. In addition, the event must be reported to the GBT Compliance Department so that they assess the case and carry outthe necessary investigations, if applicable.
GBT purchases different items and supplies necessary to carry out our business, for example, raw materials for research, development, and manufacture of products, supplies and equipment for our offices, and catering services for our meetings. In all purchases on behalf of GBT, we must always act fairly and impartially with providers and service providers in accordance with our policies and procedures.
We must not engage in conduct that could be considered as “Conflicts of Interest” or that may be considered to affect or could affect our impartiality when recommending or deciding to hire a certain provider. For example, we must not accept gifts or invitations from suppliers or service providers.
Proper Purchases
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Our Principles09Laws and Regulations on Sustainability and the EnvironmentOur Principles require that we maintain in good state and care the properties we use, and that we protect the environment and natural resources. Our production processes and our marketing chain are designed to contribute to the care of the environment, in order to reduce the impact of our operations in the environment, reduce waste, and promote recycling.
10PrivacyDuring our commercial activity, GBT collects and stores informationand personal data of employees, business partners, patients, health-care professionals, and others. This information usually includes, among others, birth dates, post or e-mail addresses, and commercial, financial, medical information. When we collect, process, and store personal infor-mation and data, we must comply with applicable local laws, as well as the Company’s privacy policies. Personal information must be collected only for legitimate business purposes, shared only with those who are allowed to access, protected in accordance with security policies and be kept only during the necessary or allowed time.
When we allow third-party to access to personal information collected by GBT, we must ensure that the holders of said information have given us their written consent for us to share their personal information with third parties, and that said third parties assume the obligation to protect such personal data.
Hiring of our Staff
At GBT we believe that our success depends on the people who are part of our work teams. We value a diverse and inclusive culture, with members who can provide different perspectives on the challenges and decisions we shall encounter daily. Our Principles value and reward ethical behavior, respect for the law and for others, and integrity in decision-ma-king process. We provide a safe and healthy environment for our employees, equal treatment, promotions based on merit, abilities, and achievements of our employees. We do not tolerate discrimination based on the characteristics of persons, such as age, sex, race, ethnic origin, sexual orientation, nationality, or religious beliefs. Also, we do not tolerate, and are firmly committed to avoiding, any type of harassment.
We do not allow harassment or offensive behavior that may interfere with a person’s ability to carry out their work. For there to be harassment it is not necessary that is an intention to offend. Inappropriate behaviors such as jokes, teasing, or even praise may involve harassing behavior and must be avoided. These provisions apply to interactions with employees, customers, contractors, suppliers, and employment candidates, and any other interaction in which we represent GBT.
Each of our employees is responsible for caring for the work environment and protecting and defending a safe and healthy work environment. The-refore, it is the obligation of our employees to promptly report to supervi-sors conditions or conducts that may put the work environment at risk, or comply with all applicable policies, laws, and regulations in labor matters. Child labor and illegal, abusive, or forced labor are strictly prohibited both for us and for the third-party suppliers.
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Our Principles12Use of Social Media
“Social media” includes any digital communication channel that allows to create and share content, posting comments, and interacting with different persons or groups. As GBT employees, we must comply with all GBT policies when using online media. Our policies are applicable to both communications related to work responsibilities and personal communications that may affect GBT. In our personal activities in social media, GBT employees must always be educated, respectful, and remem-ber that our behavior can affect both our reputation and GBT’s reputa-tion. We must always remember that the internet is a public place and that the contents that we create and publish come out of our domain.
I have an opinion about the political situation in my country. Can I express my personal political affiliations and my opinions through a social network?
Yes. However, always being of others and clarifying that the opinion expressed is personal and not of GBT.
Financial Integrity and Protection of GBT AssetsTo ensure our integrity in financial matters, compliance with applicable regulations, and transparency with our shareholders, we must keep complete and accurate financial records at all times, that accurately and truthfully reflect GBT’s financial situation and earnings. It is also essential to protect GBT’s assets and confidential information.
Why is financial integrity important? Because it helps us to maintain the trust of our shareholders, governments, patients, health-care professio-nals, business partners, suppliers, and other third parties with whom we interact or may interact.
