Policy
It is the policy of ViroGene Diagnostic Products to require the highest standards of business ethics and integrity on the part of all employees and to comply with all applicable laws and regulations in the conduct of its business. To that end, ViroGene has adopted and implemented this Code of Business Conduct and Ethics.
All directors, officers, and employees of the Company are responsible for reviewing this Code and certifying annually that they have reviewed and is in compliance with the Code.
Failure by an employee to comply with this Code will result in appropriate disciplinary action, which may include termination of employment. Unless the context requires otherwise, all references to “employees” in this Code shall also refer to officers of the Company.
Scope
This Code applies to all ViroGene’s directors, officers, and employees worldwide.
Compliance With Laws And Internal Policies
The Company requires that all employees, officers, and directors comply with all laws, rules, and regulations applicable to the Company wherever it does business. You are expected to use good judgment and common sense in seeking to comply with all applicable laws, rules, and regulations and to ask for advice when you are uncertain about them. If you become aware of or have reason to believe there has been a violation of any law, rule, or regulation by the Company, whether by its officers, employees, or directors, you are expected to promptly report the matter to your supervisor, a member of the Company’s Legal Department, or contact the Ethics Committee. Employees, officers, and directors shall not discharge, demote, suspend, threaten, harass or in any other manner discriminate or retaliate against an employee because They report any such violation or belief in good faith.
In addition to laws and regulations imposed by local governments and regulatory bodies, the Company adopts its own policies and procedures from time to time. As in the case of rules and regulations, you are also required to comply with the Company’s internal policies and procedures.
Acceptance Of Costly Entertainment or Gift
In general, Company employees, officers and directors, and their relatives may not request or accept payments of money or anything of value from any government officials, customers, suppliers, or others with whom the Company does business, has done business, or may have occasion to do business. Restricted payments include, but are not limited to, any of the following:
-
Compensation (cash, kind, credit, etc.).
-
Travel, transportation, or lodging.
-
Entertainment including, but not limited to, tickets to sporting and other events, business meals, and other business-related entertainment activities (golf, tennis, etc.) unless approved in advance by your supervisor or a member of the Company’s Legal Department or ancillary to a legitimate business meeting attended by the person or company providing the entertainment.
-
Gifts of any kind, nature, or description, including discounts, coupons, and other offers not available to the public in general, provided, however, that employees may accept branded promotional items and annual holiday gifts (other than cash) having a reasonably estimated fair market value of $100.00 or less, provided the facilities are consistent with customary industry practices and applicable law. They could not reasonably be construed as a bribe or payoff. For guidance on gifts that do not meet this criterion, please get in touch with a Company’s Legal Department member.
Honest And Ethical Conduct and Fair Dealing
Employees, officers, and directors should endeavor to deal honestly, ethically, and somewhat with the Company’s suppliers, customers, competitors, and employees. Statements regarding the Company’s products and services or otherwise must not be untrue, misleading, deceptive, or fraudulent. It would help if you did not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair-dealing practice.
Equal Employment Opportunity
ViroGene’s policy is to afford equal employment opportunities to all individuals of any race, color, religion, sex, national or ethnic origin, sexual orientation, disabled veteran or veteran of Vietnam era status, and age with due regard to their relative qualifications and abilities. ViroGene’s Equal Employment Opportunity Policy applies to recruitment, hiring, promotion, demotion, transfer, discipline, layoff, termination, rates of pay, selection for training, and every other type of pre- and post-employment personnel activity.