We are a publicly traded company and we have commercial activities in many countries. We must always keep accurate books and records that adequately reflect our financial situation and that can be used as basis for making good business decisions. The laws require us to be honest and accurate in our financial records.
Negative effects derived from inaccurate financial statements could lead to the loss of confidence of our shareholders, the negative impact of our reputation, and possible fines and penalties. Given the great importance of financial integrity and the protection of our assets, we have designed and implemented various internal controls and procedures to ensure that company records are kept, stored, and destroyed in accordance with GBT requirements and the legal regulations in force. Each employee, regard-less of their position, is responsible for complying with policies and procedures that affect GBT’s financial resources and assets.
Some examples of these processes and controls to protect our financial integrity are:• We sell and buy products and services based on qualityand fair market price, and we never allow to be influencedor to intend to influence us with payments, gifts, invitations, favors,or advantages of any kind.• We record sales, income, and payments of our companies during the corresponding accounting period, in accordance with generally accepted
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accounting principles (internationally, IFRS).• We prohibit the use of Company funds, assets, or information for any illegal purpose, including bribes.• We keep accurate books and records of the Company and do not, under any circumstances, make false entries.
Some recommendations to protect our financial integrity include:• Always comply with the applicable legal regulations, as well as GBT contracting and purchasing practices and policies.• Follow the methods for approving payments to suppliers.• If you are not sure what the policies are, check with your supervisor.• Make sure that all payments or use of Company funds are reviewed and approved by the appropriate supervisor.• Submit your expenses in an adequate and clear manner, including receipts and the reason for the expense (which should always be related to the GBT business). Never request reimbursement for personal expenses or expenses not authorized by GBT.
Scenario 1 I am aware of a fact that could negatively affect the value of GBT’s assets and it may be better not to report it. Acting in this way, am I protecting GBT?
Although we believe that we are protecting the assets and interests of GBT, failure to report this type of event could seriously damage GBT. We must always act in accordance with the laws and internal regulations as otherwise we would be failing to comply with them, which could have serious consequences for GBT. Therefore, these cases should always be reported.
Scenario 2A provider requests that we use another payment method established by GBT and asks me to pay to a third party account and does not want to explain the reasons for their request, nor does it provides me with supporting documentation. What should I do?
We must always respect the payment methods approved by GBT. Additionally, in a case such as the one described, we must report it to our supervisor and the Compliance Department so that they can solve the situation with the provider accordingly.
Scenario 3I am going on vacation to a place where I will not have an internet connection. During that time, I should make certain approvals necessary for the fulfillment of my tasks. As I will not be able to access the system, I thought of leaving my username and password to a colleague to do soin my absence. Would it be right to proceed in this way?
No. We must be extremely careful with our personal information and we must not provide our personal passwords to anyone (not even our family members). In these cases, it is allowed to delegate certain actions to other employees. We must also notify our supervisor in advance that we will be absent. Therefore, we would not breach the security of our systems, we would comply with our obligations, and we would not compromise any member of our team.
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In order to successfully carry out GBT’s business, we depend on certain properties and assets that GBT employees use in our daily work. We are entrusted with computers, mobile devices, vehicles, facilities, equip-ment, raw materials, finished products, and intellectual property rights, among other assets. All GBT assets and properties must be used only as permitted by the applicable law and for GBT’s benefit. Privacy of information sent to, received from, or stored in GBT systems is not guaranteed. All documents, including electronic communications, are subject to review at any time.
Through our computers or mobile devices, we access confidential GBT information. It is our duty to carefully protect this information, creating strong passwords that cannot be easily guessed, and we must never share.
GBT information must not be stored in services or servers other than those expressly authorized by our internal policies. Storage using services other than those allowed could put our information at risk and make it accessible to unauthorized persons, which could result in severe property damage to GBT.
14Responsible Use of GBT Properties and Assets
In this regard, we must bear in mind that GBT’s intellectual property and confidential information are irreplaceable assets that form the basis of our business. We must ensure and protect its use at all times. Intellectual property includes patents, trademarks, package and packaging designs, brand names and logos, inventions, and trade secrets. We should never discuss or share information regarding these assets in public places, such as hotels, airports, and restaurants. We must communicate immediately to our supervisor any suspicion of violation or misuse of GBT’s intellectual property or of disclosure to, or unauthorized access to by third parties.
Some examples of confidential information include:• Detailed sales information including customers, volumes, and prices.• Objectives, strategies, or commercial forecasts.• New products information.• Licenses in negotiation process with our business partners.
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We are a listed company. We are required by law to communicate and publish relevant information about our Company, such as sales, licensing agreements or significant acquisitions, regulatory matters, and other rel-evant issues. When we communicate this information to the public, we must do so completely, accurately, comprehensibly, and at the right time. As GBT employees, we may have access to relevant information about the Company before it is communicated to the public, we must always maintain the confidentiality of the information which is not public.
If, as employees, we have relevant information that has not been com-municated to the public, we cannot buy or sell GBT shares, nor disclose information that is not of public nature to relatives, friends, or any other person external to the Company, nor make recommendations to relatives, friends or others who buy or sell GBT shares.
Complying with the stock market laws goes beyond our Company and may result in serious penalties for non-complying employees.
Compliance with Stock MarketsLaws and Use of Insider Information
15Respecting Trade Secrets and Confidential Information of Third Parties
At GBT we respect trade secrets and confidential information of other companies and individuals. If we need information from third parties,we collect it from sources in the public domain and do not allow the collection of information belonging to other people that may be in violation of their rights or laws.
To find information about a competitor, we consult public sources: media, marketing publications, the internet, public records, and other public documents. We must always avoid conversations about confiden-tial information with competitors’ employees, including those that may occur within the framework of meetings of professional associations or meetings of the pharmaceutical sector. We must never deceive our interlocutors about our identity or our work so as to obtain competitors’ information.
I have found a very good research article on the internet and I would like to share it with clients and colleagues, can I do it?
The specific case must be analyzed to answer this query. Remember that the information obtained on the internet or in our internal systems is often protected by intellectual property rights of third parties and the permission of a third party may be needed to share said information. Likewise, it is important not to use the work of others as your own. In case of doubt, ask the Compliance Department.
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Our Principles17There is a conflict of interest when our personal, social, or economic interests are above the interests of the company. The appearance of a conflict can damage your reputation or that of the company. Howev-er, many potential conflicts of interest can be resolved in a way that is simple and acceptable to all.
Personal relationships influence or could influence our decisions as GBT employees, as well as the objective performance of our tasks as GBT employees (and for the benefit of GBT). Even the appearance of a con-flict of interest can put our Company at risk.
As employees, we must never allow a personal benefit to interfere with our obligation to always act in the best interest of our Company. Some-times it is not entirely clear if an activity or relationship creates a conflict of interest. In such cases, GBT employees must turn to their supervisors or a member of the Compliance Department and ask them how to handle the situation.
Receiving gifts, invitations, payments, services, or items of valueof our suppliers, customers, business partners, or any third party who does or wants to do business with GBT, is not allowed, to ensure that we maintain professional, honest, and objective relationships with them, thus avoiding conflicts of interest. Gifts or invitations can be accepted only if they are of meager value, are not in cash or cash equivalents, and do not influence our actions or decisions as GBT employees.
What is a “Conflictof Interest”?
Our internal policies include clear and specific guidelines on the offer of gifts, invitations, payments, services, and benefits to health-care profes-sionals and public officials.
Although it is difficult to define what is “meager value”, it is best to usecommon sense. If you are offered something of a value that exceeds the symbolic, you should consult your supervisor or the Compliance De-partment. If you think that accepting the gift or benefit would make an impartial third party think that your judgment as a GBT employee could be affected, the gift or benefit must be rejected.
If you have a personal relationship with a GBT provider, customer, or business partner, or with a potential GBT supplier, customer, or business partner, we need to make sure that the final decision is based on objecti-ve criteria. Reveal your relationship to your supervisor.
As employees, we must never allow a personal benefit to interfere with our obligations.
Contact Information
Corporate policies and procedures
Direct access to the Compliance department
t. +598 2626 2344 Version SET2019
